VIOLATIONS OF IMPROPER MARKING, 40 CFR 761.40(A)(8) IMPROPER USE, 40 CFR 761.30(D) AND DISTRIBUTION INTO COMMERCE, 40 CFR 761.20(C). - AT ISSUE IN THIS CASE WILL BE THE VALIDITY OF THE SAMPLES SHOWING PCB CONTAMINATION, BECAUSE THE COMPANY CLAIMS THAT ITS SPLIT SAMPLES ARE CLEAN.