National Resource Conservation and Recovery Act (RCRA) Hazardous Waste Permitting Priorities

On this page:

• What are the national RCRA permitting priorities?
• How are the priorities selected? 
• What are the current priorities?
• Which national priorities are complete?

What are the national RCRA permitting priorities?

The national RCRA permitting priorities are issues that are national in scope that affect RCRA permits and the Hazardous Waste RCRA Permitting Program implemented by EPA, states, and territories.

For each priority selected, EPA collaborates with states and territories to develop and implement an action plan. Through focused action on national priority issues, EPA upholds the integrity of the Hazardous Waste RCRA Permitting Program to ensure quality and consistency of permits and protection of human health and the environment.

How are the priorities selected?

The national RCRA permitting priorities are selected through a periodic process where the RCRA Permit Integrity Team collaborates with EPA regions and state and territorial regulatory partners to identify, prioritize, and resolve high‐level issues that impact RCRA permits or the RCRA Hazardous Waste Permitting Program nationally. New national RCRA permitting priorities are identified approximately every two years.

What are the current priorities?

Note: these priorities are being reassessed in Fiscal Year 2026. 

• Permitting Updates Rule (PUR) – develop a rulemaking to propose updates and clarifications for the treatment, storage, and disposal facilities and permitting standards in Title 40 of the Code of Federal Regulations Parts 124, 260-268, 270, 271, 273, and 279.
  • Previous priorities that were later included on the PUR are:
    • Optimize Permit Modification Process – consider ways to enable more efficient and timely processing of permit modifications.
    • Periodic Certification of Tank Systems – explore the development of a national protocol for the periodic certification of tank systems.
    • Post-Closure Care Implementation – assist states and EPA regions with post-closure care implementation.
• RCRA Model Permit – update the 1988 National RCRA Model Permit and develop an accompanying standard operating procedure for RCRA permit writers. Modules are being published as they are completed, as this is an iterative process.
• Timely Renewal Applications – explore options for earlier receipt and improved quality of permit applications for the renewal of RCRA permits. 

Which priorities are complete?

The RCRA Permit Integrity Team completed priorities are described below:

• RCRA Model Permit – EPA has published several modules in the RCRA Model Permit website to help permit writers review RCRA permit conditions for drafting RCRA hazardous waste permits. The published modules are: the Permit Cover Page, General Permit Conditions, General Facility Conditions, Preparedness and Prevention, Contingency Plan, Financial Requirements, Final Closure, Tanks, and Containers. EPA is also developing the Landfills, Groundwater Requirements, RCRA Organic Air Emissions Standards, Incineration, and Post-Closure modules. Other modules are planned and will be published incrementally. 
• RCRA Air Emissions – launched the RCRA Organic Air Emission Standards for Treatment Storage and Disposal Facilities and Generators webpage and the RCRA/Clean Air Act compliance exemption and election provisions document to improve understanding and implementation of the RCRA air emission standards. EPA also updated the RCRA Organic Air Emissions Standards Fact Sheet in December 2022.
• Permit Writer and Inspector Coordination – Starting in 2022, EPA, in collaboration with the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), have held recurrent national RCRA permit writer and inspector workshops for regulatory authorities to foster collaboration, assist compliance, and protect human health and the environment. We will continue to hold these workshops regularly.
• Tools for Expediting Permit Issuance – EPA developed a RCRA permit application checklist for states to customize for their specific permitting programs and share with applicants. EPA made a generic version of the checklist publicly available (xls)(1.36 MB).
• CostPro –EPA updated and incorporated CostPro into RCRAInfo, EPA's comprehensive information system for the RCRA program. CostPro is EPA software for estimating closure and post-closure care costs at RCRA hazardous waste treatment, storage, and disposal facilities. CostPro now provides states and EPA regions a consistent, accurate and rapid method of evaluating cost estimates for closure and post-closure care helping to expedite permitting and protect the taxpayer from these cleanup costs.
• Public Notice in Newspaper and Mail – EPA published a Federal Register notice in December 2021 that requested comment on allowing modern electronic alternatives for public notification and other notifications under RCRA. EPA also updated the RCRA Public Participation Toolkit to indicate the acceptability of using email for mailing lists, online newspapers for public notification, and virtual hearings and meetings for public participation. EPA encourages the most effective methods for public notices depending on the characteristics of the community, while ensuring the minimum regulatory requirements are met.
• Waste Analysis Plans Compliant with Land Disposal Restrictions – EPA developed the information bulletin: “Ensuring and Determining Compliance with Land Disposal Restrictions Through RCRA Permits, Waste Analysis Plans and Inspection Sampling Practices”(pdf)( 691 KB) in April 2022 to make RCRA permit writers, inspectors, and the regulated community aware of controls, conditions and sampling practices to ensure and determine compliance with RCRA land disposal restrictions.