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McCoy's RCRA Review

April 2022

Speedy April Refresher

Already comfortable with RCRA and need to fulfill your training needs without missing too much work? The McCoy VIRTUAL Refresher, April 26-27, 2022, could be the perfect class for you! Our refresher classes are fast-paced and accelerated, helping you understand the essential parts of RCRA in just two days. Contact us at 303-526-2674, or to see if this is the right class for you.

Register for the April Refresher today


Emission factors not so free

There’s no such thing as a free lunch—even when calculating emission rates. A common way for determining CAA compliance is using EPA’s AP-42 emission factors. But the agency has found widespread misuse of these factors resulting in significant noncompliance. The result? While using emission factors may be free, the results are often inaccurate, and emission violations may cost a facility tens of millions of dollars in penalties and pollution control costs. EPA alerts us to the dangers and the alternatives.   READ MORE  


Sanity for hand sanitizers

The FDA issued temporary policies in March 2020 for non-drug manufacturers to produce and distribute alcohol-based hand sanitizers due to the COVID pandemic. The FDA has withdrawn the temporary policies and now these companies can no longer sell or distribute these sanitizers after March 31, 2022. A few options are available to manage their excess hand sanitizer. Within the RCRA regulations, companies may dispose of the sanitizer as ignitable hazardous waste (D001), or possibly manage it through the episodic generation provisions, or even legitimately recycle the hand sanitizer.   READ MORE  


Virtual is here to stay

Most of us agree that virtual seminars can be well… boring. That’s why we’ve given extra care to make our virtual seminar as close to our in-person seminar as possible and customers are noticing. With two experienced presenters, newly updated course materials, all in a well-lit studio setting, you’ll forget you’re taking the class virtually. Join us for the McCoy May 9-13, 2022, RCRA .VIRTUAL seminar.

Register for the May RCRA seminar

See our full schedule here




What is circular packaging?

The ink and coating found on plastics could make a huge difference in the fight to make plastics fully recyclable. A new solution may be circular packaging, but what exactly is it? Learn what circular packaging is and why it needs to be transitioned to from the current linear packaging approach.


Wildfire waste woes

Wildfires pose a growing threat to the dry west coast climates of the United States. Over the years they have been increasing in both occurrence and severity. In 2018 and 2020, California experienced record-setting fire seasons, resulting in significant damage and destruction to over 20,000 structures. One problem associated with wildfires is the tremendous amount of hazardous waste that is generated when structures are damaged or destroyed. EPA coordinated cleanups for both California wildfires and reviewed their operations to make improvements.   READ MORE  






Regenerative Guinness

Guinness is working with a team of farmers and suppliers to begin a regenerative agriculture pilot program in Ireland. The plan will take about three years, with a goal to reduce carbon emissions during their production process. Find out what regenerative agriculture is and why it’s going to be a worthwhile challenge for Guinness.


Human-ocean connection

That special connection you feel regarding the ocean may not just be in your imagination. Did you know that the ocean has deep connections to human health? So much so, that microbiologists are making discoveries in the ocean that help detect Covid-19 and diagnose diseases such as AIDS and SARS. Read the full article.


FAQ future for hazmat guidance

Like RCRA, DOT hazardous material transportation regulations can sometimes be difficult to understand. Fortunately, resources are available to navigate those requirements, one being PHMSA’s letters of interpretation (LOI) database. On March 22, 2022, PHMSA proposed to convert the LOI into broadly applicable frequently asked questions to provide additional value to the administration’s online Code of Federal Regulations (oCFR) tool. [87 FR 16308] PHMSA believes this FAQ initiative will optimize the effectiveness, reach, and impact of its Office of Hazardous Material Safety LOI process. Comments will be accepted through May 23, 2022 via Docket Number PHMSA-2021-0109.






Zero landfill…soccer

After teaming up with Subaru, the Philadelphia Union stadium has successfully achieved a Zero Landfill Status. This is the first Major League Soccer stadium to reach this landmark. Which means that the stadium will reduce, reuse, or recycle 100% of its generated waste. This sets a great example for sports stadiums to follow.


Wood preserving NESHAPs perpetuated

On March 7, 2022, EPA proposed minor editorial and formatting changes to the wood preserving area source NESHAP of Part 63, Subpart QQQQQQ. [87 FR 12638] While a review concluded there were no improvements in work practices and control technologies to warrant strengthening the standard, some minor updates to the standard’s general provisions applicability table are necessary. Additionally, technical corrections to the surface coating of wood building products major source NESHAP of Part 63, Subpart QQQQ are also proposed. An obsolete cross-reference to OSHA-defined carcinogens would be removed in favor of a dedicated list of carcinogenic organic HAPs added to a new Table 7 in Subpart QQQQ. Comments may be submitted through April 21, 2022 via Docket ID No. EPA-HQ-OAR-2021-0133.




Combustion turbines controlled

Effective March 9, 2022, certain stationary combustion turbines regulated under Part 63, Subpart YYYY are subject to formaldehyde emission limits. [87 FR 13183] Shortly after the stationary gas turbine NESHAP was promulgated in 2004, EPA added a stay of standards for two different types of gas-fired turbines. The stay was in response to an industry effort to delist those turbines. However, the delisting was not approved, and 18 years later, the agency has lifted the stay. Consequently, lean premix and diffusion flame gas-fired stationary combustion turbines located at major sources are now subject to the 91-ppbvd formaldehyde limit. Sources have 180 days to perform their initial compliance demonstration.


Kohler’s recycled tiles

Kohler WasteLAB is turning its factory waste clay and glaze into a new collection of matte tiles. The tiles are manufactured with almost 100 percent recycled materials, and they can be custom designed. Plus, the tiles are beautiful. Kohler’s innovation and implementation is great for companies working on similar projects.


Clean air journey

Looking for a better understanding of the CAA regs and don’t know where to start? Look no further, McCoy offers .VIRTUAL 3-Day CAA seminars. With veteran presenters ready to help you navigate your journey, you’ll leave with confidence, ready to tackle your air conundrums. Review the class agenda and decide if this seminar is right for you.

Register today


2022 Seminars

3-Day CAA Seminars
.VIRTUAL: August 9–11, 2022
.VIRTUAL: October 4–6, 2022

5-Day RCRA Seminars
.VIRTUAL: May 9–13, 2022
Hilton Head Island: May 23–27, 2022
.VIRTUAL: July 25–29, 2022
Lake Tahoe: August 22–26, 2022
.VIRTUAL: September 12–16, 2022
.VIRTUAL: October 24–28, 2022
.VIRTUAL: December 5–9, 2022

2-Day RCRA Refreshers
.VIRTUAL : April 26–27, 2022
.VIRTUAL : June 21–22, 2022
.VIRTUAL : September 27–28, 2022
Houston: November 15–16, 2022

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


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Copyright ©2022 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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