4/10/03 - NOTICE OF DETERMINATION ISSUED. ON DECEMBER 3, 2002, TRICO DISCLOSED TO EPA THAT IT MAY HAVE VIOLATED SECTION 313 OF EPCRA FOR FAILING TO SUBMIT FORM R REPORTS FOR CHROMIUM, NICKEL, AND MANGANESE FOR REPORTING YEARS 1999 THROUGH 2001. TRICO DISCOVERED THE VIOLATION AS A RESULT OF AN ENVIRONMENTAL AUDIT CONDUCTED AT ITS FACILITY ON NOVEMBER 13, 2002. TRICO ADDRESSED THE CONDITIONS NECESSARY TO DETERMINE IF TRICO WAS ELIGIBLE FOR A GRAVITY-BASED PENALTY REDUCTION OR ELIMINATION IN ITS DISCLOSURE LETTER TO EPA DATED DECEMBER 3, 2002. FOLLOWING THE DISCOVERY OF THE VIOLATION, TRICO CORRECTED THE VIOLATIONS AND SUBMITTED THE REPORTS TO THE APPROPRIATE AGENCIES ON DECEMBER 3, 2002.