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McCoy's RCRA Review

December 2025

Season’s greetings from McCoy

The holidays are here, and what a year it’s been. We thank you for your business and the great relationship we have with you. Thank you for letting us be part of your RCRA journey—it’s what we love to do.

Our office is taking a holiday break from December 24, 2025, until January 5, 2026. While we’re away, you can still reach us at hello@mccoyseminars.com or at mccoyseminars.com. Here's to a festive holiday season and a great start to 2026!

 

EPA revokes NSR reactivation policy

Much of the new source review (NSR) program is administered through policy, and most states have their own authorized NSR permitting programs. In September 2025, EPA rescinded its longstanding “reactivation policy,” which had been used to subject sources to NSR permitting that might otherwise be exempt. Now, sources that have been idled but will restart their operations and don’t conduct modifications will not be pulled into NSR. The agency acknowledges that state, local, and tribal authorities may continue to enforce the older, more stringent policy.   READ MORE  

 

 

 

PFAS proposal cuts TSCA reporting

EPA aims to loosen the rules on per- and polyfluoroalkyl substances (PFAS) reporting. First finalized in 2023, the agency is proposing to add exemptions to the TSCA PFAS reporting provisions to reduce the administrative burden on PFAS manufacturers and importers. The understanding is that, since the submitted data would be retrospective, and facilities are unlikely to have that data for other compliance purposes, what would be submitted would be incomplete and of little use. The agency is also seeking to extend the reporting deadline beyond the currently scheduled April 13, 2026.   READ MORE  

 

Emissions into art

Air-Ink is the world’s first and only ink made from upcycled carbon emissions. By capturing soot from engines and other industrial sources, the company creates inks for pens, markers, and printers used by artists and designers around the world. Over the years, it’s become a great way to repurpose emissions while supporting creative work. You can check out their story and products for yourself here.

 

 

 

Cali RCRA mix

Does working with California Title 22 and Federal RCRA ever feel like mixing oil and water? If it does… we can be the emulsifier. Sign up for McCoy’s .VIRTUAL California Title 22-RCRA seminar, May 11-14, 2026, and learn how to blend both sets of regs without the headache. Over the course, we’ll cover Cali’s unique regs, the Generator Improvements Rule, compliance updates, and so much more… all delivered live and right to your screen!

4-Day Cali agenda

 

Virginia Beach awaits

Join us on the Virginia shoreline for our next 5-Day RCRA in-person seminar taking place at the Hilton Virginia Beach Oceanfront hotel, March 9-13, 2026. Stay up to date on the latest regulatory updates, connect with other professionals in the industry, and enjoy the beautiful ocean views between sessions. Rooms are available for $149 per night until February 20, 2026.

Virginia Beach agenda
McCoy’s next in-person RCRA seminar is Denver!

 

EPA eyes NSR’s “begin actual construction”

EPA recently reaffirmed its interpretation of the new source review (NSR) program’s definition of “begin actual construction.” Supporting its 2020 draft guidance on “begin actual construction,” the agency states the regulations prohibit “the initiation of physical on-site construction on an emission unit,” and not the “initiation of physical on-site construction of those parts of a facility that do not qualify as an emission unit.” EPA is working on an early 2026 proposal to amend the definition of “begin actual construction” in §52.21(b)(11) to provide greater flexibility for source owners and operators.

 

 

 

RCRA training your way

Pick your pace this February with a McCoy .VIRTUAL RCRA seminar! The .VIRTUAL 5-Day RCRA seminar, February 2-6, 2026, guides you through the material in a detailed, step-by-step format at a thoughtful pace. Our .VIRTUAL RCRA Refresher, February 18-19, 2026, packs almost all of our content from the 5-day seminar into two accelerated days! It is fast-paced!

Regardless of which seminar you choose, all attendees receive the new 2026 editions of McCoy’s RCRA Reference and Unraveled publications, plus a course binder with the latest notes shipped directly to their door before class begins.

5-Day agenda
2-Day Refresher agenda

 

Your greenest year yet

Skip the usual New Year’s resolutions this year and add a few for the planet. Small and realistic changes like buying sustainable products, washing laundry in cold water, or weatherizing your home can make all the difference. For inspiration, check out Fairfax County, Virginia’s Office of Environmental and Energy Coordination 2025 resolutions, which are still green a year later.

 

 

 

CAA GPS

Lost in the Clean Air Act? Join our .VIRTUAL Clean Air Act seminar taking place January 20-22, 2026, and let us be your CAA GPS! During training, we’ll guide you turn by turn through the regulations, helping you avoid tedious detours and time-consuming dead ends. And after class is over, you’ll have the directions you need to navigate the CAA with confidence.

3-Day CAA agenda
Next .VIRTUAL CAA in March

 

Haz waste combustors facing NESHAP changes

Impacting facilities such as hazardous waste incinerators, cement kilns, and industrial boilers, EPA proposed its residual risk and technology review of the hazardous waste combustor NESHAP on November 10, 2025. [90 FR 50814] The proposed amendments would add emission limits and work practice standards for hydrogen fluoride and hydrogen cyanide, add electronic reporting requirements, and allow states to exclude affected area sources from Title V permitting. The agency is also seeking additional information to improve its risk assessments and other analyses. A redline strikeout of the proposed amendments is available, and EPA intends to have a final rule signed by December 31, 2025, to comply with a court-ordered deadline. [Blue Ridge Environmental Defense League vs. Regan, U.S. Court of Appeals, D.C. Circuit; Case No. 22-cv-3134; December 12, 2024] Comments may be submitted through December 26, 2025 via Docket ID No. EPA-HQ-OAR-2004-0022.

 

2026 Seminars

3-Day CAA Seminars
.VIRTUAL: January 20–22, 2026
.VIRTUAL: March 31–April 2, 2026
.VIRTUAL: August 4–6, 2026
.VIRTUAL: November 3–5, 2026

4-Day California Title 22-RCRA Seminars
.VIRTUAL: May 11–14, 2026
.VIRTUAL: September 28–October 1, 2026

5-Day RCRA Seminars
.VIRTUAL: February 2–6, 2026
Virginia Beach: March 9–13, 2026
.VIRTUAL: April 20–24, 2026
Denver: June 8–12, 2026
.VIRTUAL: July 20–24, 2026
Lake Tahoe: August 17–21, 2026
.VIRTUAL: September 14–18, 2026
Las Vegas: October 19–23, 2026
.VIRTUAL: December 7–11, 2026

2-Day RCRA Refreshers
.VIRTUAL: February 18–19, 2026
.VIRTUAL: June 23–24, 2026
Houston: November 17–18, 2026

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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