Respondent submitted a self-disclosure to the US EPA under the Audit Policy on January 26, 2010 for its Humacao, Puerto Rico facility. The disclosure stated that the facility had not properly accounted for toxic chemicals present in fuels burned on-site and that it had thus failed to file the required TRI Form R reports. Subsequently, a nationwide audit of its other 10 facilities was commenced. All required TRI Form R reports for each of the facilities in Region 2 were submitted on April 23, 2010 for years 2004 to 2008.