Here’s the issue of McCoy Review you requested:

March 2025

Calling all LQGs/SQGs

The January 22, 2025 deadline for large and small quantity generators to set up an e-manifest account via RCRAInfo has come and gone. Are you in compliance? Approximately 100,000 of you are, but many are not. To see if your site has set up an account and selected someone with site manager capabilities, check out EPA’s RCRAInfo Public Extract. After clicking “Download List” under “e-Manifest Third Rule Compliance Check,” you can view the .csv file to confirm your facility is good to go. But why is an e-Manifest account even necessary? Amongst other things, designated facilities are no longer required to mail a copy of a signed manifest back to generators confirming receipt of a hazardous waste shipment. You need that e-Manifest account to meet your recordkeeping requirements.

.VIRTUAL CAA is live!

No pre-recorded lectures here—this live broadcast of our CAA training dives into the latest regulatory updates in real time. Have a question? Just turn on your mic and have a conversation with our presenters! Join us April 1–3, 2025, and let McCoy guide you through the behemoth known as the Clean Air Act in this .VIRTUAL seminar and protect our most important asset—clean, healthy air.

Can’t make April?

McCoy .VIRTUAL—California style

California’s RCRA and Title 22 regulations are jam packed with complexity! But that doesn’t have to slow you down—understanding how to stay in compliance doesn’t have to feel like a snail race. In this 4-day .VIRTUAL seminar, we’ll break it all down—helping you grasp the regs and how they might apply to your facility. Get back on track and speed things up with McCoy. Join us for the April 14-17, 2025, Cali Title 22-RCRA combo .VIRTUAL seminar today!

4-Day agenda
Next Cali seminar in October

CMAS proposal also impacts EtO

EPA proposed amendments to the chemical manufacturing area sources (CMAS) NESHAP on January 22, 2025. [90 FR 7942] New requirements in Part 63, Subpart VVVVVV would include stricter leak detection and repair practices for equipment and heat exchangers, emissions reductions from pressure relief devices and vessels, and periodic performance testing. A new source category for chemical manufacturers that use ethylene oxide (EtO) as a feedstock has also been proposed and would be subject to Subpart VVVVVV. Overall, the proposal is estimated to reduce HAPs by more than 160 tpy and smog-forming VOCs by more than 1,550 tpy. The amendments would affect approximately 280 facilities throughout the country. Comments may be submitted through March 24, 2025 via Docket ID No. EPA-HQ-OAR-2024-0303.

Grand Teton’s last unprotected lands

The National Park System spans over 85 million acres, yet more than 2.6 million acres remain privately owned. Grand Teton National Park is closing that gap by permanently protecting a 640-acre piece of land known as the Kelly Parcel—one of its last unprotected stretches.

New tech for OB/OD

In January 2025, EPA published the first update to its compendium of open burning and open detonation alternative technologies. Open burning (OB) involves destroying materials through self-sustained combustion, and open detonation (OD) is detonating explosives or munitions with added explosive charges. 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. The agency has also set a goal to finalize revisions to standards for the OB/OD of waste explosives by October 2025.

Eagles are official

The bald eagle has been a symbol of the United States since it first appeared on the Great Seal way back in 1782. Fast forward to today, and it can be seen on a myriad of official documents like the president’s flag or even the one-dollar bill. But did you know it wasn’t until 2024 it became the "official" U.S. national bird?

Watch the 4-minute PBS video!

Guardrails for remediation program transfers

In response to a 1999 report from EPA’s Office of Inspector General citing hazardous waste remediation activities inappropriately deferred to CERCLA or the RCRA corrective action program, the agency has published updated guidance on improved procedures for site transfers between the two programs. [RO 14966] This new guidance, which supersedes RO 14960, describes the steps CERCLA/corrective action program managers should take to accurately identify a facility/site’s administrative program management lead, transfer status in real-time, and improve overall program management at the state, regional, and national levels. The guidance does not impact what cleanup activities are conducted or what remediation steps should be taken by affected facilities. Instead, EPA is setting guardrails for regulators to ensure remediation projects do not fall through the cracks.

Regulators, meet your deadlines

State and regional RCRA regulators should ensure the timely submittal of data into RCRAInfo, the national data system for the RCRA hazardous waste program. [RO 14967] RCRAInfo data contributes to implementing and enforcing hazardous waste regulations, tracks program measures, supports emergency responders, and assists regulatory analysis. While EPA’s Office of Resource Conservation and Recovery maintains the functionality of RCRAInfo, submitted data is only as valuable as the accuracy and promptness of what regulators submit as prescribed by RCRAInfo’s Data Element Dictionary.

Refresh on the clock

Ready to take the next step in your RCRA adventure? Join us for McCoy’s .VIRTUAL RCRA Refresher seminar on June 24-25, 2025, where we’ll cover almost all of the 5-Day seminar contents in a fast-paced, two-day event. If you can’t make it in June or prefer in-person seminars, consider joining us in Houston, November 18-19, 2025, for the public “in-person” Refresher. No matter which format you choose, you’ll enjoy the accelerated pace (it’s fast) and walk away a RCRA pro.

2-Day agenda

AI traffic gets the green light

AI-powered traffic lights, like Google’s Green Light, are being tested in cities like Boston and Seattle to predict traffic patterns and hopefully cut down on those annoying red lights. It sounds great in theory, but whether it will make a difference or just cause a new headache remains to be seen. If it works, it might be coming to your city next.

Scroll and catch the vid. It's cool!

McCoy in bloom

RCRA is complex and, let’s be honest, sometimes it feels like you’re running a race. But no worries—McCoy’s 5-Day RCRA .VIRTUAL seminar (happening May 5-9, 2025) is here to make it easier. Skip the stress and join us for five days of training. Whether you’re new to RCRA or you’ve been at it for decades, you'll leave our seminar ready to tackle what comes next. RCRA isn’t simple, but with McCoy, you’ll simply get what you need to stay in compliance.

See our complete lineup of seminars

Summer of RCRA!

Need an office break? Enjoy a change of scenery and elevate your compliance game this summer by joining McCoy’s in-person 5-Day RCRA seminar in Denver, June 9-13, 2025, or Lake Tahoe, August 18-22, 2025. While you’re at it, why not turn it into a vacation and reserve your hotel room with our discounted room rates—call us at 303-526-2674 for more information!

5-Day in-person schedule

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
.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: June 24–25, 2025
Houston: November 18–19, 2025

Visit mccoyseminars.com to register or call us at 303-526-2674.

If you have received this email in error or wish to remove your name from our subscriber list, you may unsubscribe here. You may also update your profile here. If you need to contact us directly about subscription or other issues, you may email us at mccoyreview@mccoyseminars.com or call us at 303-526-2674.

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.

Select another issue of McCoy Review...