On June 18, 2008, EPA entered into an Audit Policy Agreement with the Wisconsin Association of Independent Colleges and Universities (WAICU), of which Marquette University is a member. The Agreement called for the participating colleges to conduct environmental audits. Following its campus-wide audit, Marquette University submitted an Initial Disclosure Report that disclosed thirty-nine violations. Later, it submitted a Final Compliance Report that described the actions taken to correct the violations. Based upon the information submitted, EPA has elected not to impose the civil penalty because Marquette University has met all nine conditions set forth in EPAÂs policy entitled ÂIncentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations (65 Fed. Reg. 19618 (Apr. 11, 2000)(Self-Disclosure Policy)). EPA has also concluded that the economic benefit of tardy compliance was not significant. A a final Notice of Determination was submitted to Marquette University.