EPA IS REFERRING THIS CASE TO DOJ AS A RESULT OF VIOLATIONS OF THE PCB RULE PROMULGATED UNDER TSCA BY THE SCHOOL DISTRICT OF PHILADELPHIA BOARD OF ED AT A NUMBER OF SCHOOLS IN THE CITY OF PA. THE SCHOOL DISTRICT OWNS AND OPERATES APPROXIMATELY 300 SCHOOLS WITHIN THE CITY OF PA, SOME OWNED BY THE DISTRICT AND SOME OWNED BY PECO ENERGY; SOME CONTAIN OIL. SOME DO NOT. IT IS BELIEVED THAT 33 TRANSFORMERS LOCATE D AT 14 SCHOOLS ARE PCB OR PCB CONTAMINATED AND OWNED BYTHE SCHOOL DISTRICT. THIS ACTION PERTAINS PRIMATILY TO THOSE 33 PCB AND PCB CONTAMINATED TRANSFORMERS AND 14 SCHOOLS. THE SC HOOL DISTRICT HAS VIOLATED THE FOLLOWING REQUIREMENTS 1) FIRE REGISTRATION; 2) COMBUSTIBLE MATERIAL; 3) QUARTERLY VISUAL INSPECTIONS ; 4) MARKING; 5) DISPOSAL; 6) RECORDKEEP- ING; 7) PCB CLEANUP INITIATION; 8) PCB CLEANUP CRITERIA, AND 9) ELECTRICAL PROTECTION. BY THIS REFERRAL, EPA SEEKS AN INJUNCTION REQUIRING THE SCHOOL DISTRICT TO TAKE CERTAIN STEPS TO COMPLY WITH THE PCB RULE AND ENSURE THAT VIOLATIONS DO NOT REOCCUR IN THE FUTURE ALTHOUGH TRANSFORMER REMOVAL IS NOT LEGALLY OR TECHNICALLY MANDATORY, EPA BELIEVES THE BEST WAY TO ENSURE FUTURE COMPLIANCE HERE IS FOR THE SCHOOL DISTRICT TO REMOVE ALL OF ITS PCB AND PCB CONTAMINATED TRANSFORMERS.