By disclosure letter and Audit Policy Eligibility Checklist submitted November 4, 2008, Halliburton Energy Services disclosed to EPA that their Duncan Manufacturing Center had non-reporting violations, late reporting violations, and data quality errors for chromium, chromium compounds, copper, ethylene glycol, lead, manganese, methanol, nickel, and toluene for 2003 Â 2007. Halliburton has subsequently corrected and submitted the Toxic Release Inventory Form R Reports for 2003 - 2007 to the EPA and to the State of Oklahoma. EPA determined that the disclosure met all 9 criteria of the Audit Policy; therefore, the gravity-based penalty was waived.