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November 2025

Countdown to Las Vegas

Don’t miss your chance to join McCoy’s 5-Day RCRA in-person seminar in Las Vegas, being held December 8-12, 2025. Attend one or all five days fully immersed in RCRA training, and between sessions, recharge with coffee, jot a few notes in your course binder, and connect with fellow attendees. Rooms at The Orleans Hotel are still available at the rack rate, so hurry up and reserve yours soon!

Our next 5-Day RCRA in-person seminar is taking place in Virginia Beach, March 9-13, 2026. Check out the full schedule here.

Dangerous precedent proposed for not regulating HAPs

On October 1, 2025, EPA proposed amendments to the secondary lead smelting NESHAP of Part 63, Subpart X. [90 FR 47268] The agency proposes new MACT standards for total hydrocarbons and dioxins/furans, but uses a novel de minimis interpretation to avoid regulating hydrochloric acid and chlorine. Despite the D.C. Circuit Court of Appeals concluding EPA must address unregulated HAPs in MACT standards (Louisiana Environmental Action Network vs. EPA; Docket No. 17-1257; April 21, 2020), the agency states, “the law cares not for trifles.” EPA also uses a questionable interpretation of CAA Section 112(e)(2) [42 U.S.C. Section 7412(e)(2)], a section meant to prioritize the promulgation of the air toxic standards in the 1990s, to claim Congress didn’t intend for the agency to regulate low levels of HAP emissions. [90 FR 47277] Comments may be submitted through November 17, 2025 via Docket ID No. EPA-HQ-OAR-2025-0078.

Crack the CAA code

If the Clean Air Act feels like a code you can’t quite decipher, McCoy’s .VIRTUAL CAA seminar, taking place January 20-22, 2026, is your key to cracking it. Over three action-packed days, you’ll gain clarity on the various programs, understand which ones may impact your facility, and walk away with the keys to unlocking CAA compliance. Register online today, or by calling us at 303-526-2674… and don’t forget to provide a good shipping address!

Next available CAA seminar

Secondary material or waste? Recycling answers

Perhaps the most fundamental aspect of RCRA is to make an accurate hazardous waste determination. Doing so requires generators to ask themselves a few questions every time they discard a material. The first two questions can often be asked together: Is my discarded material solid waste, and is it excluded from regulation? Updated guidance from EPA can help generators answer these questions and ensure, regardless of regulatory status, that a recycled material is managed in a manner protective of human health and the environment. After all, hazardous wastes do not cease to be dangerous simply because they are recycled. READ MORE

HSWA intersects interim status

RCRA interim status occurs when a change is made to the statute or regulations that would require a facility to obtain a permit, and the facility has submitted an initial permit application but has not yet received a permit. When a rule is promulgated under the authority of the Hazardous and Solid Waste Amendments of 1984 (HSWA), it takes effect in all states simultaneously. Consequently, even if a state deadline for a facility’s interim status qualification has not passed, if that facility misses the federal deadline, it would not qualify for interim status. EPA recommends that authorized states modify their regulations to reference federal compliance dates, thereby avoiding confusion, even though states are not legally required to do so to maintain RCRA authorization. [RO 14971]

2 ways to RCRA this February

McCoy brings RCRA training straight to your screen with the February 2-6, 2026, .VIRTUAL 5-Day seminar and February 18-19, 2026, .VIRTUAL Refresher. Both are live, instructor-led sessions, delivering the same expert guidance you would receive at our in-person seminars. The 5-Day covers the material over a full week, while the Refresher moves at an accelerated pace, perfect for those already comfortable with the regs. With the latest course materials shipped right to your door, all you need is your computer and a good cup of coffee!

5-Day agenda
Refresher agenda

No Title V permit for biochar

EPA recently granted a nonhazardous secondary material (NHSM) determination on biomass processed to make biochar product. [RO 14970] Provided the equipment used to produce a biochar product is only processing clean cellulosic biomass (defined in 40 CFR §241.2), the feedstock is not considered a solid waste. Consequently, the equipment would not be subject to CAA Section 129 [42 U.S.C. Section 7429] incinerator standards nor Title V permitting. Agency guidance on the Part 241 NHSM regulations and petitioning for an NHSM determination is discussed in a previous article.

Rocking the green way!

Jack Johnson is turning the music industry green… literally. In the documentary Change Amplified: Live Music and the Climate Crisis, Jack showcases how artists can lead the way in sustainability. From plastic-free concerts to locally sourced food, the industry began calling his demands the “Jack Johnson Package,” proving that you can rock out to live music and be eco-friendly at the same time. Watch his interview here, or catch the full documentary on HBO Max.

Your guide to Cali Title 22-RCRA

California’s Title 22-RCRA regulations can be tricky to manage, but rest assured, McCoy is here to help you tackle them head-on. Join us for the .VIRTUAL California Title 22-RCRA seminar taking place, May 11-14, 2026, for four days of live training covering Title 22, the Generator Improvements Rule, the latest compliance updates, and much more. Get your questions answered, stay ahead of the regs, and leave class ready to handle California Title 22-RCRA with confidence!

Cali 4-Day agenda

Scoring green goals!

For the local soccer team, Vermont Green FC, it’s more than just a game…it’s a movement! Through tracking its net-zero operations, environmental education initiatives, and purpose-driven merchandise, the club is showing that being a “green team” is more than just a slogan. Recently featured in The New York Times, Vermont Green FC isn’t just scoring goals… they’re setting new goals for local sports teams everywhere.

2025–2026 Seminars

3-Day CAA Seminars
.VIRTUAL: January 20–22, 2026
.VIRTUAL: March 31–April 2, 2026

4-Day California Title 22-RCRA Seminars
.VIRTUAL: May 11–14, 2026

5-Day RCRA Seminars
Las Vegas: December 8–12, 2025
.VIRTUAL: February 2–6, 2026
Virginia Beach: March 9–13, 2026
Denver: June 8–12, 2026
Lake Tahoe: August 17–21, 2026

2-Day RCRA Refreshers
Houston: November 18–19, 2025
.VIRTUAL: February 18–19, 2026

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.

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