7/27/05 - NOTICE OF DETERMINATION ISSUED. GUILDORD PERFORMED COMPLIANCE REVIEW AUDITS FOR THE YEARS APRIL 1999 THROUGH MAY 2002. RECORDS' REVIEWS REVEALED THAT (1) AN AIR CONDITIONING UNIT IN THE REGAN BROWN FIELDHOUSE RESIDENTIAL FACILITY LEAKED ABOVE THE PERMITTED 15% RATE, AND (2) THAT AN AIR CONDITIONING UNIT IN THE SHORE HALL LEAKED IN EXCEEDANCE OF THE LIMIT. IN A LETTER DATED JUNE 11, 2002, GUILFORD REPORTED THE RESULTS TO EPA, DISCLOSED THAT THEY MAY HAVE VIOLATED REGULATIONS IMPLEMENTING SECTION 608 OF THE CAA, AND ADDRESSED THE NINE CONDITIONS NECESSARY FOR ANALYZING THE DISCLOSURES. THE VIOLATIONS WERE DISCOVERED AS A RESULT OF A COMPLIANCE REVIEW AUDIT OF ITS REFRIGERANT PROGRAM WHICH REFLECTED GUILDORD'S DUE DILIGENCE IN PREVENTING, DETECTING, AND CORRECTING THE VIOLATIONS. GUILFORD RETIRED THE LEAKING AIR CONDITIONING UNIT IN THE REGAN BROWN FIELDHOUSE IN DECEMBER 2001 AND REPLACED IT IN JANUARY 2002. AS FOR THE UNIT IN SHORE HALL, GUILFORD REPAIRED THAT UNIT IN MARCH OF 2003, PRIOR TO THE MAY 2003 DATE AS REQUIRED BY 40 CFR 82.156(i)6).