Jul 2, 2019· Comment submitted by Dorothy Allen Kellogg, Director, Water & Waste Regulatory Issues, National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OPPT-2018-0321-0105
NRECA supports EPAs goal in revising the TSCA Sec 8 CDR rule, but believes EPA can do more to reduce the regulatory burden associated with TSCA Chemical Data Reporting with no loss of information or value by: 1.Incorporating the SBA size standard of 750 employees as the definition of small manufacturer for NAICS 221112, fossil fuel electric power generation; or 2.Defining total sales for NAICS 221112 as only including sale of electricity from coal-fired generation; and 3.Finalizing the proposal to exempt byproducts from non-integral processes such as synthetic gypsum produced from flue gas desulfurization (FGD) air pollution control systems; and 4.Expanding the CDR exemption to include all coal combustion residuals (CCR).