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McCoy's RCRA Review

May 2024

Oil and natural gas NSPS overhaul

While vital to the American economy, the oil and natural gas industry is responsible for up to 30% of the country’s methane emissions. Regulated under the Clean Air Act, the industry has been subject to ever-increasing regulation and tightening stationary source standards. In early 2024, EPA finalized a rule significantly increasing the compliance requirements for these climate change contributors. As compliance deadlines approach over the next few years, new and existing sources in the oil and natural gas source category will be responsible for slashing emissions, expanding monitoring, and implementing optical gas imaging.   READ MORE  


RCRA in Denver! 

Struggling to understand the regs? We’ve got you covered. Join us at McCoy's 5-Day "in-person" RCRA seminar at the Denver Sheraton West from June 24-28, 2024. Spend a week away from the office to solely focus your attention on RCRA and take a step closer to your goal of mastering compliance.

RCRA in Denver sign up


RSVP, network at Denver!

We're holding a networking event at our Denver “in person” RCRA seminar. Join us immediately following class on Wednesday, June 26, 2024, for McCoy’s “Food and Feather” evening with snacks, networking, and the chance to see the beautiful birds of prey from HawkQuest up close and in action. Stay tuned for more info in our newsletter and at the seminar.

Check out the 2023 hawk in flight


Pesticide risks in produce?

Concerned about what's in your food? Consumer Reports' latest analysis reveals an unsettling level of pesticides in our daily fruits and vegetables, serving as a reminder that even the foods we’ve deemed healthy can still hold risks. Although this can come as a shock, don’t be discouraged! There are still plenty of fruits and vegetables with low pesticide risk levels— read through them here to see what's safe and what's not! 






Safe and available OB/OD proposal

Open burning and open detonation (OB/OD) allow for the treatment of waste explosives and munitions that cannot be safely disposed of through other modes of treatment. Because these operations do not use emission capture technologies, the environment surrounding these OB/OD units is often highly contaminated. On March 20, 2024, EPA proposed amendments for the OB/OD of waste explosives, requiring facilities to evaluate and use safer alternative technologies when available. The proposal would result in new Parts 264 and 265, Subpart Y, addressing issues including OB/OD waste analysis, minimum technological standards, exemptions, and unit closure.   READ MORE  


Subpart P pharmaceuticals applicability

Recent EPA guidance addresses challenging scenarios regarding very small quantity generator (VSQG) requirements for hazardous waste pharmaceutical management. Questions posed to EPA inquire on VSQG pharmaceutical disposal options and the effects of opting into Part 266, Subpart P. The agency also discusses navigating episodic generation and VSQG disposal options, given the unique nature of Subpart P applicability for VSQGs.   READ MORE  


CA Title 22-RCRA with McCoy 

Exciting news awaits—McCoy is launching a brand new .VIRTUAL seminar focusing on California's hazardous waste regulations this fall! If you've been searching for clarity on California's state-specific regulations, this is the class you've been waiting for… the search is finally over. 

Our presenters will highlight and unravel the connections between federal RCRA, California's hazardous waste regulations, and the California Health and Safety Code (HSC). Don't miss out—register today for our CA Title 22-RCRA .VIRTUAL seminar, scheduled October 7-10, 2024!

McCoy’s California Title 22 White Paper
See the seminar agenda here




Integrating new iron and steel emission limits

On April 3, 2024, EPA finalized its review of the integrated iron and steel manufacturing NESHAP. [89 FR 23294] Effective June 3, 2024, the Part 63, Subpart FFFFF revisions require fenceline monitoring for chromium, set limits for previously unregulated mercury, hydrogen fluoride, and dioxins/furans emissions, and institute work practice standards. Though initially proposed, reduced opacity limits for certain blast furnaces and basic oxygen process furnaces (BOPFs) were not finalized. The list of affected sources has also expanded, meaning Subpart FFFFF now also applies to fugitive and intermittent particulate matter emissions from equipment such as blast furnace unplanned and planned bleeder valve openings, blast furnace and BOPF slag processing, handling, and storage units, and blast furnace bell leaks.


E-Bikes and Li-ion batteries? 

McCoy’s hometown has a hugely popular e-bike rebate program! With rebates claimed within minutes after release, nearly 8,000 electric bikes now cruise down the streets. And Denver isn't alone; cities across the country are joining in on the e-bike rebate movement.

