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McCoy's RCRA Review

October 2021

Finally…understand CAA

Clean Air Act experts know each facility has unique air emission issues and there’s no one-size-fits-all solution. In addition, CAA is a behemoth that takes years of experience to understand. Shorten the learning curve by attending McCoy’s CAA seminar, November 2-4, 2021, and you’ll be glad you did. Our customers share they now understand air concepts—after our training—that were mystifying before.

Register for the November CAA training
Register for the January CAA training
See the CAA agenda


Solar panels feel the heat

Solar is a rapidly growing energy source in the United States. The panels used for solar energy typically have a life span of over 25 years. When they reach end of life, they must be managed safely when sent for disposal. EPA has a web page discussing some considerations for disposing of solar panels. If your solar panels are determined to be hazardous waste, then RCRA regulations must be followed to ensure the solar panels are recycled or disposed of safely.   READ MORE  


Plenty of room for RCRA

Catch a McCoy .VIRTUAL 2-Day RCRA Refresher on November 16–17, 2021 or attend our 5-Day seminar on December 6-10, 2021. Our training provides thorough insights and clarifies the complexity known as RCRA. Our two presenters will walk you through case studies, explain waste identification, and answer questions to help you make the right RCRA decisions at your facility. Register today.

Register for our RCRA Refresher on November 16–17
Attend the 5-Day December .V RCRA seminar
5-Day .VIRTUAL Agenda




EPA has a plan

EPA announced the availability of its Draft Strategic Plan for FY 2022-2026. [86 FR 54448] This plan includes seven strategic goals focused on protecting human health and the environment along with four cross-agency strategies that describe the methods EPA will employ to carry out its mission. EPA expects the final Strategic Plan will be submitted to Congress in February 2022. Comments are due by November 12, 2021. You can submit comments through Docket ID No. EPA-HQ-OA-2021-0403, and you can view the Draft Strategic Plan online.


Borrow McCoy’s tools

Use the right tool for the job—and you’ll find many on our website including white papers, forms, and helpful links that help you speed through your day. If you’re looking for specific content (e.g., are sumps tanks?), search Compliance Corner where we clarify certain aspects of RCRA and write up the results. Or take a second look at past content published in RCRA Review. McCoy content isn’t “gated,” so you don’t need to give away your private information.

White papers, forms, and helpful links
Compliance Corner
Past content from RCRA Review




Mercury storage redux

The Mercury Export Ban Act (MEBA) was signed into law in 2008. One section of MEBA requires the Department of Energy (DOE) to designate a facility for the long-term storage of waste elemental mercury generated in the United States. The department established a fee rule and designated a long-term storage facility, but the rule was vacated by the courts. On October 6, 2020, DOE announced an amended record of decision reflecting the court vacatur.   READ MORE  


From present to past

As global temperatures increase we’re seeing indicators of a troubling shift in nature. Over 23 species of birds are proposed to be added to the extinct species list by the U.S. Fish and Wildlife Service. Birds are impacted on multiple fronts—warming trends are bringing mosquito-borne avian malaria into their habitats, along with impacts from increased development and human contact. The hour is late and extinction is a tragedy. Learn more.




Apathetic adoption

Adoption of the e-manifest system has been much slower than anticipated. Thus, EPA is holding two virtual public meetings, one in October and one in November, to discuss how to increase adoption of electronic manifests and solicit feedback from stakeholders.   READ MORE  


Beam me up

We know William Shatner as Captain Kirk from the Star Trek series and movies. Now his dream of experiencing space has become reality. He blasted off on the October Blue Origin flight, boldly going where no 90-year-old has gone before. The crew traveled 60 miles above earth and spent several minutes in zero-gravity. Mr. Shatner is an ambassador of sci-fi and will be on the forefront of civilian space exploration. More info here.




Love food, hate waste

Food waste is a major global environmental, social, and economic challenge. EPA has recently developed two reports summarizing the contamination in food waste streams and the potential risks to human health and the environment. EPA also discusses food waste processing methods, food waste management, and other emerging issues with food waste. Additional information on this topic and both reports can be found on EPA’s food waste page.


Corrective action closeout

EPA has made the RCRA Corrective Action 2020 Goals Closeout Fact Sheet available. This document provides a background on the goals that the agency set for the program and discusses the results. McCoy discussed these goals in more detail in a previous article. EPA has announced new 2030 goals for the RCRA Corrective Action program on their website as well.


Goat mitigation

Wildfires increase in size and scale each year, and 2021 was no exception in the West. California’s largest wildfire was nearly 90,000 acres. When combined, three factors create wildfires—fuel loads (brush), topography, and weather. Goats are being introduced as a unique solution to reduce wildfire fuel. They prefer consuming dry brush instead of grass, and 350 goats can clear an acre in one day. Goats to the rescue! Now that’s something to chew on. Learn more.


2021–2022 Seminars

3-Day CAA Seminars
.VIRTUAL: November 2–4, 2021
.VIRTUAL: January 11–13, 2022

5-Day RCRA Seminars
.VIRTUAL: December 6–10, 2021
Orlando: January 24–28, 2022
.VIRTUAL: February 7–11, 2022

2-Day RCRA Refreshers
.VIRTUAL : November 16–17, 2021
Denver: February 22–23, 2022

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


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Copyright ©2021 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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