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McCoy's RCRA Review

April 2024

It’s here! CA Title 22-RCRA .V seminar  

Hey Californians! Have you heard the news? McCoy’s new .VIRTUAL seminar on the California hazardous waste regulations is happening this fall! If you’ve attended our seminars before and hoped to clarify California’s state-specific regulations, this is the class for you. We’ll help bridge the gap between federal RCRA, the California hazardous waste regulations, and California Health and Safety Code (HSC). Register for our CA Title 22-RCRA .VIRTUAL seminar, to be held October 7-10, 2024

Check out the seminar agenda


EPA’s FY 2023 enforcement review

Climate change, environmental justice, and PFAS contamination are hot-button issues in environmental policy. To improve in these areas, EPA established goals and objectives in its strategic plan and national enforcement compliance initiatives. EPA recently published and summarized its fiscal year 2023 results and provided plenty of resources and data documenting how it accomplished some goals ahead of schedule while progressing toward others.   READ MORE  


McCoy’s e-product

What’s a "McCoy Sherpa"? Our office sits at the base of the 14,436-feet-high Rocky mountains and we have enduring respect for our local alpine guides and rescuers. Furthermore, we have unending respect for the Tibetan ethnic groups, native to the mountains of Nepal and Tibet. Sherpas and Sherpani (women who are Sherpas)—are the greatest and most influential mountain climbers and guides in the world.

Thus, when you wade through the voluminous data known as the RCRA federal regulations (to protect human health and the environment), our electronic product will assist as your guide. It includes 50,000+ hyperlinks, 679 Federal Register notices (going back to 1978), and 1,531 RCRA Online documents in a searchable PDF format. And yep, it also includes McCoy's RCRA Reference and RCRA Unraveledget one today!

Compare our publications
Sherpa pricing




Mandating e-manifest for agency-led cleanups

Though EPA launched the e-manifest system on June 30, 2018, adoption by the regulated community has been lackluster, as indicated in the agency’s webinars. The agency believes one way to boost adoption numbers is to lead by example. To achieve this goal, EPA’s Office of Land and Emergency Management recently published RO 14961, which requires the agency to use the e-manifest system during EPA-led emergency response and removal actions starting in FY 2025. This internal memorandum requires EPA regions and partner offices to determine the necessary elements to transition existing and future cleanups to using e-manifests. EPA personnel can register for e-manifest access via RCRAInfo, and agency e-manifest contacts are available to help fulfill this new requirement.


New Zealand bans PFAS in cosmetics 

Though a few states in the U.S. have managed to do so, New Zealand will potentially become the first country to successfully ban PFAS substances from their cosmetics. PFAS, known as “forever chemicals”, because of their inability to easily break down or be destroyed, have been found present and usually unlabeled in popular makeup products. New Zealand's ban will begin in 2026, and hopefully other countries will follow suit.

PFAS in U.S. cosmetics




Plenty of seats and at 5280!

Taking place at the Denver Sheraton West—June 24-28, 2024—is McCoy's 5-Day “in-person” RCRA seminar. Whether you're new to RCRA or want to brush up on your existing knowledge, this seminar will benefit waste professionals at all levels. Don't miss the opportunity to connect with experts, network with peers, and take your environmental compliance knowledge to a higher level. 

Register for McCoy's seminar in Denver
Class agenda


See a hawk fly at McCoy's office

Save the date! You’ve asked for networking opportunities, so at our Denver 5-Day RCRA seminar, please join us for McCoy’s “Foods and Feathers” open house. We’ll have a shuttle from the hotel to and from our office, provide light appetizers, and best of all, see the beautiful birds of prey from HawkQuest. Mr. Kin Quitugua, a master falconer and longtime environmental educator, will bring (and fly) one of his hawks. Event starts immediately following the Wednesday, June 26, 2024, class.


Multi-point PCB plans

In August 2023, EPA finalized PCB cleanup and disposal regulations under the Toxic Substances Control Act (TSCA). [88 FR 59662] The rule expanded the options for extraction and determinative methods used for characterizing PCB waste. The agency expects this change to reduce the amount of solvent used in these processes. Additional resources and links to a webinar on this rule are on EPA’s website. Following this rule in December 2023, EPA issued a draft memorandum on its approach to incorporate climate change resilience measures into PCB approvals. This approach encourages project managers overseeing PCB approvals to assess how cleanup, storage, and disposal will affect climate change. The requirement for unreasonable risk determinations will now include an assessment of future conditions. Facilities undergoing self-implementing cleanups in areas EPA believes are vulnerable to adverse climate impacts will have to provide additional documentation to the agency beyond what is required in the TSCA PCB regulations.


