NJSCC acquired on old manufacturing site for construction of a grammar school. The site had PCB Transformers. NJSCC disclosed to EPA (not an audit policy disclosure) violations of the PCB rules regarding labelling, storage, and notification. A 40% reduction was applied to these counts. EPA later discovered a violation of the manifesting rule. All PCBs have been removed from the site, and the site remediated under the TSCA rules.