OLIN CORPORATION, A VIRGINIA CORPORATION, OPERATES A FACILITY IN EAST ALTON, ILLINOIS. AN INSPECTION WAS HELD BY EPA REPRESENTATIVE ON JUNE 22, 1994. THE FACILITY WAS FOUND TO HAVE 2 PCB TRANSFORMERS AND 9 PCB CONTAMINATED TRANSFORMERS. WOODEN PALLET WAS FOUND WITHIN FIVE METERS OF ONE OF THE TRANSFORMERS (300 KVA MADE BY I.T.E. IMPERIAL CORPORATION). THE LOCATION IN PROXIMITY TO THE PALLET WAS A VIOLATION OF 40 CFR 761.30(A)(L)(VIII). A RELEASE OF PCBS FROM A DEVICE KNOWN AS NA AEROFALL MILL ELECTROMAGNETIC SEPERATOR ALSO OCCURRED BETWEEN APRIL 6 AND MAY 2, 1994. THE MATERIAL WAS REMEDIATED WITH AN ABSORBENT MATERIAL. THIS PCB LADEN MATERIAL WAS THEN SHIPPED IN 2 LAIDLAW WASTE SYSTEM, ROLLOFF BOXES TO LAIDLAW'S ROXANA, IL FACILITY DURING APRIL 1994. THE MANIFESTS DESCRIBED THE WASTE SHIPMENTS AS NON-HAZARDOUS AND OIL CONTAMINATED WASTE. THE FACILITY WAS NOT THEN AUTHORIZED TO