8/5/14 - PURSUANT TO THE AUDIT POLICY, AND BASED ON INFORMATION PROVIDED BY HUNTINGTON COLLEGE, THE EPA MAKES THE FOLLOWING FINAL DETERMINATION FOR THE FEDERALLY ENFORCEABLE VIOLATIONS AS IDENTIFIED ABOVE: THE COLLEGE DID VIOLATE THE REGULATIONS CITED IN ATTACHMENT A; HOWEVER, THE SELF-DISCLOSURE MET THE CONDITIONS OF THE AUDIT POLICY FOR 100 PERCENT ELIMINATION OF THE GRAVITY-BASED PENALTIES FOR THESE VIOLATIONS. THUS, THE EPA WILL NOT SEEK GRAVITY-BASED PENALTIES FOR THESE VIOATIONS. IN ADDITION, FOR PURPOSES OF THIS DISCLOSURE, THE EPA WILL NOT SEEK THE ECONOMIC BENEFIT PORTION OF THE PENALTIES.
CONSISTENT WITH THE PURPOSES OF THE AUDIT POLICY, AND AS AGREED TO IN ITS DISCLOSURE AND IN THE JUNE 22, 2007, AUDIT AGREEMENT, THE EPA EPECTS THE FACILITY TO INSTITUTE, ON A CONTINUING AND CAMPUS-WIDE BASIS, THE INTERNAL AND PROCEDURES NECESSARY TO PREVENT RECURRENCE OF VIOLATIONS OF ENVIRONMENTAL REQUIREMENTS.