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. 

• Non-Delegability of Section RCRA 3004(t) and Authorization Status of Several "Non-Checklist" Authorities (PDF)(6 pp, 12 K)