ON AUGUST 20, 1990, INSPECTION OF THIS MEDIUM SECURITY FACILITY REVEALED NUMEROUS RECORD KEEPING, MARKING, AND USE VIOLATIONS. PENALTY OFFSET. GRAVITY BASED PENALTY WAS REDUCED TO $38,000 UPON RECEIPT OF FACTUAL INFORMATION FROM RESPONDENT INDICATING THAT ORIGINAL CALCULATION WAS TOO HIGH. RESPONDENT WILL TEST IN SERVICE TRANSFORMERS AND REMOVE THOSE THAT HAVE CONCENTRATIONS GREATER THAN 50 PPM PCB.