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McCoy's RCRA Review

March 2026

Take care of our air

With sweeping regulatory changes taking place, forward-looking organizations will not abandon compliance with the CAA. And as always, state regulations can be more stringent than federal regulations. To hedge your bets and continue your professional development, consider our .VIRTUAL CAA Unraveled seminar. Attend on March 31-April 2, 2026, and you’ll gain clarity on the programs and how they interrelate. Take our bet—our online seminars are not mind-numbing dull!

Register for CAA Unraveled .V
Seminar details
Article: What happens to state regulations…

 

EPA throttles turbine rule

Environmentally, nitrogen oxides (NOX) are ozone precursors, create acid rain, and cause algal blooms due to nutrient pollution. Physiologically, NOX at low concentrations irritates mucosal tissues and causes asthma, while at higher concentrations, it can cause hypoxia, pulmonary edema, and death. EPA’s new NOX standards for stationary turbines do not reflect these health risks, and a final rule from January 2026 is significantly weaker than what was proposed at the end of 2024.   READ MORE  

 

Virtually spring!

Celebrate the change of seasons with, you guessed it, a RCRA .VIRTUAL 5-day seminar on April 20-24, 2026. With the changes taking place these days, many new people are making environmental management their career. And the pace of this seminar is far more comfortable for those less experienced with the behemoth, RCRA. Join us and you’ll gain a structured methodology for determining if your materials are hazardous wastes, how to identify characteristic and listed wastes, and much more.

Take a look at the 5-day agenda
Seminar details
Register here!

 

Full reverse on air toxics rule

Effective January 2, 2026, the 2024 CAA major to area source rule [89 FR 73293] is removed from the regulations. [91 FR 58] The rule required 30 source categories to follow a “once in, always in” approach for a major source determination, but when Congress passed a joint resolution of disapproval in July 2025, the rule ceased to have any legal effect. (See our previous article on the joint resolution and how such resolutions are used under the Congressional Review Act.) EPA’s action merely removes the regulatory language. Major sources under the air toxics program that reduce their potential to emit sufficiently may be reclassified as area sources, regardless of source category. [85 FR 73854]

 

 

 

Small shifts make a big difference

As extreme weather events are becoming both more common and intense, the industrial sector is feeling the heat. Heatwaves, droughts, wildfires, and floods are damaging physical infrastructure and disrupting utilities, leading to operational shutdowns. The challenges facing industry stem from just a small shift in daily temperatures, demonstrating how a small shift can make a big difference.

 

California Title 22 and RCRA

California hazardous waste regulations are more comprehensive than the federal program. For example, California’s hazardous waste criteria are more rigorous than federal RCRA, meaning waste that is nonhazardous federally may still be regulated as hazardous in California. So, if you conduct business inside this big and beautiful state, join us for our May 11-14, 2026 .VIRTUAL California Title 22-RCRA seminar and we’ll help clarify the regulatory paradigms.

Seminar details
Join us!

 

 

 

Vapes as household waste

A significant challenge with recycling vape pens is their disassembly into primary components—the lithium-ion battery, nicotine e-liquid, plastic housing, heating coil, and electronics are all handled separately. However, the RCRA household waste exclusion [§261.4(b)(1)] applies to the entire collection and recycling chain for these e-cigarettes when they are disposed of at home and managed at material recovery facilities. The exclusion can still be claimed even if non-recycled components are sent for disposal after disassembly. [RO 14974] Conversely, vapes disposed of at commercial and industrial facilities would be P075 hazardous waste due to the nicotine present as a sole active ingredient. [RO 14850]

 

2026 CUPA Forum in San Diego!

In the early 1990s, California’s regulation of hazardous materials and waste, as well as local emergency response, was diffused across more than 1,100 local and state agencies. This was confusing and inefficient. In 1993, a bill established the Unified Program to enable consolidation and coordination of everything from administration and permitting—to enforcement activities.

Fast forward to today and the Certified Unified Program Agency (CUPA) program has achieved a myriad of accomplishments from increased collaboration and oversight to its professional development and training for state regulators and the regulated community.

Check out the CUPA Forum held March 23-26, 2026

 

 

 

CCR compliance deadlines pushed

Effective February 9, 2026, deadline extensions are in place for facilities required to comply with the coal combustion residual (CCR) provisions in Part 257, Subpart D. [91 FR 5806] The final rule extends various administrative and substantive requirement deadlines by one to three years, going as far as February 9, 2032. These deadline extensions stem from a May 2024 final rule that strengthened the regulation of legacy CCR surface impoundments and management units. [89 FR 38950]

 

Sustainability trends for 2026

As we continue to move through 2026, companies are in search of strategies to achieve long-term sustainability and evolve their business. The challenges of sustainability trends arise as companies navigate today’s political environment to develop renewable energy to keep global warming at bay. Stakeholders will spend 2026 balancing short-term priorities with long-term sustainability realities. With the current uncertainty, here are 10 sustainability trends to watch in 2026.

 

Cleanup check-in

Goal 4 of EPA’s Hazardous Waste Cleanup Program Vision/Mission/Goals for 2030 states that by 2025, the program will identify and implement key elements of effective long-term stewardship for corrective action cleanups. With 2025 in the rear-view mirror, the agency encourages regions to share their long-term stewardship implementation practices and tools with other regions and the states. One useful tool is a site assessment checklist to establish a facility’s long-term assessment protocol, implement facility assessments, and maintain records of engineering and institutional controls. [RO 14973]

 

RCRA: FAST

We love our RCRA Refresher because we take almost all of the content from our 5-day seminar and pack it into two action-packed days. This offers significant, tangible benefits for experienced RCRA pros or for those seeking rapid skill acquisition. But “caveat emptor” the pacing is head-swimmingly fast. So, strap in, eat your Wheaties, and sign up for this super-efficient course. Questions? Feel free to reach out to us at hello@mccoyseminars.com.

June 23-24, 2026 RCRA Refresher details
RCRA Refresher agenda
F1 - The Official Home of Formula 1® Racing

 

Styrofoam recycling? Maybe

The Polystyrene Recycling Alliance (PSRA), a Washington DC-based initiative of the Plastics Industry Association, released a study examining end market and recovery for four major polystyrene (PS) resin types. As industry turns its focus toward a circular economy, tackling the toughest problems will be essential.

Per the PSRA study, roughly one-third of the U.S. population has access to a variety of consumer recycling channels, either a residential program, municipal drop-offs, or business drop-offs open to the public. While “consumer access” doesn’t mean actual recycling, it’s a start. For example, at McCoy, we recycle block Styrofoam through Ridwell, an organization working to make recycling and reuse more accessible, transparent, and impactful.

About the Polystyrene Recycling Alliance (PSRA)
PSRA study
Ridwell stats: Styrofoam recycled versus contaminated

 

2026 Seminars

3-Day CAA Seminars
.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: 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: 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 ©2026 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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