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McCoy's RCRA Review

July 2020

EPA terminates COVID-19 enforcement policy

In light of COVID-19, EPA issued a policy memo in March describing the agency’s increased discretion when deciding whether to enforce certain environmental regulations. We summarized the impacts of that memo in a previous article. On June 29, 2020, EPA released an additional memo terminating the temporary policy. Termination is set to occur at 11:59 PM Eastern time on August 31, 2020. Based on changing conditions, EPA may terminate the temporary policy at an earlier time and, if so, will provide notification at least seven days prior to any earlier termination date.




Don’t get burned by ignitability rule

EPA’s new rule modernizing ignitable liquids determinations is effective at the federal level on September 8, 2020. The rule won’t drastically change how generators make a D001 determination, but it does bring the definition of an ignitable hazardous waste into the 21st century. Will the other hazardous waste characteristics receive a similar revamp in the near future? We’ll have to wait and see.   READ MORE  



Catch our next live broadcast, McCoy RCRA 5-Day virtual seminar, July 27-31, 2020. Our presenters cover in-depth RCRA topics while fielding real-time questions. It’s an interactive virtual experience that's remarkably similar to our in-person seminars (try it!). For convenience, course materials are provided beforehand. Keep RCRA in your sights, as you move ahead.


Attention to air standards advised

Violations of RCRA’s air emission standards are still prevalent despite being one of EPA’s national compliance initiatives for years. Periodically, EPA disseminates guidance and advisories to help affected facilities maintain compliance. Along those lines, the agency issued an “enforcement alert” in June, describing its findings during numerous compliance inspections and its expectations for demonstrating compliance. Of particular interest is the discussion of the relationship between RCRA’s air emission standards and the CAA.   READ MORE  




Sherpa territory

RCRA guidance is important and McCoy Sherpa covers a lot of ground. Our 2020 Edition includes RCRA-centric search capabilities, 500 examples from EPA guidance, Federal Register notices back to 1978, and more. Compare Sherpa with our RCRA Unraveled and RCRA Reference books. Bring the right tool with you to be prepared for whatever comes your way.


Disaster planning resources

For some areas of the United States, natural disasters are a relatively rare occurrence. Other areas will suffer the experience on a frequent basis. Waste management and disaster planning professionals now have an updated, nationwide resource to help them plan for the worst. EPA’s Disaster Debris Recovery Tool contains a list of tens of thousands of facilities capable of landfilling and recycling many different types of debris generated from these disasters. Provided contact information allows users to take a proactive approach to protect their community in times of crisis.   READ MORE  




Another method for generating e-manifest reports

The RCRAInfo Industry Application has new functionality related to e-manifests. A new tab called “Reports/Extracts” allows users to sort through facility, manifest, and waste line information based on facility type, date, and site ID search criteria. Due to the vast quantities of data the extracts pull from, it may take some time to generate the requested report. Fortunately, reports are saved so they can be referred to later.


Pollinating progress

Since 2006 honey bees and other pollinators have been in decline due to habitat loss, pesticides, and climate change. In 2015, the White House launched its national strategy to promote the health of pollinators. With over 90 commercial crops dependent on honey bees, protection is sorely needed. The Wildlife Habitat Council has stepped in to help businesses support local pollinator habitats on corporate lands.


Help! Recycle food cartons

Demand for paper products has increased substantially due to the COVID-19 pandemic. Companies are trying to increase production while the “feedstock” paper fiber supply has been diminished. It is important to recycle paper food storage products and beverage cartons to replenish the supply of paper pulp. The Carton Council is educating consumers on the life cycle of paper products and how important paper recycling is to keeping essential items in stores.




2020 Seminars

5-Day RCRA Seminars
.VIRTUAL: July 27–31, 2020
Lake Tahoe: August 24–28, 2020
.VIRTUAL: August 24–28, 2020
.VIRTUAL: September 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 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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