Comment submitted by Keystone-Conemaugh Projects, LLC (KEY-CON)

Summary: Keystone-Conemaugh Projects, LLC (KEY-CON), a licensee for two power plants in Pennsylvania, supports the EPA's proposal to rescind CCRMU requirements and create a "CCR dewatering structure" exemption. They argue that retroactive regulations on closed units create investment risks and request specific clarifications to the definition of dewatering structures to ensure they include certain lined ponds.