9/27/05 - NOTICE OF DETERMINATION ISSUED. IN ITS DISCLOSURE LETTER TO EPA DATED SEPTEMBER 17, 2001, GREEN TOKAI DISCLOSED THAT ITS FACILITY LOCATED IN MAYSVILLE, KY, MAY HAVE VIOLATED SECTION 301 OF THE CWA BY FAILING TO PROPERLY IDENTIFY THE FACILITY'S CATEGORICAL DISCHARGE TO THE CITY OF MAYSVILLE POTW; SECTIONS 3002 AND 3004 OF RCRA BY FAILING TO COMPLY WITH STANDARDS AND REQUIREMENTS APPLICABLE TO LARGE WASTE GENERATORS AND OWNERS AND OPERATORS OF HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL FACILITIES; AND SECTION 313 OF EPCRA BY FAILING TO SUBMIT SARA 313 FORM R REPORT TO THE KY DEP FOR THE YEARS 1997, 1998, AND 1999. GREEN TOKAI REPORTED THAT THE VIOLATIONS WERE DISCOVERED IN THE COURSE OF A VOLUNTARY, SYSTEMIC, AND OBJECTIVE ENVIRONMENTAL AUDIT. THE AUDIT WAS CONDUCTED BY EHS TECHNOLOGY, INC., A THIRD-PARTY ENVIRONMENTAL CONSULTING FIRM UNDER THE DIRECTION OF OUTSIDE LEGAL COUNSEL