Unfortunately, you can’t bring up e-bikes these days without mentioning the growing concern over the lithium-ion batteries used to power e-bikes, e-scooters, and other electric devices. Due to the battery's safety issues, cities like New York City and Denver are now requiring all e-bikes purchased with vouchers to meet independent UL certification standards to ensure the safety of the controls and lithium-ion batteries.




EPA rolls out P2 Hub

In EPA’s waste management hierarchy, pollution prevention is the most preferred method of materials management. Rather than dispose of a waste or even recycle it, wouldn’t it be best if that material was never generated in the first place? Pollution prevention, also known as P2 or source reduction, is any practice that reduces, eliminates, or prevents pollution at the source. P2 is not just the responsibility of businesses and government agencies—a P2 approach can even be adopted in our homes. EPA recently launched its P2 Hub Resources Center, which provides links to everything from environmental justice mapping to financing.   READ MORE  


Stay compliant; get Refreshed

Whether you're hitting the beach, exploring new hiking trails, or simply soaking up the sun—everyone is pretty jam packed over the summer… and that usually makes RCRA training an afterthought. That’s where McCoy’s 2-day Refresher seminars come into play. Register for our June 11-12, 2024, .VIRTUAL RCRA Refresher for a convenient way to stay compliant with the regulations without disrupting your summer plans—get trained and enjoy your summer hassle-free!

.VIRTUAL June Refresher registration
Refresher agenda


E-cig safe disposal

E-cigarettes contain nicotine, a p-listed chemical, and lithium batteries. Lithium is a highly reactive metal. Damaged lithium batteries can ignite and cause fires during storage at a generator’s facility or during transportation and disposal. Due to these unique hazards, EPA does not recommend disposing of e-cigarettes in household trash or recycling. Instead, e-cigarettes should be disposed of at household hazardous waste collection sites, which can typically be found through city, county, and state websites. EPA has a printable fact sheet on its website detailing proper e-cigarette disposal.


Clear your CAA brain

Are you lost in the labyrinth of never-ending CAA permits and forms? Do you have a million tabs open trying to understand the applicability matrix? Finally found what you need, but not sure if it works for your facility? If you answered yes to any of these—you’ve come to the right place. We know it can be overwhelming, so we’ve made a seminar to clear things up for you. Sign up for the August 6-8, 2024, CAA .VIRTUAL seminar and gain an understanding of how to navigate the Clean Air Act with confidence.

See our CAA seminars!
CAA agenda






Healthy household drug disposal

Proper storage and disposal of unwanted medications are essential to prevent accidental poisonings and releases into the environment. While commercial facilities have a clear set of RCRA regulations for managing hazardous waste pharmaceuticals (40 CFR Part 266, Subpart P), such an approach may be a bit overkill for households. EPA’s new household medication disposal website offers resources to help individuals properly manage unwanted or expired medications.   READ MORE  


Next 5-day .V RCRA

Ready to take your compliance game to the next level? McCoy’s 5-Day .VIRTUAL RCRA seminar is coming up July 22-26, 2024. Instead of a dull zoom webinar focused on just checking boxes— this class is about learning RCRA inside and out, staying ahead of regulatory updates, and fully grasping compliance strategies. Sign up for the July 5-Day session, and level up your RCRA know-how!

Sign up early to avoid extra shipping charges
See the full McCoy seminar schedule


NOX NAAQS review kickoff

Conducting a periodic review of a national ambient air quality standard (NAAQS) is a multi-year process composed of many incremental steps. In March 2024, EPA announced it had begun stage one, the planning phase, of its nitrogen oxides (NOX) NAAQS review by making volume 1 and volume 2 of the three-part integrated review plan (IRP) available to the public. [89 FR 19308] IRP volume 1 provides background information on the health-based air quality criteria and primary standards for NOX. IRP volume 2 identifies policy-relevant issues in the review and describes key considerations for EPA’s development of the follow-up integrated science assessment (phase two). Volume 3 will be released later and is the planning document for quantitative analyses to be considered in the future policy assessment (phase three). EPA’s NAAQS review website contains more information on the stages of the periodic review process.


Golden Mole’s rediscovery 

Thought to be extinct since 1936, De Winton’s Golden Mole recently made a surprise comeback. It was found courtesy of a scent-sniffing dog, a team of scientists, and traces of the mole's DNA. Watch this adorable and short video explaining that a Golden Mole was eventually spotted along the west coast of South Africa, making it's rediscovery story a memorable one


2024 Seminars

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

5-Day RCRA Seminars
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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