By telephone call on October 24, 2007, Respondent notified EPA that they had inadvertently shipped one drum of PCB waste without the proper manifest. By letter dated November 16, 2007, they notified EPA of another similar violations at another site. Although these violations were self-disclosed, 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. All material was subsequently sent for proper TSCA disposal.