RESPONDENT AS ENVIRONMENTAL CONSULTANT TO BECKFORD REALTY TRUST SIGNED A MANIFEST CONVEYING WASTE GASOLINE/OIL TO AN OIL RECYCLER. THE OIL CONTAINED PCBS AND WAS REJECTED BY THE OIL RECYCLER WHICH WAS NOT PERMITTED TO DISPOSE OF PCBS. THE CONVEYANCE OF THE PCB-CONTAMINATED MATERIAL WAS A DISTRIBU- TION IN COMMERCE OF PCBS; WHICH IS PROHIBITED BY 40 CFR 761.20(C).