COUNT 1: FAILURE TO PROPERLY DISPOSE OF THE LEAKING PCBS REQUIRED BY 40 CFR 761.60. COUNT 2: FAILURE TO CONDUCT QUARTERLY INSPECTIONS OF THESE PCB TRANSFORMERS, THE USE OF SUCH TRANSFORMERS WAS AND IS PROHIBITED BY THE REGULATIONS, 40 CFR 761.20-.30. COUNT 3: FAILURE TO DEVELOP AND MAINTAIN AN ANNUAL DOCUMENT INCLUDING DATA ON PCB TRANSFORMERS CONTRAVENES THE REQUIREMENTS OF 40 CFR 761.80.