Recent Blog Posts

The Cost of Non-Compliance | Part 8: Analysis of the Database

July 11th, 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 8: Analysis of the Database At the time of this paper’s publication, the database includes more than 450 inspection reports: 254 CAFOs, […]

The Cost of Non-Compliance | Part 7: EPA’s Jurisdiction

June 27th, 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 7: EPA’s Jurisdiction EPA’s 10 Regional Offices To achieve the EPA’s goals nationwide, ten regional offices were created, each with a specific […]

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 […]