Comment submitted by Persistence Analytics Group LLC
AnonymousSupportBusiness
Summary: Persistence Analytics Group LLC supports the EPA's efforts to manage legacy coal combustion residuals but argues for stricter implementation integrity. They recommend that the final rule require site-specific verification of risks, enforceable milestones, financial accountability, and public reporting to protect communities and ratepayers.
Persistence Analytics Group LLC submits this comment regarding EPA-HQ-OLEM-2020-0107, Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy/CCRMU Amendments.
PAG supports EPA’s effort to address legacy coal combustion residuals and CCR management units through a framework that protects groundwater, nearby communities, utility customers, and long-term public infrastructure.
The core issue is implementation integrity.
CCR disposal is not only a waste-management issue. It is an infrastructure-risk issue.
Legacy CCR sites, groundwater monitoring, closure plans, corrective action, financial assurance, public disclosure, and utility cost recovery all depend on assumptions that must be verified before risks become harder to reverse.
EPA should require clear, site-specific answers to the following questions:
1. What CCR material exists, where is it located, and what is the verified exposure pathway?
2. What groundwater, surface water, flood, seismic, and structural risks are present?
3. What closure or corrective-action method is being proposed, and why is it technically and financially executable?
4. Who pays for closure, monitoring, corrective action, and long-term care?
5. How will utilities prevent unfunded environmental liabilities from becoming ratepayer exposure?
6. What public information will be available so communities can understand site risk and progress?
7. What happens if the selected remedy fails, costs escalate, timelines slip, or contamination persists?
EPA should not rely on paper compliance alone.
The final rule should require an implementation-verification layer: verified site data, enforceable milestones, public progress reporting, financial accountability, and clear failure-response mechanisms.
The goal should be simple:
Identify the risk.
Verify the remedy.
Protect the community.
Protect the ratepayer.
Prevent legacy assumptions from becoming future liabilities.
Respectfully submitted,
Neil P. Osnato
Founder
Persistence Analytics Group LLC | United Grid
National Security & Infrastructure Risk Analytics
Demand Durability | Grid Stress | Load Integrity
SAM.gov Registered Vendor
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neil@persistenceanalyticsgroup.com
609-464-9055
https://persistenceanalyticsgroup.com/