On 2/18/2010, Aquinas College disclosed violations to the Clean Water Act, RCRA, TSCA and EPCRA 311/312. Based upon the facts and admissions contained in Aquinas College's self disclosure, EPA has determined that the Respondent has complied with all nine criteria of EPA's April 11, 2000 Self Disclosure Policy (Audit Policy) (65 Fed Reg 19618). Accordingly, EPA agrees to grant a 100% reduction of the gravity-based penalty. EPA also determined that Aquinas College did not gain a significant economic benefit by failing to comply with the above-referenced laws.