Recent Blog Posts

The Cost of Non-Compliance | Part 6: EPA’s Combined Enforcement Policy

June 13th, 2023

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 6: EPA’s Combined Enforcement Policy for CAA §112(r) and 40 CFR Part 68 In June 2012, the EPA revised its enforcement policy […]

The Cost of Non-Compliance | Part 5: How the EPA Calculates Civil Penalties

May 30th, 2023

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 5: How the EPA Calculates Civil Penalties – Examples of Release Notification and Tier II Example 1 | Failure to make immediate […]

The Cost of Non-Compliance | Part 4: How the EPA Calculates Civil Penalties

May 16th, 2023

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 4: How the EPA Calculates Civil Penalties – 1984 Policy & Policies for EPCRA and CERCLA Though it may be surprising to […]

The Cost of Non-Compliance | Part 3: A Historical Timeline of Major Events (1980-1994)

May 2nd, 2023

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 3: A Historical Timeline of Major Events (1980-1994) December 10, 1980 | The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) aka […]

The Cost of Non-Compliance | Part 2: A Historical Timeline of Major Events (1962-1978)

April 18th, 2023

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 2: A Historical Timeline of Major Events (1962-1978) September 27, 1962 | Rachel Carson published Silent Spring The 1960s and ‘70s were […]