REIER'S SCRAPYARD

JAMES REIER OPERATES AN ANCILLARY BUSINESS IN WHICH HE SCRAPS TRANSFORMER CARCASSES PROVIDED TO HIM BY SAM HEILDER. DURING AN INSPECTION ON NOVEMBER 4, 1991, OHIO EPA OFFICERS FOUND ONE PCB-CONTAMINATED TRANSFORMER IMPROPERLY STORED IN AN OPEN SPACE, WITHOUT ANY KIND OF COVER OR FLOORING TO PREVENT SEEPAGE OF FLUIDS INTO THE SOIL. OTHER TRANSFORMER CARCASSES ON-SITE AND AN OIL SPILL PROVED NOT TO BE PCB-CONTAMINATED. THIS ACTION WAS BROUGHT ON THE BASIS OF FAILURE TO PROPERLY STORE THE PCB-CONTAMINATED TRANSFORMEER IN A SECURE DIKED AREA, FAILURE TO PLACE A LABEL ON THE TRANSFORMER WITH THE DATE THAT IT WAS PLACED INTO STORAGE, AND FAILURE TO MARK THE AREA AS CONTAINING PCB-CONTAMINATED MATERIALS.