ON OR ABOUT NOVEMBER 13, 1991, MR. FRANCIS TRAN, A CREDENTIALED INSPECTOR FOR EPA, CONDUCTED AN INSPECTION OF THE FACILITY WITH THE CONSENT OF MR. DON KIDDER, ENVIRONMENTAL ENGINEER, TO DETERMINE COMPLIANCE WITH TSCA AND EPA REGULATIONS RELATING TO POLYCHLORINATED BIPHENYLS (PCB'S). DURING THE INSPECTION, THE INSPECTOR NOTED THAT PCB'S HAD BEEN STORED FOR DISPOSAL IN THE FACILITY DURING CALENDAR YEAR 1991. AS OF THE DATE OF THE INSPECTION, RESPONDENT HAD NOT NOTIFIED EPA OF ITS PCB WASTE GENERATION ACTIVITIES AS REQUIRED BY 40 CFR 761.205.