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McCoy's RCRA Review

December 2023

Happy Holidays from McCoy! 

As the year comes to a close and everyone bundles up for the holidays, we want to send a special thanks to our great customers and team for yet another amazing year. Thanks for being a seminar attendee or a reader of our publications. What you do is important and your support has been the greatest gift we can ask for. 

Our office will be closed from December 22 through January 1, 2024, for some much-needed recharging and rest with family and friends. Wishing you the coziest of holidays filled with love and laughter… and we’ll see you in the New Year!

Team McCoy 


LDR guide for CERCLA sites

In general, the land disposal restrictions (LDR) program requires hazardous waste destined for land disposal to be treated to reduce the toxicity and mobility of its hazardous constituents. Depending on a facility’s operations, it may not always be clear if LDR applies to a hazardous waste, particularly when one of those operations is a CERCLA cleanup response. CERCLA states onsite remediation can attain other federal standards, such as the LDR requirements, determined to be legally applicable or relevant and appropriate. EPA recently resurrected old guidance explaining LDR applicability to CERCLA response actions.   READ MORE  


January CAA packages

Don’t worry about mixing up holiday gifts with your CAA seminar package this year. If you plan on attending next month's January 16-18, 2024, .VIRTUAL Clean Air Act seminar, rest assured, we’re holding off on shipping course materials until after the New Year… we know you have plenty of other packages to deal with this holiday season. And if you register before January 9th—shipping is on us! 

Sign up for next month’s class

CAA class agenda 




Complete TCE ban proposed

Trichloroethylene (TCE) is used as a solvent in many industrial, commercial, and consumer applications, even though chronic exposure is linked to numerous life-threatening effects. Since hundreds of millions of pounds of TCE are produced in the United States annually, EPA published a TSCA risk evaluation on this chemical in 2020 and 2023. The agency found TCE presents an unreasonable risk of injury to health, and on October 31, 2023, it proposed a rule prohibiting the manufacturing, processing, and distribution of TCE. [88 FR 74712] The proposal also includes a prohibition on TCE disposal to industrial pre-treatment, industrial treatment, and publicly owned treatment works. EPA then followed up with a webinar explaining the proposed rule in detail. Additional information is available on EPA’s risk evaluation for TCE and risk management for TCE websites and via Docket ID No. EPA-HQ-OPPT-2020-0642-0026.


Accessible masterpieces 

In a new innovative exhibit, famous art masterpieces are made accessible for the blind and visually impaired. It’s called "Masterpiece Relief for the Blind," by sculptor Tomas Bustos. Bustos will display pieces like his bronze-casted tactile recreation of the "American Gothic" and his reinterpretation of the “Mona Lisa,” unveiling the transformative impact and power that truly accessible artwork can have.

Check out Tomas Bustos’ work




Knocking out leaded aviation fuel

According to the World Health Organization, zero is the only safe blood lead concentration. Yet in 2020, piston-engine aircraft in the United States emitted 427 tons of lead into the atmosphere. Lead toxicity has been known for millennia, and EPA is now ready to take the next step to reduce lead exposure. The agency has issued a double finding on lead emissions that paves the way for future regulation under the CAA’s mobile source program. Such regulation will also require DOT to promulgate associated standards for aircraft fuel and additives.   READ MORE  


Wounded soldiers’ coral reef restoration  

In an 11-year partnership that's evolved into an impactful collaboration and tradition… Mote Marine Laboratory has once again teamed up with members of the Combat Wounded Veteran Challenge to plant corals and restore the Higgs Head coral reef in Florida. The partnership gives wounded veterans a new purpose, time to heal, and a chance to work closely with other military members. And this year, they’ve managed to plant a record-breaking number of corals on the reef. 

Watch the veterans break records!




