Comment submitted by TerryAnn, Towers Saint Amand

Subject: Public Comment on Virginia Coal Combustion Residuals Permit Program To Whom It May Concern, I am submitting comments regarding EPA’s proposed approval of Virginia’s coal combustion residuals permit program. Coal ash management remains a significant long-term groundwater and environmental protection issue due to the potential presence of contaminants including arsenic, selenium, mercury, lead, lithium, cadmium, chromium, and other hazardous substances associated with coal combustion residuals. Because groundwater contamination from coal ash disposal may persist for decades, I encourage EPA to ensure that any approved state program maintains strong, enforceable, and transparent protections that are fully consistent with long-term public and environmental health needs. I encourage careful evaluation of: Groundwater monitoring requirements and public accessibility of monitoring data. Long-term corrective action obligations and enforcement mechanisms. Oversight of legacy disposal units and inactive impoundments. Financial assurance and long-term stewardship responsibilities. Transparency regarding permit compliance, violations, corrective actions, and site monitoring. Whether state implementation mechanisms provide sufficiently durable and independent oversight capacity over time. I also encourage EPA to carefully consider cumulative environmental burdens affecting communities located near coal ash disposal facilities, including impacts to drinking water resources, surface waters, ecosystems, and environmental justice concerns. I also encourage continued transparency regarding Tribal consultation processes associated with the proposed permit program. Public records clearly indicate that consultation outreach occurred with several Tribal Nations, including the Monacan Indian Nation, Rappahannock Tribe, Nansemond Indian Nation, and Chickahominy Indian Tribe - Eastern Division. To the extent appropriate and consistent with government-to-government consultation practices, additional public clarity regarding how Tribal concerns were considered and addressed would help strengthen public understanding and confidence in the review process. If state permit authority is delegated, continued strong federal oversight and accountability remain important to ensure consistent protections and long-term public confidence. Coal ash contamination can create environmental liabilities lasting far beyond the operational lifespan of the facilities that generated the waste. Long-term groundwater stewardship and precautionary oversight should remain central priorities. Thank you for considering these comments. Sincerely, TerryAnn Towers Saint Amand - An American living in London, England with ties to New Hampshire and Maine