Comment submitted by National Ground Water Association (NGWA)
AnonymousSupportAdvocacy
Summary: The National Ground Water Association (NGWA) supports the proposed federal CCR permit program, highlighting its benefits for groundwater protection, such as permit-based oversight, public participation, and electronic access to groundwater data. While they identify some concerns regarding potential inconsistencies and resource limitations, they emphasize that the rule provides a necessary framework for protecting nearby groundwater users and ensuring enforceable permit conditions.
The National Ground Water Association's comments on the proposed rule, "Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals From Electric Utilities; Federal CCR Permit Program; Reopening of Comment Period", EPA-HQ-OLEM-2019-0361-0344, are in the attached files. Thank you for the opportunity to comment on this proposed rule.