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McCoy's RCRA Review

February 2024

Universal waste additions

Solar panels are ordinarily nonhazardous when disposed of; however, some solar panels contain enough toxic metals to meet the definition of hazardous waste. Lithium batteries, when mismanaged, pose unique hazards when sent for disposal. Despite these materials being a vital part of weening the country off of fossil fuels, the push for sustainability continues to impact environmental regulations. EPA recently announced plans to propose adding solar panels and lithium batteries to the Part 273 universal waste regulations. The goal is to promote solar panel recycling and improve safety standards for lithium batteries by creating new distinct universal waste requirements for these materials.


Plenty of VB RCRA seats and leprechauns? 

Head to the coast this March 11-15, 2024—because McCoy’s five-day RCRA seminar in Virginia Beach, VA is calling your name! Enjoy a captivating week of training on the hazardous waste regulations and for dinner, venture across the street to Murphy’s Irish Pub and listen to bagpipe performances, indulge in corned beef and cabbage, and hopefully catch a leprechaun… don’t forget to wear green!

Feeling extra festive? Stay an extra day after the seminar and on Saturday, March 16, take a drive over to the 57th Annual Saint Patrick’s Day Parade in Norfolk, Virginia. It's about a 25-minute car ride from the hotel. 

Register for Virginia Beach!


The year of the train

All aboard—2024 could be the year of the train! As the locomotive resurgence takes shape, projects are beginning to unfold. Brightline became the first privately owned company to launch a passenger train in the U.S. in over 100 years with its high-speed line running from Miami to Orlando. And this past fall, the first ever 100 percent battery powered train was built. Could this be the return of the railroad?






Small bump to 2024 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, the 2024 increases are slightly above 3 percent—further demonstrating the cost of noncompliance.   READ MORE  


Dance with the CAA 

It takes focus, strong will, and quick feet to tango with the Clean Air Act. And for that, we salute you. The CAA is a tough partner to keep pace with—so if you feel like you’re falling behind on your steps, have no fear! Sign up for the April 9-11, 2024, Clean Air Act seminar, and we’ll have you ready for the big performance! 

CAA “rehearsal” agenda

All CAA seminars


NSR Title V tie-in

On January 9, 2024, EPA proposed an update to the CAA Title V operating permit program to codify existing guidance on how “applicable requirements” under the new source review (NSR) preconstruction permitting program should be reviewed and implemented through the Title V program. [89 FR 1150] In essence, EPA’s position is that if a source obtains an NSR permit under EPA-approved CAA Title I rules (including public notice, an opportunity for comment, and judicial review), such a permit establishes NSR-related “applicable requirements” for purposes of incorporation into the source’s Title V permit. EPA would not revisit those NSR permitting decisions through the Title V process. The proposal also clarifies that a facility’s general duty to prevent accidental releases of hazardous substances [CAA Section 112(r)(1)] is not a Title V “applicable requirement.” Comments may be submitted through May 5, 2024 via Docket ID No. EPA-HQ-OAR-2023-0401.


New holiday in Kenya 

There's a new tree-planting holiday in Kenya and it's a reason to celebrate. Its purpose isn’t so everyone can take the day off, but to give citizens a chance to come together and plant 100 million trees collectively. With over 150 million seedlings available for free to the public, each Kenyan is encouraged to plant at least 2 seedlings. Although the holiday is a good idea, it needs to be carried out diligently to ensure the trees are planted and the celebration is a success. 

Kenya’s tree planting festivities


WARM up this winter

Estimating the economic impacts of climate change can be challenging—multiple variables need to be considered while incorporating future projections. On December 26, 2023, EPA released the waste reduction model (WARM) tool version 16. By reviewing municipal solid waste streams and construction/demolition materials, WARM estimates and compares potential greenhouse gas emissions, energy savings, and economic impacts of materials management practices.   READ MORE  




Compliance at your fingertips 

Say goodbye to long hours of research. The perfect RCRA search engine exists and it's called the McCoy Sherpa. As fun as searching for the right hazardous waste answers may be, why not make your life a whole lot easier and speed up the process? The Sherpa contains over 27,500 pages of relevant RCRA information, including a hierarchical format of the regs, and guidance on them… what more could you need? 

Sign up for the May 6-10, 2024, .VIRTUAL seminar or any future McCoy seminar and receive a $200.00 discount on your Sherpa!

McCoy Sherpa pricing and discounts


Climate change impacts RCRA permits

Curbing climate change is at the forefront of EPA’s national enforcement and compliance initiatives. This includes EPA’s drive to incorporate climate change initiatives into the RCRA permitting process. On December 12, 2023, EPA published a draft memorandum providing guidance on how to consider potential adverse climate change impacts during the hazardous waste permitting process.   READ MORE  




A far-fetched friendship 

The most unlikely of friendships has reached the public eye as the first evidence of social relationships amongst chimpanzees and gorillas came into light after 20 years of research. Apes, who aren’t known to associate with other animals, have been documented feeding, foraging, and playing together for the first time with another species.  

Chimpanzees and gorillas’ new companionship


Explosive OB/OD alternatives

Open burning (OB) involves destroying materials through self-sustained combustion. Open detonation (OD) is detonating explosives or munitions with added explosive charges. In December 2023, EPA published a Compendium of Alternative Technologies to Open Burning and Open Detonation of Energetic Hazardous Wastes. The alternative technologies are waste and site-specific, and the agency emphasizes that a technology used at one site may not work for another. As such, the compendium allows users to compare waste streams that have been treated or destined for treatment by different alternative technologies. EPA plans on updating the compendium as new information becomes available, and feedback on the compendium can be submitted to the agency via email to


2024 Seminars

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

5-Day RCRA Seminars
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
Las Vegas: December 9–13, 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 ©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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