1. SECTION 16 OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), AS AMENDED, 15 U.S.C. SEC. 2615. 2. EL PASO ELECTRIC COMPANY 601 SOUTH SANTA FE STREET EL PASO, TEXAS 3. RESPONDENT WAS IN VIOLATION OF SECTION 15(1)(C) OF TSCA BY 1) FAILURE TO ADEQUATELY REGISTER PCB TRANSFORMER WITH COMMERCIAL BUILDING OWNER, 2) FAILURE TO MAINTAIN RECORDS OF PCB TRANSFORMER INSPECTIONS, 3) FAILURE TO REGISTER PCB TRANSFORMER WITH FIRE RESPONSE PERSONNEL WITH 30 DAYS OF DISCOVERY, 4) FAILURE TO MARK STRUCTURE WITH ML, 5) IMPROPER DISPOSAL OF PCBS, 6) IMPROPER STORAGE OF PCB I- TEMS - STORAGE FOR GREATER THAN 30 DAYS IN AN AREA NOT COMPLYING WITH THE REQUIREMENTS OF 40 C.F.R. SEC. 761.65 (B), 7) IMPROPER STORAGE OF PCB CONTAINERS - FAILURE TO HAVE ATTACHED NOTATION OF DATE CONTAINER WAS REMOVED FRON SERVICE, 8) IMPROPER STORAGE OF PCB CONTAINERS - FAILURE TO HAVE A PREPARED SPCC PLAN, 9) IMPROPER STORAGE FACILI- TY, 10) FAILURE TO NOTIFY EPA OF PCB WASTE ACTIVITY, 11) INADEQUATE ANNUAL DOCUMENT LOG FOR 1990, 12) INADEQUATE ANNUAL DOCUMENT LOG FOR 1991, 13) INADEQUATE ANNUAL DOC- UMENT LOG FOR 1992, AND 14) IMPROPER MANIFESTING. 4. RELIEF SOUGHT PURSUANT TO SECTION 16 OF TSCA, EPA PRO- POSES A PENALTY OF $137,100.