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EPARulemakingEPA-HQ-OLEM-2020-0107

Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy Surface Impoundments

RIN
2050-AH14
Last modified
Jul 2, 2026
Comment window
closed 29d ago
National Rural Electric Cooperative Association filings
7

Activity

National Rural Electric Cooperative Association filed 7 comments on this docket between Feb 18, 2021 and Jun 30, 2026. 64 other organizations filed here. The comment window closed 29d ago.

What National Rural Electric Cooperative Association filed (7)

Sep 18, 2025· Comment submitted by National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OLEM-2020-0107-1145

Filed on regulations.gov — full text not in the inline record.

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Dec 15, 2023· Comment submitted by National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OLEM-2020-0107-0950

Attached are the comments of the National Rural Electric Cooperative Association in response to the NODA.

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Nov 16, 2023· Comment submitted by National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OLEM-2020-0107-0897

Attached please find a request to extend the comment period for the Notice of Data Availability by 30 days.

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Jul 19, 2023· Comment submitted by National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OLEM-2020-0107-0244

Comments of the National Rural Electric Cooperative Association (NRECA) are attached.

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Jun 5, 2023· Comment submitted by National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OLEM-2020-0107-0170

Request to extend the comment period by 60 days is attached.

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Feb 18, 2021· Comment submitted by Dorothy Allen Kellogg, Regulatory Director, Water and Waste Issues, National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OLEM-2020-0107-0065

NRECA supports EPA's effort to solicit comments on how to approach legacy CCR impoundments and to build a solid, technical record to support future rulemaking. NRECA urges that future legacy impoundment regulations apply to units at inactive utility sites where impoundments contain both CCR and liquid on the effective date of a new legacy impoundment rule. NRECA strongly urges the Agency to develop a site-specific, risk-based approach to legacy impoundments consistent with authority provided by the WIIN Act and the approach promulgated in the recent CCR Closure rules. Finally, NRECA also supports the Agency's suggestion that only a subset of the 2015 CCR requirements may be appropriate for legacy impoundments, specifically those associated with closure/post-closure care, groundwater monitoring, and recordkeeping.

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Abstract

On April 17, 2015, the Environmental Protection Agency (EPA or the Agency) promulgated national minimum criteria for existing and new coal combustion residuals (CCR) landfills and existing and new CCR surface impoundments. On August 21, 2018 the D.C. Circuit Court of Appeals issued its opinion in the case of Utility Solid Waste Activities Group, et al v. EPA, which vacated and remanded the provision that exempted inactive impoundments at inactive facilities from the CCR rule. As a first step to implement this part of the court decision, EPA is seeking comments and data on inactive CCR surface impoundments at inactive utilities “legacy units” to assist in the development of future regulations for these CCR units.

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Co-filers (64)

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