By disclosure letter and Audit Policy Eligibility Checklist submitted September 29, 2008, Koch disclosed to EPA that their Houston, Texas facility had non-reporting violations for Chromium, Copper, Manganese, and Nickel for 2002 Â 2006. Koch has subsequently corrected and submitted the Toxic Release Inventory Form R Reports for 2002 - 2006 to the EPA and to the State of Texas. The disclosure met all 9 criteria of the Audit Policy; therefore, the civil administrative penalty was waived.