EPA v. Taylor University (Upland) NOD

Case summary

Taylor University disclosed violations to EPCRA 312 in that they failed to submit Tier II forms for the following substances which were stored on site in amounts which exceed the reportable quantities of each: hydraulic fluid, sodium chloride, gasoline and sulfuric acid. EPA has concluded that Taylor University has met all of the criteria set forth in Incentives for Self-Policing: Discovery, Disclosure and Prevention of Violations as well as conditions set forth in Audit Policy Agreement by and between the Indiana Association of Independent Colleges and Universities and the US EPA, Region 5 . As a result, EPA has mitigated the civil penalty by 100%. Taylor University self-disclosed four types of violations of Clean Air Act regulations: (1) failure to file a notification of demolition/renovation for asbestos removal; (2) failure to determine if two emergency generators used at the facility meet the New Source Performance Standards requirements; (3) failure to obtain a facility permit; and (4) failure to keep track of refrigerant additions to appliances containing more than 50 pounds of refrigerant. After researching the potential violations further, Taylor University determined that asbestos notices were not required for the removal done at the university because the amount of asbestos material involved was below the regulatory cut-off amount. Regarding the emergency generators, Taylor University determined that the generators were meeting the NSPS requirements. With respect to the violation of failure to get a permit, Taylor University obtained a Minor Source Operating permit from the Indiana Department of Environmental Management. Finally, the university started keeping track of its refrigerant additions to appliances.

Defendants (1)

• Taylor University (Upland, IN)Named in complaintNamed in settlement

Facilities (1)

• TAYLOR UNIVERSITY

  236 W READE AVE, UPLAND, IN, 46989

  Registry ID: 110011951628

Statutes cited

• CAA 608 — National Recycling & Emission Reduction Program
• CWA 301/402 — NPDES Permit Violations
• EPCRA 312 — Emergency and Hazardous Chemical Inventory Forms
• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards

Enforcement conclusions (1)

• Taylor University (Upland) NODentered 2013-08-28

  Primary law: CAA

Timeline (3 milestones)

• 2013-08-28Pipeline Closed
• 2013-08-28Final Order Issued
• 2013-09-19Enforcement Action Data Entered