The American Public Power Association on September 15 filed comments in response to the U.S. Environmental Protection Agency’s proposed “Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; CCR Management Unit Deadline Extension Rule.”
APPA’s comments generally express support for the Proposed Rule, which would extend the compliance deadlines applicable to coal combustion residual management units (CCRMUs).
APPA said that EPA should finalize the proposed 12-month extension of the compliance deadline for completing the Facility Evaluation Report (FER) Part 1.
Also, EPA should finalize the proposed 15-month extension for groundwater monitoring compliance, along with the proposed conforming changes to the remaining CCRMU compliance deadlines, APPA argued.
APPA also said that EPA should finalize the proposed 12-month extension of the FER Part 2 compliance deadline, recognizing that FER Part 1 and Part 2 are sequential phases of the overall FER process; and if EPA grants a 12-month extension for FER Part 2, the Agency must proportionally extend all other CCRMU-related deadlines.
APPA believes the proposed extensions are justified, given the Agency's ongoing review of the CCRMU provisions. Public power utilities and affected facilities seek to avoid unnecessary spending on regulations that are likely to be revised.
