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McCoy's RCRA Review

February 2023

2021 Biennial results released

The latest biennial numbers are in: U.S. large quantity generators generated nearly 36.7 million tons of hazardous waste in 2021, just over half of which is generated in Texas. Waste generation and management data are available online back through the 2001 reporting cycle.   READ MORE  


Is it real? Or virtual?

Both. This April don’t go anywhere because our classroom is coming to you! McCoy .VIRTUAL seminars are a live broadcast that brings the training right to your door. With two dedicated presenters and physical course materials that guide you through the ins and outs of RCRA—you may forget you aren't actually in the classroom. Sign up for the April 24-28, 2023, McCoy .VIRTUAL class and get ready to bring the seminar to you! 


G5 Site remediation reshuffle

Previously, site remediations could be subject to either a CERCLA/RCRA clean-up program or the air toxics site remediation standard, but not both. On December 22, 2022, EPA removed the CERCLA/RCRA exemptions from Part 63, Subpart GGGGG. Now, even if your site is subject to a CERCLA or RCRA remediation program, those clean-up activities may still need to be CAA-compliant. The agency also decided to retain the “co-location” provision, so sources not subject to another air toxics standard will not be pulled into G5.   READ MORE  


Inflation pumps 2023 penalties

EPA is required by law to annually adjust the maximum civil penalties allowed under environmental law to account for inflation. Because the adjustments are tied to the consumer price index, it’s no surprise the 2023 increases are approximately 8 percent. Thus, the cost of noncompliance continues to increase.   READ MORE  




Solve the puzzle

You have the pieces and can see some of the patterns, but still struggle to put it all together? The Clean Air Act can certainly feel like a riddle. That's why McCoy CAA seminars were started, to provide better guidance and understanding on the Clean Air Act and help you uncover the way it works. Join McCoy’s next CAA seminar is April 4-6, 2023, and start to connect pieces of the CAA puzzle.


Stress…sweet spot

In a world where stress seems pretty much inevitable, why should it be looked at as a bad thing? Researchers postulate that the right amount of stress can be a tool for multiple benefits and can vastly improve your day-to-day performance. By finding the perfect balance of stress—high levels of motivation and engagement can be achieved. While having too much can lead to burn out. It's all about finding the sweet spot!






Ultimate RCRA research tool

Used to having a gazillion Google tabs open researching RCRA regulations and struggling to find the information you need? Now you can put that to an end. Imagine a place with vast amounts of RCRA knowledge. An all-in-one spot with the ability to search the regs quickly and easily and get guidance on them. Every compliance answer you could need under one roof. That place exists and it's called the McCoy Sherpa, the ultimate RCRA research tool.

Get more details on the McCoy Sherpa


HAP limits in limelight

From water purifier to soil additive to construction material, lime is highly versatile, and limestone deposits are found worldwide. Lime production begins with limestone mining, and while limestone extraction is not subject to a stationary source standard, lime manufacturing is. EPA has proposed amendments to the lime manufacturing air toxic standard by setting emission limits for previously unregulated hazardous air pollutants and establishing operating parameters for various air pollution control devices. Comments can be submitted on the proposal until February 21, 2023.   READ MORE  


RCRA agenda looks ahead

The Fall 2022 regulatory agenda is now available. EPA continues to focus on regulating PFAS as RCRA hazardous constituents and coal combustion residues. EPA plans to propose a new rule for drum reconditioners due to growing concerns about environmental contamination stemming from these facilities. The agency also plans to make numerous technical corrections to the RCRA regulations.   READ MORE  


Fall into CAA agenda

EPA’s Fall 2022 regulatory agenda is now available. The agency is planning reviews, revisions, and amendments to scores of 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  


PFAS in pesticides

New studies reveal alarming amounts of PFAS residing in pesticides and it’s coming from unfamiliar sources. Larger concentrations than ever before are being found and restriction is the task at hand, and this has triggered Maine as the first state to regulate the harmful chemical. So how exactly is PFAS getting into pesticides and why is it going to be so hard to get rid of?




Invest in e-manifest

Since the inception of the e-manifest system in June 2018, EPA has received an estimated 25,000 electronic manifests out of a total of 7 million manifests created. Less than a half percent of all manifests are electronic. The Hazardous Waste Electronic Manifest System Advisory Board recently made its October 2022 meeting minutes available. The purpose of the meeting was for the board to advise EPA on proposed IT changes to the e-manifest system to increase the adoption of electronic manifests.

The board is hosting its next three-day virtual public meeting February 28-March 2, 2023. [88 FR 2910] and plans to discuss e-manifest program priorities and user fees for 2024 and 2025. 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.


EtO risk redux rejected

After the miscellaneous organic chemical manufacturing NESHAP (Part 63, Subpart FFFF) received its risk and technology review in 2020, EPA received numerous petitions for reconsideration due to previously unavailable data. Petitioners felt the agency’s use of the 2016 integrated risk information system (IRIS) value for ethylene oxide (EtO) was flawed, and a risk value provided by the Texas Commission on Environmental Quality (TCEQ) should be used instead. Developed using a different model, the TCEQ EtO risk value was estimated to be 2000-fold lower than the IRIS risk value. EPA proposed to reject the reconsideration and reaffirm its use of the 2016 IRIS cancer risk value for EtO on February 4, 2022. [87 FR 6466] On December 21, 2022, the agency finalized this decision. [87 FR 77985]




Catch your register early!

Phew, you made it! We know some people prefer in-person seminars, so we want you to know our seating is limited because we are conducting fewer of them as .VIRUTAL is here to stay. Rest assured, making your registration early—will lock-in your spot well before space runs out. Sign up on our website or over the phone and plan your trip today. The March 13-17, 2023, Virginia Beach and the June 5-9, 2023, Denver seminars are right around the corner. Can't wait to see you there.

McCoy’s Full Schedule


Bees at your workplace?

Honeybees are making the move to a new home, and it may not be where you expect. With many corporations budgeting more for the environment and tackling new sustainability projects, look no further than Free Range Beehives, a company that installs and maintains beehives at the jobsite. Its mission is to save honeybees while encouraging wellness and engagement, and in the process, make your office buzz! 


2023 Seminars

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

5-Day RCRA Seminars
Virginia Beach: March 13–17, 2023
.VIRTUAL: April 24–28, 2023
Denver: June 5–9, 2023
.VIRTUAL: July 31–August 4, 2023
Lake Tahoe: August 14–18, 2023
.VIRTUAL: September 18–22, 2023
.VIRTUAL: October 30–November 3, 2023
Las Vegas: December 4–8, 2023

2-Day RCRA Refreshers
Houston: May 17–18, 2023
.VIRTUAL: September 6–7, 2023
.VIRTUAL: November 14–15, 2023

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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