In July 2016, Cycle Chem notified EPA that the Respondent shipped them PCB waste that was not fully identified on the manifest. This waste was improperly disposed, but Cycle Chem was held liable and has since paid a penalty. In July 2016, the Respondent notified EPA they had inadvertently shipped similar PCB waste to Clean Earth without identifying it on the manifest - these wastes were solidified, diluted, and ultimately disposed in an unauthorized facility. EPA is not seeking removal since the concentrations were non-detect at the time of disposal. In September 2016, the Respondent notified EPA they had stored PCB waste in excess of the time allowed by the regulations. 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 of $82,275.