On June 21, 2012, EPA entered into a Consent Agreement and Final Order (CAFO) with the University of Massachusetts System (UMass) to both initiate and resolve a case against the University for illegal use of PCBs in window glazing compound at one of its buildings on the Amherst campus. After spending approximately $4,000,000 to address PCB-contaminated caulk at the building, UMass discovered that the windows had PCB-contaminated glazing compound. Forty C.F.R. § 761.20(a) prohibits the unauthorized use of PCBs in concentrations of 50 ppm or greater unless the use meets certain exceptions. Currently, the only feasible way to address this contamination is to remove 900 windows at a cost of approximately $3,000,000. The CAFO places UMass on a schedule to remove all the widows and to implement interim measures that are designed to protect people until the windows can be removed. The CAFO also includes a penalty of $75,000 that will be remitted if UMass meets its compliance obligations.