'Manifesting and marking violations self disclosed for two facilities of Occidental Chemical Corp. There was a self-disclosure but it was not made under the audit policy but under the PCB Penalty Policy.
This Consent Agreement will settle the civil penalty without issuance of a complaint. As allowed under 40 CFR section 22.13(b), when the parties agree to settle one or more cause of action before the filing of an administrative complaint, a proceeding may be simultaneously commenced and concluded by the issuance of a consent agreement and order pursuant to 40 CFR section 22.18(b)(2) and (3)