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McCoy's RCRA Review

September 2021


Join us for the next .VIRTUAL 5-Day RCRA seminar—to be held on October 18-22, 2021 and again on December 6-10, 2021. Our presenters demystify the regs, help you understand applicability, and answer nuanced questions during our live broadcast. Round out the year with comprehensive McCoy training. Register today.

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Register for December.VIRTUAL
5-Day .VIRTUAL Agenda


RCRA PFAS Petition

In June, the state of New Mexico petitioned EPA for the RCRA regulation of per- and polyfluoroalkyl substances (PFAS). While perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) are the most well-known and studied PFAS, New Mexico believes the entire class of PFAS, potentially thousands of different chemicals, deserves regulation. The petition is only the latest in a growing line urging EPA to take regulatory action on these “forever chemicals”. Certain PFAS are already subject to EPCRA’s TRI reporting requirements, and the agency may soon craft regulations under CERCLA and the SDWA. Perhaps RCRA is right around the corner.   READ MORE  






DOE’s powerful wind

The Department of Energy (DOE) released three new reports that wind energy is experiencing record growth and declining costs for electricity generation. In 2020, wind energy installations increased by 42%, resulting in more growth than any other energy source. DOE is doubling down on its efforts to meet wind energy goals and increase the health and climate benefits for the future. Find out how.


Get a clear picture of CAA

With climate change impacting our world, air emissions are a trending topic, but understanding the issues around CAA applicability are complex. Attend McCoy’s CAA seminar, November 2-4, 2021. Our presenters provide guidance to help you make the right CAA decisions at your facility. Experience an interactive online training with a well-lit studio, two presenters, peer-asked questions, and detailed content to help you see the big picture with CAA.

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Out of accumulation time

What happens when you run out of time for storing hazardous waste? What if the nation simply lacks the necessary incineration capacity? A backlog of untreated waste is raising these very questions. And to stay in regulatory compliance, facilities may need to examine alternatives not usually considered. Recent EPA guidance highlights options available for generators and permitted facilities looking to extend their hazardous waste accumulation limits.   READ MORE  


PFAS, EPCRA, and SW-846

As the dangers of per- and polyfluoroalkyl substances (PFAS) are further studied and congressional action intensifies, EPA regulatory and guidance actions are picking up steam. Effective July 6, 2021, three specific PFAS were added to EPCRA’s section 313 Toxics Release Inventory. [86 FR 29698, §372.65] To regulate these persistent and bioaccumulative chemicals, one must also be able to test for them. As such, EPA added test method 3512 to SW 846, used to detect certain PFAS in surface water, ground water, and wastewater. Method 3512 previously existed as an appendix to Method 8327, another test method for analyzing PFAS.






Closure device clarity

With greater scrutiny from regulators, compliance with RCRA’s air emission standards is more important than ever. Consequently, EPA recognizes a need for additional guidance on which standards apply to closure devices found on hazardous waste management units. The language describing closure devices creates confusion on whether these devices are subject to Subpart BB or CC. New draft guidance explains the scope of these standards, and comments are being received until October 3, 2021.   READ MORE  


Speed with Sherpa

Get ahead of schedule with McCoy Sherpa, our electronic tool that helps you decipher the RCRA regs in record time. Gain access to over 28,000 pages of RCRA-specific content and use the integrated search engine to find answers in a flash. Access over 500 EPA examples, 18 interactive flow charts, and over 50,000 hyperlinks and have RCRA guidance at the ready. Get ahead. Get McCoy Sherpa.

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McD’s, eBay, & Louisiana sun

McDonald’s and eBay are partnering with Lightsource bp to purchase future power from Louisiana’s largest solar project, to be located 30 miles northwest of Baton Rouge. Their combined purchasing power will help McDonalds and eBay reach their sustainability goals, while, in turn, help Lightsource BP to expand its clean energy footprint. Construction on the solar farm is expected to begin at the end of 2021, with commercial operations beginning in mid-2023. More info here.


Requisite request: recycle batteries

Lithium-ion batteries are found in innumerable electronics used both at home and in business. Unfortunately, their reactive chemistry and improper management have caused hundreds of fires throughout the country. Recognizing the danger, EPA released a report on the importance of safely handling and recycling these hazardous wastes. Proper battery management allows for both the recovery of valuable materials and a reduced risk of bodily injury and property damage.   READ MORE  


2021–2022 Seminars

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

5-Day RCRA Seminars
.VIRTUAL: September 20–24, 2021
Denver: October 4–8, 2021
.VIRTUAL: October 18–22, 2021
.VIRTUAL: December 6–10, 2021
Orlando: January 24–28, 2022
.VIRTUAL: February 7–11, 2022

2-Day RCRA Refreshers
Houston: 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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