FRANKLIN & MARSHALL COLLEGE

On September 9, 2008, EPA issued a Notice of Determination (“NOD”) based on self-disclosures Franklin and Marshall College provided pursuant to the Agreement between the Association of Independent Colleges and Universities of Pennsylvania (“AICUP”) and EPA, dated March 24, 2004, regarding the Resource Conservation and Recovery Act (“RCRA”) and the Clean Water Act (“CWA”) violations at Franklin and Marshall College in Lancaster, Pennsylvania