'Respondent, through errors in manifesting, labeling, and tracking, contributed heavily to the illegal disposal of 180 PCB Large Capacitors in a non-TSCA section of Chemical Waste Management''s landfill in Model City, New York. Respondent''s facilties are not in Region 2, but because these violations took place during the course of a shipment that ended up being disposed in Region 2, and because Region 2 took a related action on the actual disposal, Region 1 agreed that Region 2 should take this action. A Notice of Opportunity Related to Enforcement Action under TSCA (a Show Cause letter) was issued on July 18, 2001. Then, in a March 15, 2002, letter, Respondent disclosed that that had also, through these same kinds of mistakes, caused the illegal disposal of a PCB Transformer at a non-TSCA facility in New Jersey. Finally, Region 1 had alerted us to two PCB spills they observed during an inspection. It was decided that these violations should be rolled into Region 2''s action.' This action was issued under the revised Part 22 regulations. In the course of the overall action, Respondent notified EPA that they had updated their tracking systems to ensure these kinds of violations would not recur.