Mindful sleep? 

Forget counting sheep—practicing mindfulness meditation might be the secret for a better night's sleep

A study in JAMA Internal Medicine found that practicing mindfulness can help eliminate exhausting and racing thoughts that keep you up at night. The idea is to create a “reflex of relaxation.” That way, you can tap into this response when you can’t sleep,” says Dr. Herbert Benson, director emeritus of the Harvard-affiliated Benson-Henry Institute for Mind Body Medicine. So, close your eyes and give mindfulness meditation a try.

Ted Talk on mindfulness meditation






ISA leads charge on lead

On February 7, 2024, EPA announced the availability of its “Integrated Science Assessment for Lead,” or ISA. [89 FR 8425] As a CAA criteria pollutant, lead has primary and secondary national ambient air quality standards (NAAQS) to protect public health and welfare. The ISA is an evaluation of the most policy-relevant science that forms the scientific foundation for reviewing NAAQS. As the toxic effects of lead have been known for millennia, the ISA is not overturning our knowledge of lead’s deleterious impacts. Instead, the document provides further quantitative data that can be used to support future reductions to emission limits.


Be a citizen scientist!  

Looking for enrichment outside of your normal workday? Perhaps you’re curious about crowdsourcing in the name of interesting, science-based projects. website is designed to make practical use of crowdsourcing and enroll citizen scientists across the U.S.

The site provides a portal to a catalog of federally supported citizen science projects, a toolkit to assist practitioners, and a gateway to a community of hundreds of citizen science practitioners and coordinators. Take a look at the project catalog and begin exploring!




Emission tamp down for taconite

Taconite, a low-grade iron ore, was once considered a waste rock; however, the mineral is now considered a valuable resource in the steel manufacturing industry. Taconite iron ore processing is regulated under Part 63, Subpart RRRRR, which EPA amended under a final rule on March 6, 2024. [89 FR 16408] The rule does not change the applicability of this NESHAP but does set an implementation deadline associated with the tighter mercury and acid gas emission limits. While not a broadly applicable rule with only eight affected sources, the agency still expects mercury emissions to be reduced by 33% and hydrochloric acid and hydrofluoric acid emissions by 72% and 29%, respectively. Particulate matter emissions are also expected to decrease by 35% relative to baseline. More information is available via Docket ID No. EPA-HQ-OAR-2017-0664.


...about McCoy's .V seminars

Signed up for a McCoy .VIRTUAL RCRA seminar and aren’t sure what to expect? Here’s a few important tidbits:

The training is presented via Zoom and is a live broadcast of the “in-person” seminar (it’s not dull). Course materials are shipped prior to the seminar and include the RCRA Reference and RCRA Unraveled books, plus a binder with the latest course notes.

The class provides a logical understanding of RCRA, shows you how to stay up to date with the most recent changes to the regs, and we discuss “best practices” for maintaining compliance. Sign up for the May 6-10, 2024, 5-Day, or the June 11-12, 2024, 2-Day Refresher seminar. 

5-Day agenda
2-Day Refresher agenda
McCoy full schedule


PM NAAQS mostly unchanged

Based on its 2022 policy assessment and 2019 integrated science assessment for particulate matter (PM) discussed in a previous article, EPA finalized the primary and secondary PM national ambient air quality standards (NAAQS) on March 6, 2024. [89 FR 16202] The agency retained the primary and secondary 24-hour PM2.5 standards, the secondary annual PM2.5 standards, and the primary and secondary PM10 standards. Only the primary annual PM2.5 standard has changed, reduced from 12.0 µg/m3 to 9.0 µg/m3. EPA also updated the PM air quality index and monitored network design criteria. More information, including factsheets, presentations, and maps, is available on the agency’s final reconsideration of the PM NAAQS website.


2024 Seminars

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

5-Day RCRA Seminars
.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: 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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