On 8/20/2009 Spring Arbor University disclosed violations to the Clean Water Act (CWA 311/SPCC) and EPCRA 311/312. Based on the facts and admissions contained in Spring Arbor's self disclosure, the EPA has determined that 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 has determined that Spring Arbor University did not gain a significant economic benefit by failing to comply with the above-referenced laws.