By telephone call on February 25, 2013, Respondent self disclosed to EPA that one drum of cleanup debris from a pole top transformer spill was manifested incorrectly by their contractor in violation of protocol, and was consolidated with non-TSCA waste and disposed at a non-TSCA facility. The Respondent hired a new contractor and reinforced its protocols. 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 which reflected a reduced penalty. EPA has determined that the material may stay in the landfill because it had been diluted to a non-detectble level and because, if the Respondent followed notification and manifesting procedures correctly, it could have been authorized to be disposed there.