ON OR ABOUT 3/22/99, RESPONDENT TRANSPORTED AND/OR OFFERED FOR TRANSPORT APPROXIMATELY 171 KILOGRAMS OF LIQUID PCB WASTE IN CONTAINERS FOR COMMERCIAL OFF-SITE DISPOSAL. RESPONDENT PREPARED SHIPPING PAPERS FOR THE PCB SHIPMENT DESCRIBED ABOVE, BUT DID NOT SPECIFY ON THE MANIFEST THAT THE SHIPMENT INCLUDED PCB WASTE. THE PROPOSED PENALTY FOR THIS VIOLATION IS $5,000.