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McCoy's RCRA Review

June 2024

Join us for Food…and feathers!

Get ready for this year’s Food and Feathers event taking place immediately after the Denver RCRA seminar wraps up Wednesday, June 26, 2024. It’s right next door at the Sheraton Denver West Hotel! Enjoy light appetizers, network with fellow professionals, and the highlight of the evening…get an up-close encounter with the stunning birds of prey from HawkQuest! You won’t want to miss this one. 

Check out last year’s event held at the McCoy office


Last chance for Denver 

Don’t miss out on your last chance to sign up for McCoy's immersive 5-Day "in-person" RCRA seminar at the Sheraton Denver West from June 24-28, 2024. If you’ve been considering signing up… don’t wait as we have a few seats left. Hurry up and secure your spot today before registration closes! Once all spots are filled, we’ll start a waitlist! If you have any questions, contact us at 303-526-2674 or


Next step in NSR revisions

For much of the CAA’s new source review (NSR) program’s history, emission decreases were not allowed to be considered in step 1 of a major modification determination. Though that provision officially changed with the 2020 project emissions accounting rule, EPA recognized some loopholes were introduced to the NSR program. Now, the agency proposes to button things up by better defining what constitutes a project, strengthening administrative requirements, and requiring emission decreases to be enforceable.   READ MORE  




PFAS D&D guidance updated

In April 2024, EPA updated its December 2020 interim guidance on per- and polyfluroralkyl substances (PFAS) and PFAS-containing materials destruction and disposal technologies. The updated guidance reviews three existing PFAS destruction technologies: landfilling, incineration, and deep-well injection. The interim guidance also evaluates the effectiveness of four emerging technologies and covers technology evaluation methods.   READ MORE  


Head to the EHS HAZMAT Summit! 

McCoy’s very own presenters, Eric Weber and Andrew Garcia, are set to deliver two seminars each at the EHS HAZMAT Summit, taking place this July 14-17, 2024, in Kansas City, Missouri! Eric will cover the air regs in a 4-hour Clean Air Act Refresher Course and a shorter break-out, CAA for Non Airheads. While Andrew will focus on RCRA with the RCRA Recycling Exclusion and Avoiding the Most Common Mistakes in Waste Identification.

For more on speakers and start times—take a look at the event agenda!






Enforceable MCLs for PFAS

EPA regulates emerging contaminants of concern in drinking water through the Safe Drinking Water Act (SDWA). On April 26, 2024, EPA finalized a national primary drinking water regulation establishing maximum contaminant levels (MCLs) and goals for six individual per- and polyfluoroalkyl substances (PFAS) and mixtures of PFAS under the SDWA. This final rule also includes a novel hazard index MCL, public notice, monitoring, and reporting requirements.   READ MORE  


No more permits for “other” incinerators

CAA Title V permits are not only for major sources of hazardous air pollutants—many area sources, incinerators, and mineral processors also require them. But does a Title V permit make sense for low-emitting equipment often only used temporarily to manage natural disaster-derived vegetation debris? State and industry stakeholders did not believe so and provided comments as part of an August 2020 other solid waste incineration units (OSWI units) source category review. [85 FR 54178] On April 17, 2024, EPA exempted from Title V permit requirements air curtain incinerators regulated under Part 60, Subpart EEEE or Subpart FFFF that burn only wood waste, clean lumber, and yard waste. [89 FR 27392] The rule eliminates only the need to obtain a Title V permit but still requires compliance with the emission and opacity limits in these standards.




Take on RCRA and CA Title 22!

Managing hazardous waste in California can be a tall order. The regulations may be more extensive than federal RCRA. And on top of that, you have to understand both the California Health and Safety Code (HSC) and the California Code of Regulations (CCR). Which can be a lot to handle all at once. That’s where we come in. Join us for our all-new .VIRTUAL seminar centered around California's hazardous waste regulations this October 7-10, 2024! 

McCoy California Title-22 registration
Seminar agenda


Stationary combustion turbine delisting petition squashed

CAA Section 112(c)(9) provides a mechanism by which EPA may use its discretion to delist source categories from the NESHAP program. In 2019, members of the oil and natural gas industry petitioned the agency to delist the stationary combustion turbine source category regulated under Part 63, Subpart YYYY. On April 16, 2024, EPA denied the petition on the grounds it was incomplete and associated health risk criteria were not met. [89 FR 26835] The agency also stated the denial is “with prejudice” and will deny any future petition to delist the source category as a matter of law unless a future petition is accompanied by substantial new information or analysis.


