1. THIS MATTER HAS NOT BEEN FILED. DUE TO RATHER DETAILED FACTUAL ALLEGATIONS, A SATISFACTORY COMPLAINT HAS NOT YET BEEN COMPLETED. 2. THE MATTER IS CIVIL ADMINISTRATIVE ACTION INSTITUTED PUR- SUANT TO SECTION 16(A) OF THE TSCA, 15 U.S.C. SECTION 2601 ET SEQ., 15 U.S.C. SECTION 2615(A). SPECIFICALLY, THE COMPLAINT ALLEGES THAT THE RESPONDENT EM- PLOYED PCB TRANSFORMER, BUT MAINTAINED NO INSPECTION OR RE- CORD, OF ITS TRANSFORMERS, IN VIOLATION OF 40 C.F.R. PART 761. APPENDIX B (III), INTERIM MEASURES PROGRAM, 46 FED.REG. 16090 (MARCH 10, 1981), AND, 40 C.F.R. SECTION 761.180(A). ANTIOCH UNIVERSITY VIOLATED THE PCBS MANUFACTURING, PRO- CESSING, DISTRIBUTION IN COMMERCE AND USE REGULATIONS (PCB RULE), CODIFIED AT 40 CFR PART 761. RESPONDENT IMPROPERLY STORED COMBUSTIBLES WITHIN 5 METERS OF A PCB TRANSFORMER, FAILED TO DEVELOP, MAINTAIN AND MAKE AVAILABLE AN ANNUAL DOCUMENT LOG (FOUR COUNTS).