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EPARulemakingEPA-HQ-OLEM-2019-0173

Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Alternative Demonstration for Unlined Surface Impoundments & Request for Comment on Legacy Units; Response to DC Circuit Court Decisions Part B

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Jun 13, 2024
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closed 2293d ago
National Rural Electric Cooperative Association filings
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Activity

National Rural Electric Cooperative Association filed 1 comment on this docket between Apr 22, 2020 and Apr 22, 2020. 21 other organizations filed here. The comment window closed 2293d ago.

What National Rural Electric Cooperative Association filed (1)

Apr 22, 2020· Comment submitted by Dorothy Allen Kellogg, Regulatory Director, Water and Waste Issues, National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OLEM-2019-0173-0096

NRECA appreciates and supports EPA's proposal to provide an opportunity for plants to demonstrate that an alternative liner design can be as protective as the design prescribed in the current CCR rules, and we encourage the agency to adopt the recommendations we and USWAG have offered to improve the proposal. We also support with improvements the agency's proposals regarding the use of CCR to close units and to decouple unit closure from groundwater remediation. We urge EPA to finalize this proposal - or at least the alternative liner demonstration program - concurrently with the previous CCR Part A proposal. Plants expecting to make an alternative liner demonstration need to know what will be required, when it will be required, and that there will be sufficient time to make the demonstration prior to forced closure.

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Abstract

This rule is in response to the vacatur of certain provisions of the 2015 CCR Rule in the August 2018 USWAG court decision.

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Co-filers (21)

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