Comment submitted by Association of State and Territorial Solid Waste Management Officials (ASTSWMO)
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Summary: The Materials Management Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) supports the EPA's proposed rule regarding the disposal of coal combustion residuals (CCR). They advocate for aligning CCR regulations with Subtitle D of the Resource Conservation and Recovery Act, specifically supporting clarifications on dewatering structures, groundwater monitoring flexibility, and the distinction between storage piles and temporary accumulations.
Attached are comments from the ASTSWMO Materials Management Subcommittee.