EPA conducted a PCB compliance inspection at the facility in May 2006. As a result of the May 2006 inspection, EPA has determined that Cooley violated the PCB Regulations by the unauthorized use of PCBs (by using PCB-contaminated surfaces without meeting the required PCB cleanup standard) and by failing to comply with all the requirements necessary for the continued use of PCB-contaminated surfaces at its facility under § 761.30(p) (such as maintaining two coats of solvent and water resistant paint over PCB-contaminated surfaces and marking PCB-contaminated surfaces/areas with the ML Mark).