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February 2025 |
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Reading from California?
Reading this from California? Check out our 4-day RCRA Cali Title 22 .VIRTUAL seminar, scheduled for April 14–17, 2025. Over the four days, we’ll cover the latest regulatory updates, break down the newly adopted Generator Improvements Rule (GIR), and of course, cover federal vs California RCRA. And if you didn’t know already—the seminar is live! So, bring the questions you’ve been dying to have answered, or the ones you’ve recently conjured up… enjoy the “mic” feature and speak to our presenters in real time!
4-Day agenda
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Solar Panel FAQs
Because solar panels are not regulated as universal waste under the federal RCRA program, generators who determine their solar panels exhibit the toxicity characteristic may need to manage them as fully regulated hazardous waste. Fortunately, several recycling exclusions may be applicable when managing such waste. EPA recently published answers to frequent questions about managing end-of-life solar panels under RCRA. READ MORE
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Preventing vapes from going up in smoke
Tropical punch, blue lagoon, and razzle-dazzle… just a few of the thousands of flavors available in e-cigarettes. Vaping is everywhere, including schools and small businesses, which is why EPA has come out with guidance on how these entities should be managing collected electronic nicotine delivery systems. To avoid the potential fires and acute poisoning that come from these devices, facilities should individually wrap or bag batteries and e-liquid vials, or if the vape pen cannot be disassembled, place each one in its own plastic bag. Potential disposal options include small business collection programs, offsite consolidation to a parent company, or RCRA-permitted TSDFs.
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Next .VIRTUAL RCRA
Didn’t make it to a February seminar? It’s time to set your sights on McCoy’s next .VIRTUAL RCRA seminars in May and June! Tune in from the comfort of your home or office as expert presenters guide you through the latest in hazardous waste regulations and compliance. Sign up for the 5-Day seminar, May 5-9, 2025, or if you’re a RCRA pro, take the Refresher seminar happening June 24-25, 2025. And don’t forget—McCoy’s updated course binder and the 2025 RCRA Unraveled and RCRA Reference publications are pre-shipped to every attendee.
Full 2025 lineup
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PEPO proposal cuts EtO
On December 27, 2024, EPA proposed amendments to the polyether polyols (PEPO) production industry NESHAP. [89 FR 105986] PEPO are chemicals used to produce lubricants, adhesives, sealants, cosmetics, soaps, and polyurethane foams. Hazardous air pollutants emitted by PEPO production facilities include ethylene oxide (EtO), which is highly carcinogenic. The proposed amendments to Part 63, Subpart PPP aim to reduce EtO emissions by 14 tpy and cut emissions of all hazardous air pollutants by 157 tpy. Additionally, periodic fenceline monitoring of EtO would be required every 5 days, and the monitoring data would be made publicly available through EPA’s WebFIRE database. Comments may be submitted through February 25, 2025 via Docket ID No. EPA-HQ-OAR-2023-0282.
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Ratcheting up 2025 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 penalties incurred in 2025 are approximately 2.5 percent greater than in 2024—further demonstrating the cost of noncompliance. READ MORE
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RCRA model permit update
Title V, NPDES, UIC, MPRSA… environmental permitting is challenging and specific to a facility’s operations. As discussed in a previous article, EPA’s RCRA model permit provides example language vetted by legal and enforcement experts that should reduce permit issuance time and promote consistency. The agency recently updated the RCRA model permit with a module on general permit conditions applicable to all RCRA permits. These modules help permit writers by standardizing the language associated with hazardous waste management permits.
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Virginia Beach next month!
Our in-person RCRA seminar in Virginia Beach is just a month away, March 10-14, 2025! If you’re planning on attending, be sure to register and make hotel accommodations while they’re still available—the McCoy room block at the Hilton Virginia Beach Oceanfront Hotel ends February 21, 2025. Can’t make it to Virginia Beach? Join us in Denver, June 9-13, 2025, or Lake Tahoe, August 18-22, 2025!
For more information on “in-person” seminars, email us at Hello@mccoyseminars.com or call 303-526-2674, and we’ll be happy to assist.
5-Day in-person schedule
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Lay down your CAA foundation
Starting from scratch when a compliance decision needs to be made? As you already know—the Clean Air Act is complicated. It hinges on the specific facility and is painfully permit-driven. But that doesn’t mean you have to start from square one each time. Sign up for McCoy’s April 1–3, 2025, .VIRTUAL seminar, and we’ll clarify the applicability determinations and show how they fit together. Lay down your CAA foundation and save yourself and your facility valuable time!
Upcoming CAA seminars
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LA fire resources
Our hearts go out to those affected by the ongoing fires in Los Angeles. During this difficult time, several resources have become available to provide support: the California government, the LA Homeless Services Authority, and the Legal Aid Foundation of Los Angeles all have resource and assistance pages available on their websites for those affected by the fires.
Want to help? LAist has provided a comprehensive guide on how you can directly assist fire victims—offering direct links to organizations that are actively providing aid to displaced families and individuals. And to stay up to date with the fires, download the Watch Duty App—a tool used by the public and fire fighters.
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Beneath the surface
In just the Western United States alone, there are an estimated 100,000 to 500,000 abandoned mine sites. But did you know they pose both physical and environmental risks? From unstable structures and unsealed shafts, to groundwater contamination, abandoned mines are much more than just an empty tunnel beneath the surface.
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New NAAQS for SO2
Secondary national ambient air quality standards (NAAQS) are designed to protect public welfare. The standards defend against adverse effects on vegetation, animals, weather, visibility, climate, property, and economic impacts. EPA’s final rule covering the secondary NAAQS for sulfur oxides (SOX), nitrogen oxides (NOX), and particulate matter (PM) took effect on January 27, 2025. [89 FR 105692] While the rule does not change the standards for PM or NOX, it does revise the SO2 standard from 0.5 ppm averaged over 3 hours to an annual standard of 10 ppb averaged over 3 years. SO2 is the NAAQS indicator for SOX. EPA believes emission reductions to meet the secondary SO2 standard will not be necessary as existing measures taken by states to meet the primary SO2 standard should be sufficient.
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The Zildjian cymbal
When you think of a drum cymbal, your first thought might be a wild drummer smashing it to bits… but the process of making one is surprisingly a calming and beautiful experience. A Zildjian cymbal, widely regarded as one of the best drum cymbals in the world, begins its journey as a molten blend of copper, tin, and silver before being carefully crafted together by the Zildjian family’s centuries-old techniques.
See how the legendary Zildjian sound is made
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2025 Seminars
3-Day CAA Seminars
.VIRTUAL: April 1–3, 2025
.VIRTUAL: August 5–7, 2025
.VIRTUAL: October 21–23, 2025
4-Day California Title 22-RCRA Seminars
.VIRTUAL: April 14–17, 2025
.VIRTUAL: October 6–9, 2025
5-Day RCRA Seminars
Virginia Beach: March 10–14, 2025
.VIRTUAL: May 5–9, 2025
Denver: June 9–13, 2025
.VIRTUAL: July 21–25, 2025
Lake Tahoe: August 18–22, 2025
.VIRTUAL: September 15–19, 2025
.VIRTUAL: November 3–7, 2025
Las Vegas: December 8–12, 2025
2-Day RCRA Refreshers
.VIRTUAL: February 19–20, 2025
.VIRTUAL: June 24–25, 2025
Houston: November 18–19, 2025
Visit mccoyseminars.com to register or call us at 303-526-2674.
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Copyright ©2025 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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