CAA this August 

If the Clean Air Act is still causing you to burnout, and the applicability matrix is adding fuel to the fire, sign up for the next CAA .VIRTUAL seminar August 6-8, 2024. We’ll help put out the flames! The course is designed to break down the complexities of air, while providing clear guidance on the regulations. Don’t miss out—register now to start cooling the CAA burnout with ease. 

CAA sign up
See the 3-Day format


Sterilizing EtO emissions

Ethylene oxide (EtO) is a critical chemical in the healthcare industry as a sterilization agent. As a hazardous air pollutant, EtO is regulated under Part 63, Subpart O, and on April 5, 2024, EPA finalized its residual risk and technology review of the commercial sterilization facilities NESHAP. [89 FR 24090] The rule revamps Subpart O by broadening applicability, adding continuous emissions monitoring requirements for most facilities, and regulating more sources. Staggered compliance times and variable emissions reduction targets are set, depending on the emission source and quantity of EtO used. The agency has published a compliance guide to help sterilizers get up to speed on the new rule.






Minor revisions to major source standards

On April 4, 2024, in response to petitions, EPA finalized a series of revisions to four Part 63 air toxic standards: Subpart CC petroleum refineries, Subpart YY ethylene production, Subpart EEEE organic liquids distribution, and Subpart FFFF miscellaneous organic chemical manufacturing. [89 FR 23840] The final rule includes three primary changes. First, pressure relief devices and smoking emergency flares during force majeure conditions must be evaluated and accounted for. Second, floating roof storage vessels may be opened before degassing but only in a limited manner and without actively purging the tank. Third, heat exchange system leak monitoring may use water sampling methods in limited instances.


Wallpaper made with windows?

In today’s AI driven world, it's refreshing to see such a recognizable image like the Windows 10 wallpaper that is a handcrafted art piece, rather than something generated by a computer. The very familiar wallpaper was made using real mirrors, lasers and smoke by the designer and globally renowned artist Bradley Munkowitz, also known as GMUNK.


PVC petition denied

In early 2023, EPA tentatively denied the Center for Biological Diversity’s request that discarded polyvinyl chloride (PVC) be listed as a hazardous waste under RCRA. After a recent public comment period, the agency has affirmed its earlier decision and formally denied the petition. The CAA already regulates air emissions from incinerators that may combust PVC, and RCRA prohibits open solid waste dumping while setting landfill leachate standards. EPA found these considerations and stakeholders’ failure to provide sufficient information to justify listing discarded PVC as a hazardous waste warranted the petition’s denial.


Mercury imports rising

On December 26, 2023, EPA’s Office of Chemical Safety and Pollution Prevention announced the availability of the 2023 Mercury Inventory Report for the 2021 reporting year. [88 FR 88915] This report summarizes data collected from mercury manufacturers, importers, and processors on mercury supply, use, and trade in the United States, including mercury recycling. Though elemental mercury exports are banned under the 2008 Mercury Export Ban Act, exporting mercury-added products is generally not prohibited. Additionally, the import of mercury and mercury-added products has increased despite a lack of national recycling options. When mercury is recovered from mercury-containing waste and metal ore and discarded, that recovered elemental mercury would carry the RCRA U151 waste code. [RO 14934]


NATURE makes music…

Nature has become an official musical artist and has its own Spotify page as well as other music streaming platforms. You heard that right… the sounds of rain, forests, animals, and songs with some of the world’s biggest artists on feat.NATURE. And that's not even the best part—revenue from the tracks that credit NATURE will support conservation projects—it’s projected to raise more than $40 million from more than 600 million listeners in its first four years. Learn about the project


Next “in-person” in Lake Tahoe

If you’re a fan of the “in-person” seminar experience, then McCoy’s next RCRA course at Harveys Lake Tahoe could be the class for you. Taking place August 19-23, 2024, experience five days of hands-on RCRA training with the McCoy presenters and course materials. And while you’re in town, make the most of what beautiful Lake Tahoe has to offer—summer concerts, themed festivals, and many more fun events take place the week of the seminar. 

Lake Tahoe seminar registration


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
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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