Finalizing HFC phasedown

On October 24, 2023, EPA finalized hydrofluorocarbon (HFC) phasedown provisions in a new Part 84, Subpart B. [88 FR 73098] The rule is part of the agency’s efforts implementing the 2020 American Innovation and Manufacturing Act, passed to phase down the United States’ production and consumption of HFCs. Reducing HFC use to 15% of baseline by 2036 will allow the U.S. to meet its commitments under the Kigali Amendment to the Montreal Protocol. Part 84, Subpart B restricts the use of HFCs based on global warming potential in specific industry subsectors, creates a process for submitting technology transition petitions, sets reporting and recordkeeping requirements, and provides some exemptions to those provisions. Effective December 26, 2023, the rule sets compliance dates between January 1, 2025, and January 1, 2028, depending on the subsector. EPA also provides additional information on its HFC phasedown efforts and answers to frequently asked questions.


E-waste is waste too

We live in a world where new and incredible electronic products are created each and every day. And it's compelling large manufacturers like Samsung to revolutionize the way their electronics are produced, recycled, and repurposed. Shop Samsung’s recycled products, rather than the more harmful alternative of single-use products—sent to landfills like the Agbogbloshie dump, the world’s largest e-waste junkyard, in Ghana’s capital, Accra.






NHSM’s defining change

While hazardous waste is typically the focus of RCRA, knowing how nonhazardous wastes are regulated is just as important. The Part 241 nonhazardous secondary materials (NHSM) regulations are not only part of RCRA, they also interface with the CAA. Back in 2018, a petition requested amendments to these NHSM provisions, and while EPA recently denied most of the requested changes, one definition did receive a performance-based update.   READ MORE  


Music festivals taking initiative! 

Glastonbury, one of the largest music festivals in the world, has not only made a name for itself with its headline acts like the late David Bowie and Sir Elton John but by taking a green initiative and setting the stage for other festivals around the world. The organizers built an onsite recycling plant and created clean energy from the festival’s own solar array, pledging to take care of the farm and leave no trace after the festival concludes. And at the June 2023 Glastonbury festival, they’ve taken their passion for the environment to new heights... literally

Glastonbury’s green initiative


New CCR data prompts proposal reevaluation

On November 14, 2023, EPA published a notice of data availability regarding its May 18, 2023 proposed rule (88 FR 31983) on the disposal of coal combustion residuals (CCR) from electric utilities. [88 FR 77941] New data and analysis were submitted during the comment period for the May 2023 proposal but have not been made available until now. The agency believes the new information, coupled with its own research, is significant enough to reevaluate the initial proposal and obtain new comments on the data. EPA developed a risk assessment to support the 2023 proposed rule and has made public information available via Docket ID No. EPA-HQ-OLEM-2020-0107.


2024 in-person lineup is here! 

The 2024 in-person seminar lineup is here! Get RCRA training anywhere from the warm Houston sunshine all the way to the beautiful waters of Lake Tahoe—McCoy in-person seminars are open for registration! And whether you’re attending locally or are traveling from out of town, we recommend reserving a seat in class and making your hotel arrangements with the McCoy room rate ASAP… accommodations can fill up in a jiffy. 

Full 2024 seminar lineup

Have a registration question? Contact us by emailing,, or by calling our office number, 303-526-2674, and we’ll be happy to assist you!


2024 Seminars

3-Day CAA Seminars
.VIRTUAL: January 16–18, 2024
.VIRTUAL: April 9–11, 2024
.VIRTUAL: August 6–8, 2024
.VIRTUAL: October 22–24, 2024

5-Day RCRA Seminars
.VIRTUAL: February 5–9, 2024
Virginia Beach: March 11–15, 2024
.VIRTUAL: May 6–10, 2024
Denver: June 24–28, 2024
.VIRTUAL: July 22–26, 2024
Lake Tahoe: August 19–23, 2024
.VIRTUAL: September 16–20, 2024
.VIRTUAL: November 4–8, 2024

2-Day RCRA Refreshers
.VIRTUAL: February 21–22, 2024
.VIRTUAL: June 11–12, 2024
Houston: November 20–21, 2024

Visit to register or call us at 303-526-2674.


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Copyright ©2023 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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