8/5/10 - NOTICE OF DETERMINATION ISSUED. IN A SEPT 24, 2008 LTR TO EPA, REINHARDT COLLEGE DISCLOSED VIOLATIONS OF THE CWA, RCRA, EPCRA, AND THE CAA. ON APR 28, 2009, REINHARDT COLLEGE SUBMITTED A FINAL COMPLIANCE REPORT, WHICH CONTAINED ADDITIONAL INFO, INCLUDING THE CORRECTIVE ACTIONS TAKEN TO BRING THE COLLEGE BACK INTO COMPLIANCE.
PURSUANT TO THE AUDIT POLICY AND BASED ON INFO PROVIDED BY REINHARDT COLLEGE, EPA MAKES THE FOLLOWING FINAL DETERMINATION FOR THE FEDERALLY ENFORCEABLE VIOLATIONS: REINHARDT COLLEGE MEETS THE CONDITIONS OF THE AUDIT POLIYC FOR 100 PERCENT ELIMINATION OF GRAVITY-BASED PENALTIES FOR THESE VIOLATIONS. EPA WILL NOT SEEK GRAVITY-BASED PENALTIES FOR THESE VIOLATIONS. IN ADDITION, FOR PURPOSES OF THIS DISCLOSURE, EPA WILL NOT SEEK THE ECONOMIC BENEFIT PORTION OF THE PENALTY.
CONSISTENT WITH THE PURPOSES OF THE AUDIT POLICY, EPA EXPECTS REINHARDT COLLEGE TO INSTITUTE, ON A CONTINUING AND INSTITUTIONAL BASIS, THE INTERNAL POLICIES AND PROCEDURES NECESSARY TO PREVENT RECURRENCE OF VIOLATIONS OF ENVIRONMENTAL REQUIREMENTS.