Respondent shipped PCB waste for disposal without identifying it as PCB on the manifest. Contamination was discovered and waste went for proper TSCA disposal. Respondent could not identify any source of PCBs on their site, but took several measures to prevent recurrence of violation. Respondent spent $130,000 to remediate the violation, decontaminate the equipment, replace older contaminated equipment, and enhance security on their site. Final penalty paid was $20,485.