Audit, Compliance and Risk Blog

After more than 30 years EPA defines a new Hazardous Air Pollutant

Posted by Jon Elliott on Mon, Jan 17, 2022

Since 1990, the Clean Air Act (CAA) has defined a list of Hazardous Air Pollutants (HAPs), requiring the U.S. Environmental Protection Agency (EPA) to set emissions standards for many sources of these pollutants. HAPs include heavy metals, organics, and other airborne pollutants that are not otherwise regulated as “criteria” air pollutants (such as carbon monoxide, particulate matter, and ground level ozone). The 1990 CAA Amendments included a list of 189 HAPs (later corrected to 188), and empowered EPA to modify the list. In the intervening decades, EPA conducted rulemakings and deleted four initially-listed HAPs, but until 2022 had never added a new HAP. However, EPA has now added 1-bromopropane (1-BP) as a new HAP, effective February 4, 2022.

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Tags: HAPs, Clean Air Act

National Contingency Plan now requires monitoring of chemical dispersants

Posted by Jon Elliott on Wed, Aug 04, 2021


The US government promulgates a “National Oil and Hazardous Substances Pollution Contingency Plan” – more commonly referred to as the National Contingency Plan (NCP) – as the blueprint for responses to spills of oil and hazardous substances. The NCP is used for responses under the Clean Water Act (CWA) and the Superfund law (Comprehensive Emergency Response, Compensation and Liability Act (CERCLA)), and is overseen by the Environmental Protection Agency (EPA) (although you should note that the first NCP was issued in 1968, not only before CWA and CERCLA were enacted, and even before EPA before was created).

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Tags: EPA, CERCLA, Clean Air Act, NCP

Environmental policy: what are the Democrats promising

Posted by Jon Elliott on Tue, Oct 20, 2020

As the 2020 Presidential election approaches its close, both major parties’ major environmental proposals have been formalized. As the incumbent party, the Republican National Committee decided not to adopt a formal election platform, and instead adopted a resolution promising continuity, the most substantive provision of which is “That the Republican Party has and will continue to enthusiastically support the President’s America-first agenda.” (I summarized candidate Trump’s 2016 proposals HERE, and have written dozens of blogs summarizing specific actions since that election).
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Tags: climate change, Environment, Clean Air Act, Republican Party, 2020 US Presidential election, Clean Energy, Democratic Party