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McCoy's RCRA Review

June 2020

Manifest signature alternatives

Hazardous waste manifesting is a linchpin of the RCRA program, allowing the regulators and regulated community to keep track of waste from cradle-to-grave. And a critical part of manifesting is obtaining signatures from the generator, transporter, and designated facility. Unfortunately, COVID-19 has made such a simple and mundane task a health risk. To address this situation, EPA has provided some alternatives to the traditional hard-copy signature usually applied by generators.   READ MORE  

 

Deep roots

Fortune 500 chief sustainability officers agree that the COVID pandemic is driving an increase in their environmental plans, not a pullback. One Tree Planted is a non-profit that specializes in global reforestation initiatives with companies like Nestlé and AstraZeneca. Together they are planting millions of trees to offset climate change. And these programs keep employees engaged by giving them a cause to rally behind.

 

Significant changes to the development and use of EPA guidance

A proposed administrative rule will significantly change the way EPA develops, and the regulated community uses, regulatory guidance. In conjunction with the agency’s new guidance portal, there will soon be regulations governing how EPA issues, modifies, and withdraws guidance documents. The proposal is intended to ensure guidance documents are appropriately reviewed, accessible and transparent, and open to public participation.   READ MORE  

 

 

 

CCR comments continued, part deux

EPA’s proposed rule for a federal coal combustion residues (CCR) permit program had an original public comment deadline of April 20, 2020. [85 FR 9940] After a first comment extension to May 20, 2020 expired [85 FR 20625], the agency has provided yet another extension—this time to July 19, 2020. [85 FR 29878]

 

 

 

Try our Sherpa

Let the McCoy Sherpa 2020 Edition be your guide. Whether you’re telecommuting, working in the field, or managing your facility, McCoy’s Sherpa is packed full of valuable RCRA insight. With over 50,000 hyperlinks and searchable RCRA-centric content, you'll want to keep it at your fingertips. When you need to go the extra mile, our Sherpa will help shorten the journey.

 

RCRA training, your way

Though many things are still on hold, your RCRA training doesn’t have to be one of them. Join us for our next McCoy.VIRTUAL 5-day seminar, July 27-31, 2020. Our RCRA experts will present a live broadcast of our 5-day seminar. Course materials will be shipped to you beforehand, so you can catch the interactive training from any location.

Register for July McCoy.VIRTUAL

 

First SQG renotification requirement coming up

In 2021, SQGs start a four-year renotification cycle. Renotification will help keep SQG information current in the RCRAInfo database, just like an LQG’s completion of a biennial report. Though EPA Form 8700-12 is the primary vehicle for meeting this SQG renotification requirement, states may require completion of equivalent documents.   READ MORE  

 

 

 

Hazardous waste import reporting

Importing hazardous waste requires a little extra paperwork to demonstrate RCRA compliance. Facilities involved in hazardous waste imports must include additional information on the WR and GM forms in their biennial reports. EPA’s Office of Inspector General found that TSD facilities and LQGs often do not submit all of the required information, or do so incorrectly. Recent guidance for importers clarifies these issues.   READ MORE  

 

RCRA turns 40!

May 19, 2020 marked the birthday of the RCRA regulations; first issued forty years ago in 1980. Some of you have been involved with this program from its inception and some have just started your environmental management career.

We believe that RCRA has helped us to have clean parks to play in, clean water to drink, and clean air to enjoy. And that’s worth commemorating! And if you didn’t celebrate last month, it’s not too late. The effective date of the RCRA regs was November 19, 1980, so you have plenty of time to book the caterer and order the cake. Between now and November, there’s plenty of time to celebrate 40 years of RCRA compliance.

 

2020 Seminars

5-Day RCRA Seminars
.VIRTUAL: July 27–31, 2020
.VIRTUAL: August 2020
Lake Tahoe: August 24–28, 2020
Virginia Beach: September 21–25, 2020
Denver: October 5–9, 2020
Chicago: October 26–30, 2020
Las Vegas: December 7–11, 2020

2-Day RCRA Refreshers
Boston: August 4–5, 2020
Houston: November 17–18, 2020

Visit understandrcra.com to register or call us at 303-526-2674.

 



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Copyright ©2020 McCoy and Associates, Inc. 12596 West Bayaud Avenue, Suite 210 Lakewood, CO 80228

McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided in RCRA Review. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance in RCRA Review is general in nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.



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