On 10/6/2010 Marian University voluntarily disclosed violations of EPCRA 312 and CWA 311/SPCC to the EPA. Based upon Marian's December 2010 Final Compliance Report and additional clarifying information provided more recently in 2012, EPA has determined that the University met each of the nine criteria in EPA's self disclosure policy ( Audit Policy in 65 Fed. Reg. 19618, April 11, 2000). Consequently, EPA has decided to eliminate 100% of the gravity portion of the potential penalty against Marian for these self-disclosed violations.