'CAFO issued 9/10/2002, assessing a penalty of $7,012. Respondent also agrees to complete a SEP. Respondent failed to maintain necessary records for 18 pole-top transfomers located in the upper storage for reuse area and 116 pole-top transformers and five pad-mounted transformers located in the lower storage for reuse area. Respondent failed to notify EPA of their PCB waste handling activities. Respondent failed to conduct monthly inspections and maintain relevant records. Respondent failed to dispose of PCB Article Containers within one year of when the the Article Containers were placed into storage for disposal.