This is an appeal by Spitzer Great Lakes Ltd. Co. ("Spitzer" or "Respondent") from an Initial Decision arising out of an enforcement action initiated by the U.S. Environmental Protection Agency, Region V ("EPA" or "Region"). The enforcement action was filed against Spitzer for seven alleged violations of the Toxic Substances Control Act ("TSCA"), 15 U.S.C. §§ 2601-2692, relating to Spitzer's handling of polychlorinated biphenyls (PCBs). Spitzer, after retaining counsel, conceded the facts alleged in the complaint and accordingly was found liable on all seven counts.