EPA v. CARROLL UNIVERSITY NOD

Case summary

On February 23, 2011, the Regional Administrator signed a Final Determination in connection with violations self-disclosed by Carroll University. Following a campus-wide audit required by an Audit Policy Agreement between the U.S. Environmental Protection Agency and the Wisconsin Association of Independent Colleges and Universities, Carroll University submitted an Initial Disclosure Report on May 5, 2010 disclosing possible non-compliance with the Clean Air Act, the Clean Water Act, the Resource Conservation and Recovery Act, the Emergency Planning Community Right-to-Know Act, and the Toxic Substances Control Act. Based upon a December 2010 Final Compliance Report, EPA concluded that Carroll University had met all of the criteria set forth in the Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, otherwise known as the Audit Policy. EPA mitigated the civil penalty by 100% and determined that any economic benefit Carroll University would have obtained from the self-disclosed violations is insignificant.

Defendants (1)

• CARROLL UNIVERSITYNamed in settlement

Facilities (2)

• CARROLL COLLEGE

  100 N. EAST AVENUE, WAUKESHA, WI, 53186-3103

• CARROLL COLLEGE

  100 N EAST AVE, WAUKESHA, WI, 53186

  Registry ID: 110005449434

Statutes cited

• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste
• CAA 608 — National Recycling & Emission Reduction Program
• CAA 112 — Hazardous Air Pollutants

Enforcement conclusions (1)

• CARROLL UNIVERSITY NODentered 2011-02-23

  Primary law: CAA

Timeline (2 milestones)

• 2011-02-23Final Order Issued
• 2011-04-01Enforcement Action Data Entered