NWP 38Effective 2026-03-15

Cleanup of Hazardous and Toxic Waste

Requirements at a Glance

  • Pre-Construction Notification (PCN) is required for all activities
  • Authorized under Section 10 and Section 404
  • Must be performed, ordered, or sponsored by a government agency
  • Pre-Construction Notification (PCN) is mandatory for all activities
  • Does not authorize new or expanded hazardous waste disposal sites
  • Temporary fills must be removed and the site restored to pre-construction elevations
  • Must comply with General Condition 18 regarding endangered species
  • Remedial plan must be included in the PCN submittal

Purpose & Scope

Nationwide Permit 38 authorizes specific activities required to contain, stabilize, or remove hazardous or toxic waste materials. This permit is used for remediation projects performed, ordered, or sponsored by a government agency with established legal or regulatory authority. It also covers court-ordered remedial action plans or related legal settlements. The scope includes both work in navigable waters under Section 10 and the discharge of fill material under Section 404. However, it specifically prohibits the establishment of new disposal sites or the expansion of existing sites used for hazardous waste disposal. The permit is designed to facilitate the cleanup of contaminated sites while ensuring the methods used for remediation do not themselves cause significant environmental harm.

What Changed in 2026

The 2026 reissuance of NWP 38 contains no substantive changes to its national terms or conditions compared to the 2021 version. The Corps reevaluated the permit's individual and cumulative effects and determined that the existing requirement for a mandatory pre-construction notification (PCN) for all projects remains a sufficient safeguard for protecting the aquatic environment. While the regulatory requirements remain identical, the supporting decision document was updated with current environmental baseline data. This includes results from recent national assessments, such as the 2022 National Lakes Assessment and the 2021 National Wetland Condition Assessment, to ensure the impact analysis is grounded in the most current available ecological data.

Who Needs This Permit?

Compliance managers, environmental remediation contractors, and government agencies (EPA, state environmental departments) use this permit. it is essential for projects involving the cleanup of Brownfields, Superfund sites, or other areas where hazardous materials must be contained or removed from jurisdictional waters.

Common Project Types

  • Dredging and removal of contaminated sediments from a riverbed
  • Installation of an underwater cap to contain toxic waste
  • Construction of temporary cofferdams for soil remediation work
  • Placement of fill for access roads to reach a contaminated wetland site
  • Stabilization of a contaminated shoreline to prevent erosion into a waterway
  • Remedial actions performed under a court-ordered settlement

Environmental Review

The Corps determined that reissuing NWP 38 has 'no effect' on federally-listed endangered or threatened species or their critical habitat. This finding is anchored by General Condition 18, which requires project-specific Section 7 consultation if an activity 'might affect' listed resources; no activity is authorized until the consultation process is complete. Compliance with Section 106 of the National Historic Preservation Act is ensured through General Condition 20. Because every project under NWP 38 requires a PCN, district engineers are able to review each remediation plan for potential impacts to historic properties. For Essential Fish Habitat (EFH), district engineers can apply regional conditions to ensure that cleanup activities do not cause more than minimal adverse effects on sensitive aquatic life.

Frequently Asked Questions

Do I need to submit a PCN for hazardous waste cleanup under NWP 38?

Can I use NWP 38 to expand a hazardous waste landfill?

Is there a specific acreage limit for NWP 38?

Does this permit cover cleanup ordered by a court?

What happens to temporary fills used during the cleanup?

Stay current on NWP 38 updates

Get notified when regulations change — no spam, just updates that matter.