ON OR ABOUT 9/18/96, AN AUTHORIZED EPA INSPECTOR CONDUCTED AN INSPECTION AT THE DEADWOOD AVENUE FACILITY INCLUDING THE BEN FRENCH SUBSTATION. THE INSPECTION REVEALED THAT A TRANSFORMER AT THE BEN FRENCH SUBSTATION WAS NOT MARKED WITH THE PCB FORMAT. THIS TRANSFORMER WAS ALSO LEAKING FLUID WITH A PCB CONCENTRATION OF OVER 9000 PPM. THE RESPONDENT FAILED TO PROPERLY DISPOSE OF THE LEAKING PCBS. A TRANSFORMER AT THE STORAGE AREA BEHIND THE MAIN BUILDING WAS ALSO LEAKING FLUID WITH A PCB CONCENTRATION OF 50 PPM. THE PROPOSED PENALTY IS $13,600.