This Notice of Determination was issued in response to violations voluntarily disclosed by Adrian College on 9/16/2009. EPA has determined that Adrian College met all the criteria set forth in both the Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations (4/11/2000) and the Audit Policy Agreement by and between the Michigan Colleges Foundation, the Participating Institutions and the US EPA, Region 5 . Consequently, the EPA has mitigated the civil penalty by 100%.