ON APRIL 18, 1994, U.S. EPA REGION 5 FILED AN ADMINISTRATIVE COMPLAINT AGAINST RESPONDENT ALLEGING IN 4 COUNTS THAT RESPONDENT, AT ITS 7585 VIRON ROAD N.E., FRIDLEY, MINNESOTA FACILITY, VIOLATED SECTION 15 OF TSCA, 15 U.S.C. SEC. 2614, BY FAILING TO DISPOSE OF PCB ITEMS IN STORAGE FOR DISPOSAL WITHIN ONE YEAR, BY STORING PCB'S IN A TEMPORARY STORAGE AREA FOR GREATER THAN 30 DAYS AND FAILING TO NOTIFY EPA OF THE SAME, AND BY FAILING TO DEVELOP AND MAINTAIN ANNUAL RECORDS ON ITS PCB ITEMS FOR 2 CALENDAR YEARS AS REQUIRED BY 40 C.F.R. PART 761; THUS SUBJECTING RESPONDENT TO CIVIL PENALTIES OF $60,000. THE PARTIES AGREED TO SETTLE THIS MATTER AND EXECUTED A CAFO ON JANUARY 27, 1994. COMPLAINANT AGREED TO ADJUST THE PROPOSED PENALTY IN THE COMPLAINT DOWNWARD FROM $60,000 TO $35,000 BASED UPON INFORMATION PRESENTED BY RESPONDENT DURING SETTLEMENT DISCUSSIONS WHICH: (A) WARRANTED ADJ