By telephone call on February 29, 2012, Respondent notified EPA that they had inadvertently shipped PCB remediation waste without the proper manifest, and that the material had been disposed in an unauthorized facility. Respondent did not invoke the Audit Policy, since it would not apply. The self-disclosure reductions available in the PCB penalty policy were applied. EPA issued a Show Cause letter with a CAFO included which reflected a penalty. Respondent has implemented new control procedures to prevent future violations.