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January 16, 2025
This e-newsletter delivers announcements from EPA's Office of Resource Conservation and Recovery on rulemakings, guidance documents, reports, research, upcoming webinars, and more.
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EPA Revamps the Hazardous Waste Cleanup Program Web Content
On January 6, 2025, EPA updated the Hazardous Waste Cleanup Program webpages. This update includes:
- A new, user-friendly landing page for all corrective action program topics and initiatives.
- A new searchable, sortable table of corrective action guidance, regulations, rulemakings, and resources.
- A new training webpage.
- A refresh of our Hazardous Waste Cleanup Program content.
Check out the new and updated webpages.
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EPA Posts Guidance for Schools and Small Businesses on How to Safely Dispose of Electronic Cigarettes
On January 8, 2025, EPA posted a new webpage to help schools and small businesses safely dispose of e-cigarettes. E-cigarettes contain lithium batteries and nicotine, making them hazardous waste under the Resource Conservation and Recovery Act (RCRA).
Schools and Businesses can safely dispose of e-cigarettes and components by following these three steps:
1: Safely store collected e-cigarettes before disposal.
2: Determine their RCRA hazardous waste generator category.
3: Determine their disposal options.
EPA’s new webpage provides more about each of these steps and includes photos, links, and help counting how much hazardous waste schools and small businesses may have from e-cigarettes.
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EPA Adds New Management Method Codes for use on e-Manifest and the Biennial Report
On January 1, 2025, EPA added new Management Method Codes related to the temporary storage of hazardous waste to improve data precision and quality, and in response to many data entry questions from the recent Biennial Report Cycle. These codes begin with an “S” and indicate how waste will be managed after storage and transfer. They are intended to replace the code H141 for Storage and Transfer.
EPA is only adding new codes. We are not changing any existing codes. Please be aware that on January 1, 2027, we will remove the code H141 for Storage and Transfer from both e-Manifest and the Biennial Report. Check out the new codes below:
Management Method Codes added on January 1, 2025
Code
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Description
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S010
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STORED AND TRANSFERRED FOR METALS RECOVERY
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S011
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STORED AND TRANSFERRED FOR MERCURY RECOVERY
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S015
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STORED AND TRANSFERRED FOR DEPLOYMENT/DEACTIVIATION OF AIRBAG WASTE
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S020
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STORED AND TRANSFERRED FOR SOLVENTS RECOVERY
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S039
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STORED AND TRANSFERRED FOR OTHER RECOVERY OR RECLAMATION FOR REUSE
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S040
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STORED AND TRANSFERRED FOR INCINERATION
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S041
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STORED AND TRANSFERRED FOR OPEN BURNING/OPEN DETONATION
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S042
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STORED AND TRANSFERRED FOR THERMAL DESORPTION
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S070
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STORED AND TRANSFERRED FOR CHEMICAL TREATMENT
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S081
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STORED AND TRANSFERRED FOR BIOLOGICAL TREATMENT
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S090
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STORED AND TRANSFERRED FOR POLYMERIZATION
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S100
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STORED AND TRANSFERRED FOR PHYSICAL TREATMENT ONLY
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S110
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STORED AND TRANSFERRED FOR STABILIZATION
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S113
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STORED AND TRANSFERRED FOR STABILIZATION TO REMOVE HW CHARACTERISTICS OR TO ACHIEVE DELISTING LEVELS
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S120
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STORED AND TRANSFERRED FOR COMB. OF CHEMICAL, BIOLOGICAL, AND/OR PHYSICAL TRT
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S121
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STORED AND TRANSFERRED FOR NEUTRALIZATION ONLY
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S122
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STORED AND TRANSFERRED FOR EVAPORATION
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S129
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STORED AND TRANSFERRED FOR OTHER TREATMENT
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S130
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STORED AND TRANSFERRED FOR SURFACE IMPOUNDMENT THAT WILL BE CLOSED AS LANDFILL
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S131
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STORED AND TRANSFERRED FOR LAND TREATMENT OR APPLICATION
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S132
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STORED AND TRANSFERRED FOR LANDFILL (WITH PRIOR TREATMENT AND/OR STABILIZATION)
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S134
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STORED AND TRANSFERRED FOR DEEPWELL OR UNDERGROUND INJECTION
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These codes correspond with how the receiving facility will ultimately manage the waste. For example, when a handler sends waste to storage for later metals recovery, they should use the Management Method Code S010 for Stored and Transferred for Metals Recovery on the manifest and Biennial Report Generation and Management (GM) form. The final receiving facility will still use the Management Method Code H010 for metals recovery.
Again, in place of H141, handlers will need to use the appropriate new “S” code to indicate that they received the waste to be stored or transferred and will later be managing it using a specific management method. This change will provide clarity to generators and regulators as to how facilities will handle the waste and help generators when filing their Biennial Report GM forms.
EPA will be making the “S” Codes available in e-Manifest in January 2025 and handlers can use them in the 2025 Biennial Report, as well as the 2026 Annual Report in certain states. Handlers may use the code H141 until January 1, 2027, but EPA recommends handlers start incorporating these changes in advance of that deadline.
