Respondent dislcosed to EPA on 12/03/2004 that they had initiated a PCB research project that included importing/exporting PCBs without filing the proper notification with EPA. This was a voluntary disclosure, but the Audit Policy did not apply. EPA issued a Show Cause letter with a CAFO enclosed. The letter explained that the penalty sought could have been $7,800.00, but the CAFO only sought the reduced penalty of $2,730.00.