pollutant. States are required to have implementation plans and permit programs for controlling certain air emissions, including those from industrial processes such as spray painting, abrasive blasting, and vapor degreasing.

Clean Water Act

CWA regulates all sources of pollution and discharges of pollutants to navigable waters. Any addition of pollution to navigable waters is prohibited, except as provided in the conditions of a National Pollutant Discharge Elimination System permit issued by the EPA or an authorized state agency. The CWA also regulates storm water discharges, dredged or fill material, and oil spills.

Resource Conservation and Recovery Act

RCRA defines which substances are hazardous wastes and regulates their generation, transportation, treatment, storage, and disposal. A hazardous waste is defined as a substance which, because of its quantity, concentration, or other characteristics, may increase mortality or serious illness or pose a hazard to health or the environment. All generators of hazardous waste are responsible for the hazardous wastes they generate from acquisition through disposal. RCRA requires extensive record keeping and reporting.

Comprehensive Environmental Response, Compensation and Liability Act

CERCLA authorizes the President of the United States to clean U.S. facilities at which hazardous substances have been released. The Superfund is used to finance enforcement and cleanup efforts, pending reimbursement by responsible parties. The cost recovery provisions of Superfund create huge potential civil liabilities for business, since they allow the EPA (and others) to sue businesses to recover cleanup costs, which can amount to millions of dollars at a single site. The costs and damages can be recovered from a wide range of persons and businesses associated with the sites, including anyone associated with the contaminated site or the hazardous waste that contaminated the site. The important thing is to learn and review that all the facts before purchasing land or awarding an environmental services contract.

Emergency Planning and Community Right-to-Know Act

EPCRA imposes detailed chemical release and inventory reporting requirements on businesses that handle toxic, hazardous, and extremely hazardous chemi-



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