A self-disclosure regarding violations was submitted to the EPA on October 19, 2011. The disclosure indicated that the company had failed to file TRI Form R reports for copper, nitric acid and nitrate compounds for calendar years 2005, 2006, 2007 and 2009 as required by Section 313 of the Emergency Planning and Community Right-to-Know Act. The required Form R reports for these three chemicals were submitted on October 7, 2011.