Brooklyn Polytech University violated a PCB rule (40 C.F.R. p 761.207(a)) in a failure to identify PCB waste submitted for off-site disposal on uniform hazardous waste manifest 8700-22. This document was simultaneously commenced and concluded by the issuance of a Consent Agreement and Final Order when the parties agree to settle one or more causes of action before the filing of an Administrative Complaint. The original proposed penalty would have been $5,500.00 if an administrative complaint had been issued.