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EPA Publishes Second Technical Corrections to the Legacy Coal Combustion Residuals Surface Impoundments Rule
On January 16, 2025, EPA published a second direct final rule and companion proposed rule to clarify and correct typographical errors, inconsistencies, and other minor errors in the May 2024 Legacy CCR Surface Impoundments final rule. The changes reflected in the direct final rule and companion proposal include:
- Fixing incorrect regulatory text citations and cross-references.
- Clarifying and adding provisions in the regulatory text to match what is clearly described in the preamble of the May 8 rule.
- Clarifying definitions for consistency and to improve implementation.
- Improving rule implementation by adding a new section consolidating compliance deadlines for CCRMU.
This action is a direct final rule that will go into effect on May 16, 2025 unless EPA receives adverse comments by March 17, 2025. If necessary, and before the effective date, EPA will withdraw provisions that receive adverse comments. EPA is not reopening or requesting comment on any other aspect of the Legacy CCR Surface Impoundments final rule or the CCR regulations.
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 On January 3, 2025, EPA updated the "Compendium of Potential Alternative Technologies to Open Burning and Open Detonation of Hazardous Waste Explosives." This compendium identifies alternative treatment technologies that potentially can be used in place of open burning and open detonation of certain hazardous waste explosives and represents currently available information.
This update adds explosive waste streams for a previously listed technology, adds a new table specific to mobile treatment unit manufacturers and vendors, and improves clarity through removal of incomplete information and revised descriptions.
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EPA Announces Virtual Working Session on Best Practices and Labeling Large-Format Batteries to Increase Recycling
Please join EPA for two webinars this spring to gather input from interested parties on best practices for collecting large-format batteries to increase recycling, as well as labeling these batteries to improve collection and recycling. For purposes of these discussions, large format batteries are rechargeable batteries over 25 pounds or more than 2000 watt-hours and often used in electric, hybrid, and internal combustion engine vehicles; other motive equipment; and stationary energy storage systems.
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February 11, 2025: Current Standards and Practices for Collecting Large Format Batteries for Recycling - This working session will provide an overview of the current policy landscape, attitudes, and trends around large format battery recycling. EPA will share applicable findings from the small- and mid-format working sessions, and speakers will share their perspectives and lessons learned on managing large format batteries. Participants will also discuss key questions and challenges. EPA welcomes the following entities to attend:
- State, Tribal, and local government agencies.
- Automobile manufacturers or trade associations.
- Stationary storage system operators.
- Standards and safety organizations.
- Battery and automotive salvage and shredding operations.
- Battery recyclers and refurbishers.
- All others involved in the large format battery life cycle.
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April 24, 2025: Expanding End of Life Management for Large Format Batteries–Recycling and Refurbishing - This working session will focus on both recycling and refurbishing large format batteries. Speakers will discuss recycling capacity, recycler’s needs, safety concerns, and other market issues. On the refurbishment side, speakers will explore the current state of the market along with associated challenges and safety practices. EPA encourages anyone involved in the end-of-life management or decommissioning of large format batteries to join these conversations including:
- State, Tribal, and local government agencies.
- Large format battery manufacturers and users.
- Standards and safety organizations.
- Others involved in the large format battery life cycle.
- Learn more about this effort
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EPA Releases Reports to Congress on Recycling Infrastructure Assessment and Survey of State Data Collection
In December 2024, EPA posted two new Reports to Congress. One is an assessment of the nation’s current recycling infrastructure stock and gaps, and the other is a report containing the results of EPA’s recent survey of states on residential recycling.
In 2021, Congress directed the EPA to collect data on residential recycling and estimate the financial investments needed to modernize the U.S. recycling system. In its report, “An Assessment of the U.S. Recycling System: Financial Estimates to Modernize Material Recovery Infrastructure,” EPA estimates that an investment of $36.5 to $43.4 billion is needed to improve curbside collection, drop-off, and processing infrastructure across the U.S. by 2030. This estimate includes material recovery facilities, packaging material-specific recycling facilities, composting, anaerobic digestion, and livestock infrastructure. Key investments must be made in all aspects of the national recycling system – generation, collection, sorting, processing, and end markets – along with education and policies that disincentivize landfilling materials.
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EPA’s second Report to Congress, the “Recycling Needs Survey and Assessment,” presents the results of a survey which found approximately 50% of states and territories collect data on the number of community curbside recycling programs, and that 80% percent of states and territories do not have deposit programs. The survey also found that approximately 50% of states and territories measure an overall recycling rate, with an average recycling rate of about 30%.
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On January 16, 2025, EPA announced a decision on the alternate liner demonstration application Coronado Generating Station in St. Johns, Apache County, Arizona, submitted for agency review. The decision advances EPA’s commitment to protect groundwater from coal ash contamination. EPA denied the application because Coronado Generating Station failed to demonstrate that their surface impoundment complies with applicable requirements of the CCR regulations.
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