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McCoy's RCRA Review

June 2022

June Refresher coming up fast

Only a few days remaining to sign up for the McCoy June 21-22, 2022, RCRA Refresher .VIRTUAL seminar. Call us at 303-526-2674 and we can assist with your registration quickly—just like the McCoy RCRA Refresher will quickly get you up to speed on the essential parts of RCRA. Come to a Refresher and receive the core content you need for your job. Sign up now and join us next week for a RCRA Refresh!

Don’t forget to review the agenda



EPA recently published guidance on the large quantity generator contingency plan requirement to have a quick reference guide (QRG). The QRG provisions were added to the federal regulations in 2016. Since then, regulators and the regulated community have had questions on how to comply with specific elements. The new guidance answers many questions and clarifies some requirements.   READ MORE  


RCRA summer camp

Remember the confidence you had going back to school after picking up an abundance of new skills and knowledge from summer camp? Whether it was learning how to build a rocket or playing sports. These newly gained strengths helped you get that “A” in science class or collaborate with a team. Come to the July 25-29 .VIRTUAL 5-Day RCRA seminar and go back to your job duties with a newfound energy and conviction. Welcome to “Camp McCoy!”

.VIRTUAL RCRA Summer Camp Registration




Reviewing the O3 review

By law, every five years, EPA is supposed to review each primary and secondary NAAQS, ensuring those standards reflect the latest advances in scientific knowledge. While the 2015 ozone NAAQS was reviewed in 2020, the agency believes the process was flawed. A draft policy assessment has been made available to provide the public, the regulated community, and EPA policymakers with the most accurate information on ozone effects. EPA is planning to complete its review of the 2020 review by the end of 2023.   READ MORE  


WIPP recertification

The Department of Energy’s (DOE’s) Waste Isolation Pilot Plant (WIPP) underwent the fourth periodic evaluation of its continued compliance with disposal regulations in 40 CFR Part 191 and WIPP compliance criteria in 40 CFR Part 194. The WIPP is a DOE disposal facility designed specifically for defense-related transuranic radioactive wastes. This recertification process is required every five years and is based on a thorough review of information submitted by DOE, independent technical analyses, and public comments. EPA has recertified the WIPP and has determined that DOE continues to meet all applicable requirements of the disposal regulations and WIPP compliance criteria. [87 FR 26126]






A Repreve for shopping

Next time you go shopping, check the tag to see if the product you’re looking for is made with Repreve fibers. Leading brands like Ford, Nike, Patagonia, and many more have incorporated Repreve into their materials. Repreve is a recycled fiber built and processed from thrown-away plastic water bottles. The company recently reached their initial goal of recycling 30 billion plastic bottles! Your future purchase can make a difference by recycling billions of plastic bottles that otherwise end up in landfills each year.


Ozone danger zone?

Using an ozone generator to purify indoor air? Manufacturers claim these generators are safe and effective. EPA recently reviewed research conducted on ozone and its effects on indoor air quality and human health. The agency also investigated how effective ozone generators are at air purification. The research revealed that ozone generators may do more harm than good.   READ MORE  


Summer CAA

The Clean Air Act is not your average subject. So, we made a not-so-average .VIRTUAL seminar to tackle it. We’ve recreated our “in-person” experience with interactive conversations, two presenters, great use of whiteboard examples, and thoughtful slides delivered from a well-lit setting (not the usual Zoom living room d├ęcor). To add to the learning experience, we’ll pre-ship essential course materials to you well before the class start date. Please email, we’re here to assist with class registration and any questions you may have.

Register for the August 9-11, 2022, .VIRTUAL CAA seminar


E-manifest destiny delay

EPA published a proposal on April 1, 2022, to amend several provisions in the hazardous waste manifest regulations [87 FR 19290]. The amendments would change how generators receive signed copies of manifests from receiving facilities. They would also alter procedures for exception, discrepancy, and unmanifested waste reports. Other changes are also proposed as discussed in a previous McCoy Review article. Since then, EPA has extended the comment period till August 1, 2022 [87 FR 31514].


Tahoe work (and vacation)

How many chances do you have to learn RCRA while feeling like you’re on vacation? Sign up for McCoy’s 5-Day RCRA seminar at the Harveys Lake Tahoe Hotel & Casino, August 22-26, 2022. Check out the class agenda and the Lake Tahoe’s events page to make plans in advance! From delightful dinners to breathtaking concerts, we want to help make the RCRA trip of your dreams. Call us at 303-526-2674 for further information.

Reserve a seat in class today


Test methods touched up

The rulemaking process can be a labored affair for any federal agency, and despite extensive review and proofing, minor mistakes are inevitable. EPA catalogs errors and corrections caught by agency personnel and the regulated community. Periodically, the agency updates and revises regulations as necessary. On April 26, 2022, EPA proposed a series of corrections and updates to emissions testing regulations under Parts 51, 60, and 63. [87 FR 24488] Primarily, the corrections fix typographical errors, update testing procedures, and add alternative equipment and methods approved by the agency. Comments may be submitted through June 27, 2022 via Docket ID No. EPA-HQ-OAR-2020-0556.






Lake Powell drops to all-time low

The water levels at Lake Powell have dropped close to 100 feet in the last three years and it’s currently at its lowest level since originally filled in the 1960s. As the lake water level declines, so does its hydropower and drinking water availability to nearly 40 million people and power for over five million homes. The Bureau of Reclamation has enacted an emergency drought response plan, which includes releasing water from the Blue Mesa and Navajo reservoirs, but this strategy is not sustainable—as climate change is depleting water sources—everywhere.

Read the full Bureau of Reclamation response here


No more mercury cell emissions

On May 6, 2022, EPA finalized its risk and technology review (RTR) of the mercury cell chlor-alkali plant NESHAP located in Part 63, Subpart IIIII. [87 FR 27002] Most significantly, the RTR “prohibits” mercury emissions from existing sources. With a compliance deadline of May 6, 2025, the standard effectively requires existing sources to close their mercury cell chlor-alkali plants or convert to another technology (e.g., membrane cell). The chlor-alkali process produces chlorine and caustic soda but the mercury cell method is obsolete and the NESHAP has limited applicability in the United States. Despite the standard’s limited reach, the RTR helps the United States meet its obligations under the Minamata Convention.


Sky and ocean blue?

Contrary to common belief, the blue color we see both in the sky and ocean is not due to a reflection, or any relationship between the two. There isn’t a single factor, but a variation of many different reasons they are both blue. Read the full article to fully understand why we see the sky and ocean as the same, beautiful blue hue.


2022–2023 Seminars

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

5-Day RCRA Seminars
.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
Virginia Beach: March 13–17, 2023
Lake Tahoe: August 21–25, 2023
Las Vegas: December 4–8, 2023

2-Day RCRA Refreshers
.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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