Respondent was issued a Show Cause letter with a Consent Agreement included. Respondent had self-disclosed (not thru the Audit Policy) to EPA that they had, on three occasions, shipped PCB waste in violation of federal requirements. In one case, the waste was sent through a water treatment system and so was considered disposed in violation. Gravity-based penalty for these violations would have been $93,000. EPA accepted a settlement of $32,550.