National Rural Electric Cooperative Association
EPARulemakingEPA-HQ-OLEM-2019-0172

Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; A Holistic Approach to Closure Part A: Deadline to Initiate Closure

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Last modified
Oct 19, 2022
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closed 2370d ago
National Rural Electric Cooperative Association filings
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Activity

National Rural Electric Cooperative Association filed 1 comment on this docket between Feb 5, 2020 and Feb 5, 2020. 21 other organizations filed here. The comment window closed 2370d ago.

What National Rural Electric Cooperative Association filed (1)

Feb 5, 2020· Comment submitted by Dorothy Allen Kellogg, Regulatory Director, Water and Waste Issues, National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OLEM-2019-0172-0086

NRECA appreciates EPA's efforts to provide the opportunity for extensions to the deadline due to the lack of alternative disposal capacity for both CCR and non-CCR wastes. While urging the agency to move expeditiously to finalize this and the upcoming Part B proposal, we also offer three recommendations to improve this proposed rule: 1.Do not shorten the construction timeline from October 31, 2020 but extend the deadline to January 15, 2021 as recommended and justified by the USWAG analysis and recommendation; 2.Revise the proposed extensions to better accommodate events beyond a plant's control (e.g. weather) and remove the proposed language (and related notifications) making the extensions mutually exclusive per the attached Appendix A; and 3.Finalize the CCR Part A and Part B rules concurrently and in coordination with the final ELG rule.

Abstract

This rule is in response to the vacatur of certain provisions of the 2015 CCR Rule in the August 2018 USWAG court decision and in response to the court’s remand of a specific provision in the July 2018 CCR rule, issued on March 13, 2019. This rule will establish a new date for CCR surface impoundments to cease receipt of waste and initiate closure. It is not economically significant.

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Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; A Holistic Approach to Closure Part A: Deadline to Initiate Closure (EPA) — National Rural Electric Cooperative Association | OpenPolis