Coal Combustion Residuals State Permit Programs (RCRA)

Current understanding

Under the 2016 WIIN Act amendments to RCRA, states may develop Coal Combustion Residuals (CCR) permit programs that operate in lieu of the federal CCR rule if EPA determines they are at least as protective. Approved state programs give utilities and disposal facilities a single permitting authority for coal ash surface impoundments and landfills, affecting closure timelines, groundwater monitoring compliance, and enforcement pathways. Approvals may be partial (covering only some CCR units or requirements) with the federal program continuing to apply to the remainder.

Evidence log

• 2026-07-14 — Alabama: Approval of State Coal Combustion Residuals Permit Program: cross-connection with coal-combustion-residuals-permit-program: Alabama’s proposed partial approval is one instance within EPA’s broader framework for approving state CCR permit programs under RCRA. (novelty: 2)
• 2026-05-18 — Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category-Unmanaged Combustion Residual Leachate: cross-connection with steam-electric-effluent-guidelines: Both regulate coal combustion residual waste streams from power plants — ELGs govern wastewater/leachate discharges under the Clean Water Act, while CCR state permit programs govern land-disposal of the same residuals under RCRA. (novelty: 2)
• 2026-05-28 — Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals From Electric Utilities; Federal CCR Permit Program; Reopening of Comment Period: 2026 — EPA reopened the public comment period on its 2020 proposed federal CCR permit program, which would operate in Indian country and in states without EPA-approved state CCR permit programs; reopening signals continued agency work on the federal backstop but no substantive changes yet. (novelty: 2)

Open questions

Related