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McCoy's RCRA Review

July 2022

August CAA

Are any Clean Air Act complexities bogging you down at work? You have an air compliance objective but need help navigating the way there. Sometimes, a change of scenery, pace, or even a fresh perspective can open your mind and guide you towards that goal. Spend three days with us at the August 9-11 .VIRTUAL CAA seminar and let McCoy training be a breath of fresh air.

McCoy’s CAA 3-Day Agenda


Direction on thermal desorption

Recently, EPA was asked for clarification on the regulatory status of thermal desorption units (TDUs) used as recycling units when the materials are managed under the transfer-based exclusion. TDUs are used to legitimately reclaim organics from hazardous secondary materials. EPA’s guidance reiterates the conditions of the transfer-based exclusion and discusses the RCRA status of TDUs managing excluded materials.   READ MORE  


Virtually RCRA

If you’ve been searching for a virtual RCRA seminar to fulfill your training needs, then you’re in luck! McCoy has multiple 5-Day virtual seminars to choose from that will help you understand the RCRA fundamentals. There’s still time to register for the July 25-29 .VIRTUAL 5-Day RCRA seminar. Sign up soon to ensure we can ship you the class materials in time. If you can’t make it to July, give yourself more time and register for the September 12-16 .VIRTUAL RCRA seminar.

See our full schedule here




Don’t flush the pharms

Effective August 21, 2019, EPA prohibited all healthcare facilities and reverse distributors from disposing of their hazardous waste pharmaceuticals down the drain, effectively known as the “sewer ban.” EPA has published an introductory fact sheet on the sewer ban and another fact sheet for publicly owned treatment works on navigating the new requirements. The agency also has a water reuse action plan to reduce sewering of pharmaceuticals, among many other things.   READ MORE  


Beware: lithium battery blunders

During recent Pipeline and Hazardous Materials Safety Administration (PHMSA) inspections, inspectors routinely observed shippers improperly packaging and shipping lithium batteries. PHMSA has published a safety advisory notice to increase awareness of this issue. The notice discusses the dangers of shipping lithium batteries for consumers, shippers, and carriers. It also summarizes the regulatory information needed to ship lithium batteries properly. Additional resources on preparing lithium batteries for shipment are provided in the notice.




Make a low-carb garden

A low-carbon garden not only reduces carbon, but can lead to healthier soils, lusher plants and of course a beautiful yard. Lowering the number of times you cut your grass, mulching more often and even having a pond can lead to a low-carbon garden. Read the article, “How to turn your garden into a carbon sink”, for the full story.


Texas Refresher!

McCoy’s last 2022 in-person RCRA Refresher is taking place at the South Shore Harbour Resort in Houston, Texas, November 15-16, 2022. We recommend making your travel plans early, so reserve a seat in class and make hotel accommodations fast! We are standing by to offer assistance with registration and can answer any questions you may have. Please call us at 303-526-2674 for more information.

Find out more about the Houston Refresher


Vehicle coating VOC clampdown

The surface coating of automobiles and light-duty trucks is regulated under both the NSPS and NESHAP programs. VOC emissions from the multi-step prime coat, guide coat, and topcoat operations are typically controlled via thermal and catalytic oxidizers. As part of the periodic review for the Part 60, Subpart MM NSPS, EPA proposed a new Subpart MMa to control VOC emissions from affected sources that commence construction, reconstruction, or modification after May 18, 2022. [87 FR 30141] Besides lowering VOC emission limits, Subpart MMa would not exclude the coating of plastic autobodies, not include a startup, shutdown, and malfunction exemption, and require periodic testing to determine VOC destruction efficiency. Comments may be submitted through July 18, 2022 via Docket ID No. EPA-HQ-OAR-2021-0664.


Banning single-use plastics

With plastic waste problems on the rise, the U.S. made the decision to begin phasing out single-use plastics, which are disposable plastics normally used to package small items. The ban will become effective in 2032 but will only cover public land and national parks. Learn about the ban and what it can do to prevent the massive increase in plastic waste.






Misc. metals coating controls considered

On June 7, 2022, EPA proposed an amendment to the miscellaneous coating manufacturing NESHAP in Part 63, Subpart HHHHH. [87 FR 34614] Only applicable when an affected source is not already subject to another subpart of Part 63, this major source standard controls organic HAP emissions from process vessels, storage tanks, pipe runs, and other equipment. The proposal would add particulate matter (PM) to the MACT standard, which would act as a surrogate for metal HAPs. Affected sources would need to meet process vessel PM emission limits, demonstrate compliance via a continuous parameter monitoring system, and submit semiannual reports documenting compliance and deviations. Comments may be submitted through August 8, 2022 via Docket ID No. EPA-HQ-OAR-2018-0747.


EPA slides for third on gasoline industry standards

EPA published a 3-part proposal for updating gasoline terminal, plant, and pipeline regulations on June 10, 2022. [87 FR 35608] The proposal would not only strengthen the major and area sources standards of Part 63, Subparts R and BBBBBB but also create a new Part 60, Subpart XXa. External floating roof tanks would require controls similar to NSPS Part 60, Subpart Kb, optical gas imaging may be an option for LDAR monitoring, and performance test requirements would be unique to the standards rather than tied to the general provisions. The startup, shutdown, and malfunction exemption is also not provided in proposed Part 60, Subpart XXa. Comments may be submitted through August 9, 2022 via Docket ID No. EPA-HQ-OAR-2020-0371.


Forest fires and wine?

Rising temperatures and the smoke from forest fires are having a direct influence on wine production in the state of Washington—and it’s the second-largest wine producer in the U.S. See how Washington wineries are being affected by climate change and what the vineyards plan to do to fight through these complications. Dive in further, and read the article on the Betz Family Winery, which cannot release its 2020 wines due to the smoke from forest fires tainting their grapes.


2022–2023 Seminars

3-Day CAA Seminars
.VIRTUAL: August 9–11, 2022
.VIRTUAL: October 4–6, 2022
.VIRTUAL: January 10–12, 2023
.VIRTUAL: April 4–6, 2023
.VIRTUAL: July 18–20, 2023

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
.VIRTUAL: January 23–27, 2023
Virginia Beach: March 13–17, 2023
.VIRTUAL: April 24–28, 2023
Denver: June 5–9, 2023
.VIRTUAL: July 31–August 4, 2023

2-Day RCRA Refreshers
.VIRTUAL : September 27–28, 2022
Houston: November 15–16, 2022
.VIRTUAL: February 15–16, 2023

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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