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McCoy's RCRA Review

September 2022

New PM NAAQS on horizon?

As the body of scientific knowledge advances, so too does EPA’s understanding of the effectiveness of NAAQS for criteria pollutants. The agency recently released its updated final policy assessment on the current NAAQS for particulate matter (PM). Though these standards were reviewed in 2020, new technical data and information warrants a reconsideration. Indeed, while most current primary and secondary PM standards are deemed adequate, the assessment suggests room to strengthen the primary annual PM2.5 standard.   READ MORE  


Virtual refresh

Whether you’re in a familiar place like home or office, or even a library or coffee shop, you can get your RCRA training with McCoy and complete it quickly. Spend two fast-paced virtual days with us refreshing your RCRA knowledge at the September 27-28, 2022, .VIRTUAL RCRA Refresher. Before you know it, class is over and you’ll feel rejuvenated and assured of your RCRA future.

Review the .VIRTUAL Refresher Class Agenda


TRI reporting PFAS

EPA is adding five per- and polyfluoroalkyl substances (PFAS) to the Toxics Release Inventory (TRI) list of chemicals. [87 FR 42651] This list was established under the Emergency Planning and Community Right to Know Act. Addition of these PFAS to the list was required by a statutory mandate included in the National Defense Authorization Act for the fiscal year 2020. The final rule took effect on August 17, 2022, meaning facilities must report 2022 releases of these chemicals on TRI forms due July 1, 2023.






October CAA.V

Ever feel like the Clean Air Act is too big to wrap your head around? It’s a common feeling so you’re not all alone. That’s why McCoy’s virtual CAA seminar breaks down the Clean Air Act into more understandable pieces. Class presenters will help you maneuver through the CAA paradigm piece by piece. Come with questions and a willingness to learn and McCoy will take care of the rest. Sign up for McCoy’s .VIRTUAL CAA 3-Day Seminar, October 4-6, 2022.


Watch your WAPs

EPA reviewed waste analysis plans (WAP) from 57 facilities and sampling results for 14 different land disposal restrictions (LDR), finding numerous deficiencies in WAP and LDR compliance. New guidance provides EPA’s recommendations for permit writers and facilities to improve their WAPs and sampling strategies to achieve LDR compliance. The recommendations include increasing LDR verification sampling events, solidifying enforceable permit conditions for treatment operations, and conducting a thorough waste analysis of each waste stream.   READ MORE  


Plan for 2023!

If you like to plan ahead, then you’re in luck, as additional training dates are on the horizon! McCoy’s 2023 RCRA and CAA seminars are officially open for registration. McCoy offers both virtual and in-person public classes, so be sure to take a look at the schedule and sign up for a seminar that works best for you. Plan early for 2023 and look forward to a bright future! Questions? Email if you need assistance.




Jolly ole farm

A farm located in the grasslands of England intends to thrive into the future by taking a different approach to farming. This includes reintroducing beavers to the land to capture surface water, planting thousands of trees, and implementing a no-fence GPS system for cattle so wildlife can migrate freely. England has a wet, humid climate, and this makes it one of the last remaining rainforests in Europe. Find out how they plan to last over 1,000 years.


Emergency engine, no more?

On August 10, 2022, EPA issued a final rule amending the emergency engine provisions in Part 63, Subpart ZZZZ and Part 60, Subparts IIII and JJJJ. [87 FR 48603] The rule reflects an immediately effective 2015 court vacatur of two provisions and, as a result, is administrative in nature. To be classified as an emergency engine under the internal combustion engine standards, such an engine can only be used in a non-emergency capacity for up to 100 hours per year in limited ways. Two of those ways were vacated by the court: 1) running the engines when the reliability coordinator declares an energy emergency alert Level 2, and 2) when there is a 5% or greater deviation from standard voltage or frequency. Since the 2015 vacatur, engines that operate for either of these reasons are considered non-emergency engines and must be in compliance with the applicable emission standards.


Handwrite or type notes?

With many ways of taking notes, is one way better than the other? A study published by Princeton University makes the case that taking notes by hand could be more beneficial than using a keyboard and laptop. The article outlines how students taking notes with pen and paper scoring higher on tests than students taking notes with a laptop. Another study in 2019 explains that medical students find taking notes with a computer more beneficial than taking notes with pen and paper. Is there a “best way” of taking notes, or is it up to your personal preference?




Wetlands rising

Rising sea levels are forcing U.S. coastal wetlands to “migrate” and these changes could damage the people and wildlife that reside in these areas and impact the economic value the wetlands bring. These coastal areas are home to nearly 30 percent of the U.S. population and numerous fisheries, crops, and forests that produce a wide range of ecological values and provide jobs. What can be done to restore and protect the wetlands?


Financial assurance affirmation

RCRA-permitted facilities must provide financial assurance that they have the necessary resources to fulfill their permit obligations, closure, post-closure, and corrective action costs. As one could imagine, these mechanisms can be fairly complex. EPA issued a memo to regions providing a list of existing guidance on financial assurance and a new standard procedure to assist regulators overseeing the validity of financial assurance mechanisms.   READ MORE  




Clearest recycling guide!

We’ve all seen the numbers on plastics and know they have something to do with recycling… but what do they REALLY mean? Those recognizable numbers specify the type of plastic resins that a product is made with. Certain types of plastics can be easily recycled while others cannot. It’s important we learn about and follow these numbers when disposing of plastic products—to avoid contaminating the material—and this is a huge help to curbside recycling and recycling teams everywhere.

What do recycling numbers really mean?




October e-manifest advisory board meeting

The Hazardous Waste Electronic Manifest System Advisory Board is conducting a three-day virtual public meeting on October 4-6. [87 FR 49830] EPA and the board plan on discussing recommendations regarding the operational activities, functions, policies, and regulations for the e-manifest system. Attending and providing oral public comments during the meeting requires online registration. You can register and find more information about the meetings on EPA’s website.


Coexist (and thrive!) with wildlife

See the before and after photos to see why the goal is to bring back apex predators (and their numerous positive environmental effects). In addition, learn how wildlife can help maintain and improve the ecosystems they reside in—while working with people and communities so we can all coexist and thrive. Read the Popular Science plan to reintroduce wolves and beavers into wilderness areas across eleven states.


Moon glow

Two astro-photographers, Andrew McCarthy and Connor Matherne, merged their image-taking skills together to generate a composite, full-color photo of the moon. The picture is a combination of 200,000 detailed shots and 50,000 full color shots taken by Andrew and Connor. Be sure to take a look at the article and the breathtaking moon photo.


2022–2023 Seminars

3-Day CAA Seminars
.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: 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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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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