Bollman disclosed that it failed to file accurate TRI Form Rs for toluene for the years 2002 through 2004: the TRI Forms that they submitted for those reporting years were not based on reasonable estimates of the quantity of toluene released from their Facility. Since the violations were not discovered through an audit or compliance management system, Bollman did not satisfy criterion one of the Audit Policy and did not qualify for full penalty mitigation. However, Bollman met the remaining eight criteria, and they agreed to settle with EPA for $8,392, which reflects the Audit PolicyÂs 75% penalty reduction from the original assessed amount, $33,566.