An official website of the United States government.

This is not the current EPA website. To navigate to the current EPA website, please go to This website is historical material reflecting the EPA website as it existed on January 19, 2021. This website is no longer updated and links to external websites and some internal pages may not work. More information »

Non-Delegability of Section 3004(t) of the Resource Conservation and Recovery Act (RCRA) and Authorization Status of Several "Non-Checklist" Authorities

This memorandum explains the Permits and State Programs Division (PSPD), Office of Solid Waste and the Office of the General Counsel (OGC)'s reexamination of the requirement for States to adopt and become authorized for counterparts to certain provisions in RCRA section 3004(t) - Third Party Direct Action Against Financial Responsibility Insurers or Guarantors. 

You may need a PDF reader to view some of the files on this page. See EPA’s About PDF page to learn more.