9/30/10 - NOTICE OF DETERMINATION ISSUED. IN A LETTER TO EPA DATED OCT 18, 2008, AQUINAS DISCLOSED VIOLATIONS OF RCRA. ALL VIOLATIONS WERE CORRECTED BY DEC 17, 2008.
FINAL DETERMINATION: PURSUANT TO THE AUDIT POLICY, AND BASED ON INFORMATION PROVIDED BY AQUINAS, EPA MAKES THE FOLLOWING FINAL DETERMINATION: AQUINAS COLLEGE DID VIOLATE THE REGULATIONS; HOWEVER, THE SELF-DISCLOSURE MEETS THE CONDITIONS OF THE AUDIT POLICY FOR 100 PERCENT ELIMINATION OF THE GRAVITY-BASED PENALTIES FOR THESE VIOLATIONS. THUS, EPA WILL NOT SEEK GRAVITY-BASED PENALTIES FOR THESE VIOLATIONS. IN ADDITION, FOR THE PURPOSES OF THIS DISCLOSURE, EPA WILL NOT SEEK THE ECONOMIC BENEFIT PORTION OF THE PENALTY.