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EPARulemakingEPA-HQ-RCRA-2012-0028

Hazardous and Solid Waste Management System: Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities: Notice of Data Availability and Request for Comment.

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National Rural Electric Cooperative Association filings
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Activity

National Rural Electric Cooperative Association filed 1 comment on this docket between Sep 5, 2013 and Sep 5, 2013. 31 other organizations filed here. The comment window closed 4711d ago.

What National Rural Electric Cooperative Association filed (1)

Sep 5, 2013· Comment submitted by Dorothy Allen Kellogg, Senior Principal - Environment Policy, National Rural Electric Cooperative Association (NRECA)· EPA-HQ-RCRA-2012-0028-0075

The National Rural Electric Cooperative Association (NRECA) submits comments on EPA's recent Notice of Data Availability (NODA) and Request for Comment regarding the "Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals from Electric Utilities" (78 Fed Reg 46940, August 2, 2013). NRECA has worked with our utility sector partners in the Utility Solid Waste Activity Group (USWAG) and endorse the extensive comments submitted by that organization (attached). As more extensively discussed in the USWAG comments NRECA emphasizes that: 1. The new information in the NODA reaffirm that a revised CCR risk assessment supports management of CCR as non-hazardous wastes. 2. The definition of a "CCR landfill" should not include large scale fill CCR beneficial use projects because such operations do not involve the disposal of a solid waste. 3. The data demonstrates that existing CCR surface impoundments do not pose an immediate safety threat. 4. The final CCR rule should not require the initiation of closure of a CCR surface impoundment or landfill if the owner/operator of the unit can demonstrate that there is a reasonable basis that the impoundment may be needed to manage wastes in the future. 5. Closure time frames for CCR surface impoundments and landfills should be derived from the facility's closure procedures and schedules as addressed in a state-authorized closure process that is included in the facility's operating record or in a closure plan certified by an independent professional engineer. 6. EPA should not apply the location restrictions for new units to "overfills," nor should these expansions be subject to the liner and groundwater monitoring requirements for new units if these standards are already being met by the underlying unit.

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Abstract

Notice of Data availability and supporting and related materials relevant to the coal combustion residuals rulemaking.

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Co-filers (31)

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