FACILITY MAY HAVE FAILED TO SUBMIT MSDS INFO FOR CHEMICALS STORED ABOVE REPORTABLE THRESHOLDS; AND FAILED TO SUBMIT EMERGENCY AND HAZARDOUS FORMS FOR 1996, 1997, AND 1998. IN A FOLLOWUP LETTER TO EPA DATED 12/9/99, REAMES ACKNOWLEDGED THAT THEY HAD SOME EPCRA VIOLATIONS AT THEIR FACILITIES LOCATED IN VALDOSTA, ADEL, AND BARRETTS, GEORGIA. IN THAT LETTER, REAMES STATED THAT THEY HAD CONTRACTED WITH SOUTHERN ENGINEERING CONSULTANTS TO PERFORM A REVIEW OF THEIR ENVIRONMENTAL OPERATIONS. AS A RESULT OF THIS REVIEW AND DISCUSSIONS WITH EPA, REAMSES SELF-DISCLOSED THE VIOLATIONS. REAMES DISCOVERED THE VIOLATIONS AS A RESULT OF AN ENVIRONMENTAL AUDIT WHICH REFLECTED THEIR DUE DILIGENCE IN PREVENTING, DETECTING, AND CORRECTING THE VIOLATIONS. THE FACILITY SUBMITTED THE PROPER FORM REPORTS TO THE APPROPRIATE AUTHORITIES AND FURTHER ADDRESSED ALL NINE CONDITIONS OF EPA SELF-DISCLOSURE POLICY. A GRAVITY- BASED PENALTY OF $159,135 COULD HAVE BEEN ASSESSED.