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August 2024 |
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Last chance for CAA in 2024!
McCoy’s next CAA .VIRTUAL seminar is this October 22-24, 2024. And as you already know, the Clean Air Act is elaborate, permit-driven, and every facility requires its own specific approach. So yeah, it can be a lot… that’s why we spend 3 days digging deep and breaking it down. We’ll clarify how the applicability determinations fit together—and hopefully can make your life a lot easier. It’s the last one this year, so don’t forget to sign up!
CAA Agenda
Future CAA seminar dates
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Overhauling organic chemical manufacturing standards
On July 15, 2024, EPA’s new and revised CAA provisions impacting the synthetic organic chemical manufacturing and the polymer/resin industries took effect. Hundreds of chemical plants nationwide affected by these NSPS and NESHAP amendments must achieve compliance within the next three years. Ten stationary source standards have been revised, and four new ones have been promulgated, requiring affected facilities to implement stricter control and monitoring practices to reduce VOC and HAP emissions. EPA estimates approximately 9.3 million people live within 10 km of these facilities, and the rule will reduce the number of people who have an elevated air toxics-related cancer risk by 96% in those surrounding communities. READ MORE
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Gutting GHG emissions
Fossil fuel-fired power plants are the nation’s largest source of greenhouse gas emissions (GHG), representing 25% of the United States’ GHG emissions in 2021. GHGs include methane, hydrofluorocarbons, and nitrogen oxide, but one chemical in particular composes 80% of all GHGs in the atmosphere: carbon dioxide (CO2). In May 2024, EPA finalized a series of rules to cut emissions of these climate change culprits at new and existing power plants. The agency’s regulatory impact analysis projects reductions of CO2 emissions by 1.38 billion metric tons through 2047. READ MORE
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Thanks, Paris, for reusable cups
The Paris Olympics caught the entire world’s eyes these past few weeks, but this time it wasn’t from the miraculous athletes. This year’s Olympics was the largest sports event ever to replace single-use beverage cups with an eco-friendly alternative—thanks to the implementation of Re-uz's innovative reuse system, which has already saved millions of cups destined for landfills.
Check out Re-uz and see how they plan to leverage their success at the Olympics to push for reusables at other major venues worldwide. Recently, they’ve teamed up with Coca-Cola to implement their system at events across Europe.
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A guide to McCoy .VIRTUAL seminars
Thinking about a McCoy .VIRTUAL(.V) seminar? You’ve come to the right place! Our .V seminars are presented by RCRA experts—questions are encouraged—and speaking on your computer microphone makes it easy. The online host is a RCRA presenter, so typed-in questions are also answered efficiently and smoothly.
That's not all—before class kicks off, we’ll ship a comprehensive set of course materials right to your door. So please make sure to provide a good shipping address during registration to guarantee a timely delivery. Join us for the September 16-20, 2024 RCRA seminar or for the October 22-24, 2024 CAA seminar!
Check out the full schedule
McCoy registration page
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RCRA regulatory agenda sees few changes
The Spring 2024 regulatory agenda is now available. EPA is keeping per- and polyfluoroalkyl substances in its sights for regulation as RCRA hazardous constituents and CERCLA hazardous substances. The agency has also begun reviewing potential universal waste regulation for lithium batteries and solar panels. READ MORE
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EPA’s spring CAA agenda
The Spring 2024 regulatory agenda is now available and EPA is planning reviews, revisions, and amendments to scores of CAA stationary source regulations. A critical aspect of the CAA is the periodic review of source category standards. While much of what is on the agenda is the typical review, some items result from lawsuits and court orders. READ MORE
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See Houston for yourself!
Some of our customers are “in-person seminar only” folks. We get it! It’s a good reason to attend our in-person 2-day Refresher in Houston, Texas, November 20–21, 2024. Because Houston and industry are almost synonymous, we find attendees who come to this seminar to be some of the sharpest RCRA professionals around. We love the questions people ask (complex ones or not so) and the networking abounds. So dust off your spurs and we hope to see you in our Houston RCRA Refresher.
RCRA Refresher agenda
Houston Refresher details
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Climate scientist, first female Mexican president
Claudia Sheinbaum, a former climate scientist and head of Mexico City’s government, was recently elected as the first woman president of Mexico after a landslide election victory. She has a PhD in energy engineering and was an Intergovernmental Panel on Climate Change (IPCC) author in 2007, which earned a Nobel Peace Prize. Sheinbaum has one of the most exemplary climate-science backgrounds of any political premier in history—and as president, plans on turning Mexico into a global climate action leader.
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Coking oven review complete
Coke is produced in a battery of ovens to remove impurities from coal and used in blast furnaces to produce iron and steel. On July 5, 2024, EPA finalized its amendments to the coke ovens: charging, top side, and door leaks NESHAP and the coke ovens: pushing, quenching, and battery stacks NESHAP. The revisions to Part 60, Subparts L and CCCCC reduce HAP emission limits, require opacity monitoring, set new benzene fenceline monitoring requirements, and revise emission estimate equations. Performance test results and compliance reports must be submitted via the Compliance and Emissions Data Reporting Interface accessible via EPA’s Central Data Exchange.
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Broadly removing affirmative defense
Affirmative defense is a mechanism that allows a source to avoid civil penalties during judicial or administrative proceedings and typically applies within the context of malfunction events resulting in noncompliance with any applicable standard. In light of NRDC vs. EPA (U.S. Court of Appeals, D.C. Circuit; Docket No. 10-1371; April 18, 2014), which found such mechanism to not be under the authority of EPA but rather the courts, the agency has been removing affirmative defense provisions from CAA Section 111 and 112 rules. On June 24, 2024, EPA proposed removing the provisions from 18 NSPS and NESHAP rules. [89 FR 52425] The agency continues to evaluate violations on a case-by-case basis to determine whether enforcement actions are appropriate. More information is available at Docket ID No. EPA-HQ-OAR-2023-0509.
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Work in Cali haz waste?
If you work with California’s hazardous waste regulations then you won’t want to miss out on McCoy’s first ever California Title 22-RCRA .VIRTUAL seminar this October 7-10, 2024!
During class, we’ll present specific guidance on the California Health and Safety Code (HSC) and the California Code of Regulations (CCR), helping bridge the gap between California and federal RCRA! Plus, course materials are shipped prior to the seminar which include McCoy’s RCRA Reference and RCRA Unraveled books, accompanied by a binder with course notes. So, what are you waiting for? Hurry up and register—it’s coming up hotter than the California sun!
Seminar agenda
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New lime manufacturing limits
On July 16, 2024, EPA finalized amendments to the lime manufacturing NESHAP. [89 FR 57738] First proposed in January 2023, as discussed in a previous article, the agency attempted to set emission limits on previously unregulated pollutants, including hydrogen chloride, mercury, organic HAPs, and dioxins/furans. Subsequent to that proposal, EPA received negative comments and amended the original Part 63, Subpart AAAAA proposal. While the final rule still sets emission limits for the previously mentioned pollutants, the limits are weaker than those first proposed. No changes were made to the emission limits for particulate matter, a surrogate for non-mercury metal HAPs.
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2024–2025 Seminars
3-Day CAA Seminars
.VIRTUAL: October 22–24, 2024
.VIRTUAL: January 14–16, 2025
.VIRTUAL: April 1–3, 2025
5-Day RCRA Seminars
Lake Tahoe: August 19–23, 2024
.VIRTUAL: September 16–20, 2024
.VIRTUAL: November 4–8, 2024
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
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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