The Cost of Non-Compliance | Part 10: Conclusion & Appendix A Database
Uriah Donaldson presented a technical paper at the 2023 IIAR Conference titled The Cost of Non-Compliance: An Objective Analysis of Federal EPA’s Enforcement at Ammonia Refrigeration Facilities. This blog series includes excerpts from his technical paper.
Part 10: Conclusion & Appendix A Database
The Federal EPA and its body of regulations is not likely to go away anytime soon. While it is hypothetically possible that the EPA’s reach could be limited through defunding and/or deregulation, either scenario does not seem likely. Therefore, owners and operators of ammonia refrigeration facilities must be aware of EPA’s historical enforcement and make informed decisions regarding their compliance programs.
Below is a view only link to the primary content of the database assembled and used as the foundation for this paper. Notably, facility names have not been included for the sake of privacy. Instead, EPA Docket Numbers can be used for reference.
The previous blogs in this series are available in the following links:
- Part 1: Introduction
- Part 2: A Historical Timeline of Major Events (1962-1978)
- Part 3: A Historical Timeline of Major Events (1980-1994)
- Part 4: How the EPA Calculates Civil Penalties – 1984 Policy & Policies for EPCRA and CERCLA
- Part 5: How the EPA Calculates Civil Penalties – Examples of Release Notification and Tier II
- Part 6: EPA’s Combined Enforcement Policy for CAA §112(r) and 40 CFR Part 68
- Part 7: EPA’s Jurisdiction
- Part 8: Analysis of the Database
- Part 9: Examples and Summaries of Real Inspection Reports