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July 17, 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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On July 17, 2025, EPA Administrator Lee Zeldin signed a direct final rule and companion proposal to extend the compliance deadlines for the coal combustion residual management units (CCRMU) requirements. With this rule, EPA is creating an option to allow the two parts of the Facility Evaluation Report to be prepared concurrently so long as both reports are submitted no later than February 8, 2027. Additionally, EPA is extending the deadline for owners or operators of CCRMU to comply with the groundwater monitoring provisions to no later than August 8, 2029. Since the Facility Evaluation Report and groundwater monitoring requirements serve as prerequisites for other CCRMU requirements, with this rule, EPA is also making conforming changes to the remaining CCRMU compliance deadlines.
These extensions are in response to feedback from members of the regulated community about challenges that are impacting their ability to comply with specific CCRMU compliance deadlines. Find out more on our website.
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Concerns over “Free Liquids Memorandum” and the Coal Combustion Residuals (CCR) Regulations
On July 17, 2025, EPA Headquarters issued a memo to EPA’s Regional Land, Chemical, and Redevelopment Division Directors to address questions received from the regulated community about a document in the docket for the final Legacy CCR Surface Impoundments and CCR Management Units Final Rule titled:
“Memorandum: Considerations for the Identification and Elimination of Free Liquids in Coal Combustion Residuals (CCR) Surface Impoundments and Landfills (Title 40 of the Code of Federal Regulations Part 257, Subpart D) April 19, 2024” (“Free Liquids Memorandum”).
The memo clarifies that the Free Liquids Memorandum does not impose legally binding requirements on EPA, states, or the regulated community. States and regulated entities are not required to adopt any of the methods, recommendations, or statements contained in the Free Liquids Memorandum and EPA personnel will no longer rely on or use the Free Liquids Memorandum to carry out the agency’s work to implement the CCR program.
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EPA Posts Official Response Document to the Hazardous Waste Electronic Manifest Advisory Board’s
EPA convened the e-Manifest Advisory Board for a virtual public meeting from September 17 to 19, 2024. The purpose of the meeting was for EPA to seek the Board’s consultation and recommendations regarding the e-Manifest system. The meeting theme was Meeting the Needs of the User Community: e-Manifest Program Priorities and User Fees for FY 2026 and 2027.
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The fees for the upcoming fee cycle are as follows:
Any manifest that originates (signed by the generator) on or after October 1, 2025, will be charged the fiscal years 2026 and 2027 user fee rate when submitted to the e-Manifest system by the receiving facility. Receiving facilities will see their first invoices reflecting the new rates starting in November 2025.
The FY 2026/2027 fees are part of a phased approach to sunset paper manifests. Critically, the Agency is implementing a deliberate discount for data plus image uploads to empower companies to invest in electronic manifesting infrastructure, creating a bridge for users to modernize systems incrementally while transitioning away from paper.
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