Lockheed Martin disclosed under the Audit Policy that they had shipped PCBs without a manifest, and that they had 2 pumps stored onsite that contained PCBs. The Audit claim was denied, but self-discosure reductions under the PCB Penalty policy can apply. The pumps and related materials were disposed of at a TSCA facility. A show cause letter with CAFO was issued. Respondent signed the CAFO.