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November 2024 |
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Peanut shells as fuel?
Part 241’s nonhazardous secondary material regulations create an interface between RCRA and the CAA. Combusted materials are typically solid waste unless they meet specific criteria in Part 241 and would, in such circumstances, be considered fuel. For clean cellulosic biomass, like peanut shells, this determination may not always be so cut and dry. The latest guidance from EPA’s Office of Resource Conservation and Recovery clarifies the regulatory status of this material stream. These determinations are used to classify units under CAA as boilers, which burn fuel, versus incinerators, which burn solid waste. READ MORE
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Cali Title 22-RCRA with McCoy
We’ve all heard the expression that California could be its own country... but in RCRA terms, it may as well be. In general, they have tougher regulations compared to federal RCRA and even have their own California-only hazardous waste. So, if you work in Cali RCRA, consider signing up for our Cali Title 22- RCRA seminar taking place April 14-17, 2025. We’ll decipher how the federal RCRA regs, California hazardous waste regs, California Health and Safety Code (HSC), and much more work in Cali!
Sign up here!
Cali 4-Day agenda
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McCoy’s Thanksgiving hours!
Thank you for your continued support and business this year. We wish you a safe, happy, and relaxing Thanksgiving weekend filled with friends, family and of course… turkey!
As a holiday tradition, McCoy’s office will be closed November 28-29, 2024. You can reach us at hello@mccoyseminars.com and we’ll assist you when we return the following week.
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No MACT backsliding
For decades since its 1990 inception, the CAA air toxics program held that once a source was considered “major” for a specific MACT standard, it was always major for that standard. However, EPA’s interpretation of this policy changed in 2020 when it finalized a rule allowing major MACT sources to transition to area source standards if reducing their potential-to-emit (PTE) hazardous air pollutants. To prevent backsliding and potential emission increases, EPA has recently finalized a new rule requiring sources at more than two dozen source categories to maintain MACT compliance, even if reducing PTE. READ MORE
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Last call for Las Vegas
Don’t you worry… there’s still time to register for McCoy’s in-person RCRA seminar in Las Vegas, December 9-13, 2024! But FYI—McCoy’s $45 room rate at The Orleans Hotel & Casino ends November 14, 2024. So, hurry if you want to join the McCoy room block. You don’t want to miss this one, it’s McCoy’s last in-person seminar of 2024!
Las Vegas registration page
Seminar agenda
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Shipping container issues
Shipping containers have revolutionized the transportation industry, with over 250 million containers carrying goods across the oceans each year. However, they don’t always make it to their intended destination—on an annual basis, nearly 1,500 shipping containers fall off cargo ships and end up lost at sea. Most of these containers will plummet to the ocean floor and eventually bust open. It’s an environmental disaster when containers burst open.
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HFC rule partly vacated
Authorized by the 2020 American Innovation and Manufacturing Act, EPA’s 2021 Allocation Framework Rule established a series of mechanisms to prevent the illegal production, import, and sale of illegal hydrofluorocarbons (HFCs). [86 FR 55116] However, in Heating, Air Conditioning & Refrigeration Distributors Int’l vs. EPA (U.S. Court of Appeals, D.C. Circuit; Docket No. 21-1251; June 20, 2023), the courts decided EPA lacked the authority to finalize certain provisions. Consequently, the agency removed regulations that prohibited using disposable cylinders and implemented a cylinder tracking system from Part 84, Subpart A, effective September 11, 2024. [89 FR 73589]
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McCoy’s February .Vs
McCoy’s first .VIRTUAL RCRA seminars of 2025 are taking place in February! Set your sights on the February 3–7, 2025 .VIRTUAL 5-Day RCRA seminar, or the February 19-20, 2025 .VIRTUAL RCRA Refresher if you consider yourself RCRA savvy. Course materials are shipped prior to the seminar and include McCoy’s brand new 2025 RCRA Reference and RCRA Unraveled books, accompanied by a binder with course notes, so make sure to include a good shipping address during registration!
Full seminar schedule
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Oil/natural gas face limited legal defense
In the next step to removing affirmative defense provisions from NSPS and NESHAP regulations, EPA pulled the plug on this legal defense from Part 63, Subparts HH and HHH. [89 FR 84291] Affirmative defense allows a source to avoid civil penalties during judicial or administrative proceedings, typically applying within the context of a malfunction resulting in excess emissions. However, the courts found such a mechanism not to be within the authority of EPA but rather the courts. [NRDC vs. EPA; U.S. Court of Appeals, D.C. Circuit; Docket No. 10-1371; April 18, 2014] Effective October 22, 2024, affirmative defense no longer applies to the oil and natural gas production NESHAP and the natural gas transmission and storage NESHAP. In other words, emission standards apply at all times.
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1950s powerplant reimagined
BIG, a group of designers and engineers, along with landscape architecture studio Scape, have plans to rehabilitate a decommissioned 1950s powerplant into a reimagined community center on 125 acres of land on Manresa Island, Connecticut. They’ll be keeping the powerplant’s original structure, including the ginormous industrial smokestacks.
Other projects by BIG
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Largest dam removal in US history!
The Klamath River dam removal is the largest removal project in US history. For the last 100 years, dams have blocked salmon and steelhead trout from accessing over 400 miles of habitat, and in the process, harmed water quality, and intruded on indigenous cultures. Such dams were unproductive and no longer provided flood control or irrigation. And although the dam removals were successful, it was just the first step of the Klamath River’s recovery.
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NASA’s “Hidden Figures”
A group of four black women known as the “Hidden Figures,” who were critical to NASA’s early success, are finally getting the recognition they deserve. Last month, they were honored with Congressional Gold Medals, the highest civilian honor bestowed by Congress. And in 2016, their story was adapted in an Oscar-nominated film, Hidden Figures.
Read about their story here
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2024–2025 Seminars
3-Day CAA Seminars
.VIRTUAL: January 14–16, 2025
.VIRTUAL: April 1–3, 2025
.VIRTUAL: August 5–7, 2025
5-Day RCRA Seminars
Las Vegas: December 9–13, 2024
.VIRTUAL: February 3–7, 2025
Virginia Beach: March 10–14, 2025
.VIRTUAL: May 5–9, 2025
Denver: June 9–13, 2025
.VIRTUAL: July 21–25, 2025
Lake Tahoe: August 18–22, 2025
2-Day RCRA Refreshers
Houston: November 20–21, 2024
.VIRTUAL: February 19–20, 2025
.VIRTUAL: June 24–25, 2025
Visit understandrcra.com to register or call us at 303-526-2674.
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Copyright ©2024 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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