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McCoy's RCRA Review

September 2025

EPA goofs on GHGs

EPA proposed to recind its 2009 greenhouse gas (GHG) endangerment finding on August 1, 2025. Accompanying the proposal is the removal of GHG emission standards for motor vehicles and engines. The rationale for the recission makes novel legal claims unsupported by the CAA and legal history to support policy objectives. If finalized, the recission will certainly face substantial legal challenges in court.   READ MORE  

 

Keeping up with CAA

Keeping up with the Clean Air Act is nothing short of a challenge… but McCoy’s .VIRTUAL CAA seminar taking place October 21-23, 2025, makes it simple. During training, we’ll walk you through the essentials, highlight the latest regulatory updates, and address any questions regarding the recent congressional changes. Keep up with CAA the McCoy way!

CAA agenda
Upcoming CAA seminars

 

Phasing out paper manifests?!

That’s right. More than seven years after launching the e-manifest system, EPA is considering phasing out paper manifests. A virtual public meeting will be held September 23-25, 2025, where stakeholders can weigh in on this monumental development. [90 FR 38146] Those seeking to participate in the meeting or just seeking a heads up will want to familiarize themselves with the agency’s white paper and charge questions, available at Docket ID No. EPA-HQ-OLEM-2025-0391.

 

Unravel Cali T 22-RCRA

Who’s ready for McCoy’s .VIRTUAL California Title 22-RCRA seminar, October 6-9, 2025! Delivered by McCoy presenters live on Zoom, get the chance to ask questions in real time as they cover the California Health and Safety Code, Title 22 rules, the Generator Improvements Rule, and the latest in federal vs. state updates. And last but not least, every attendee will receive a course materials package including the latest McCoy course binder, and 2025 RCRA Unraveled and Reference publications, making it feel just like an in-person seminar… lock in your spot today!

McCoy’s California white paper
4-Day schedule

 

 

 

EPA withdraws NSR proposal

In July 2025, EPA withdrew its new source review (NSR) project emissions accounting proposal. [90 FR 34206] Proposed in May 2024 and discussed in a previous article, the rule would have modified the definition of “project,” strengthened administrative requirements, and required step 1 emission decreases to be legally and practicably enforceable. [89 FR 36870] The agency stated there is insufficient justification for the rule, and the proposed revisions could have resulted in “unnecessary additional burden on regulated entities and implementing agencies.” While the most recent NSR project emissions accounting action is the 2020 rule, which allows step 1 emission decreases, air agencies are not required to modify their state implementation plans to account for this rule. [85 FR 74890]

 

SoyFoam

Introducing SoyFoamâ„¢—a safer, PFAS-free alternative to traditional firefighting foam, and it’s made from something you would never expect… soybeans! Already being tested by local fire departments, SoyFoam is also the first and only firefighting foam that’s GreenScreen Certified® at the Gold level. Check out the SoyFoam performance test here.

 

 

 

 

 

Get ahead of cleanup costs

Hazardous waste cleanup and remediation activities can be incredibly costly and time-consuming. We are aware of one facility subject to corrective action that has spent more than $500 million over the last four decades on remediation. Get things right the first time by reviewing EPA’s newly reorganized resources on hazardous waste cleanup efforts.   READ MORE  

 

Your RCRA knowledge

Keep your RCRA skills healthy with regular care and attention by signing up for McCoy’s November 3-7, 2025, .VIRTUAL RCRA seminar. Over the week, shine light on regulatory confusion, cultivate a better understanding, and grow your skills. Your RCRA knowledge will be thriving in no time! And if you can’t make the November’s dates, we’ve got plenty to choose from.

McCoy’s full schedule

 

 

 

Disaster debris exemption for CISWIs

On August 26, 2025, EPA promulgated an interim final rule exempting the temporary burning of disaster debris in commercial and industrial solid waste incinerators (CISWIs) from applicable CAA Section 129 provisions. [90 FR 41508] EPA finds that during emergencies, quickly removing disaster-generated debris is important to maintaining public health and regulations hinder recovery. CISWIs will therefore be allowed to combust nonhazardous debris in an area declared a state of emergency, but will not be allowed to burn waste from normal operations during the disaster recovery period. Notification is required if the exemption is claimed for longer than eight weeks. Affected regulations include Part 60, Subparts CCCC and DDDD and Part 62, Subpart IIIa. Comments may be submitted through October 10, 2025 via Docket ID No. EPA-HQ-OAR-2003-0119.

 

Updated guide combats illegal dumping

Illegal dumping remains a significant challenge for many U.S. communities, threatening public health, safety, and the environment. EPA recently updated its Illegal Dumping Prevention Guide to offer tailored strategies that address the root causes of this problem. These strategies include improving access to affordable waste disposal, enhancing community education and outreach, and strengthening enforcement through local leadership and coordinated efforts. The guide features real-world case studies and tools to implement effective prevention programs.   READ MORE  

 

Refreshing Houston!

Join us in Houston, Texas, November 18-19, 2025, for McCoy’s 2-Day Refresher at the South Shore Harbour Resort. Reserve your room with the special McCoy rate of $140 per night while availability lasts. At the refresher, you’ll brush up on the regs, dive into the latest compliance updates, and get your questions answered by McCoy expert instructors. And if you end up with a little free time, be sure to swing by the Houston Zoo to say hello to their newest addition, the baby Baird’s tapir!

Refresher agenda
Houston registration page

 

McCoy training, Vegas style

This December 8-12, 2025, attend McCoy’s 5-Day RCRA seminar being held in the fabulous city of Las Vegas! Join us for one or all five days of in-person training at The Orleans Hotel, where we’ve reserved a limited block of rooms for just $45 per night. While you’re in town, be sure to catch an unforgettable show like Michael Jackson ONE by Cirque Du Soleil or the Wizard of Oz experience at the Sphere. It’s the perfect opportunity to strengthen your RCRA skills while enjoying some well-deserved Vegas fun!

Vegas registration page

 

A watery journey 

Dan Rubinstein spent the summer of 2023 on a truly one-of-a-kind adventure. Over the course of 11 weeks, he paddled 1,200 miles from Ottawa to New York City, navigating rivers, lakes, and waterways on… believe it or not… an inflatable paddleboard! He tells the full story of his journey in his book, Water Borne: A 1,200-Mile Paddleboarding Pilgrimage.

 

2025–2026 Seminars

3-Day CAA Seminars
.VIRTUAL: October 21–23, 2025
.VIRTUAL: January 20–22, 2026
.VIRTUAL: March 31–April 2, 2026

4-Day California Title 22-RCRA Seminars
.VIRTUAL: October 6–9, 2025
.VIRTUAL: May 11–14, 2026

5-Day RCRA Seminars
.VIRTUAL: November 3–7, 2025
Las Vegas: December 8–12, 2025
.VIRTUAL: February 2–6, 2026
Virginia Beach: March 9–13, 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.

 



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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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