ON SEPTEMBER 27, 2007, EPA ISSUED A NOTICE OF DETERMINATION ( NOD ) PURSUANT TO THE FINAL POLICY STATEMENT ON INCENTIVES FOR SELF-POLICING: DISCOVER, DISCLOSURE, CORRECTION, AND PREVENTION OF VIOLATIONS . THE NOD IS BASED ON SELF-DISCLOSURES PROVIDED BY SAFETY-KLEEN SYSTEMS, NC. FOR VIOLATIONS OF THE PCB RULE, DISTRIBUTION IN COMMERCE OF PCBS. THE VIOLATIONS TOOK PLACE AT THEIR VINTON, VIRGINIA AND FAIRLESS HILLS, PENSSYLVANIA FACILITIES AND WERE DISCLOSED BY LETTERS DATED MAY 18, 2004 AND APRIL 12, 2006 RESPECTIVELY. SAFETY KLEEN DID NOT SATISFY ONE OF THE CRITERIA FOR 100% PENALTY REDUCTION, AND THEREFORE DID NOT QUALIFIY FOR TOTAL RELIEF UNDER THE SELF DISCLOSURE POLICY. AS A PART OF ITS ENFORCEMENT DISCRETION, EPA ISSUED A NOD/NOTICE OF NONCOMPLIANCE (NON) TO SAFETY-KLEEN AS THERE WAS INSIGNIFICANT ENVIRONMENTAL HARM; THE PCB WASTE AS TIMELY DISPOSED OF; AND SAFETY KLEEN FULLY COOPERATED WITH EPA IN RESOLVING THE ISSUES. EPA WAIVED THE TOTAL GRAVITY-BASED CIVIL PENALTY FOR THESE VIOLATIONS, WHICH WOULD HAVE BEEN $51,582.