Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy/CCRMU Amendments; Public Hearing

The submission is a technical placeholder or administrative notice regarding attachments for comments filed by Earthjustice, et al. It does not contain a specific position or argument from the submitter.

Earthjustice submitted a set of attachments, including an Environmental Assessment Report for the John Sevier Fossil Plant, as part of a larger joint comment with several other environmental organizations. The comment serves as a technical submission of data and reports rather than a direct statement of support or opposition to the proposed rule.

This submission is a collection of technical documents and attachments (specifically a Sitewide Groundwater Remedial Action Plan for the E.W. Brown Generating Station) submitted by a coalition of environmental advocacy groups. The comment does not express a specific stance on the proposed rule but provides supporting documentation for their position.

Earthjustice, along with several other environmental organizations, submitted a series of technical documents and evidence regarding the health and environmental impacts of coal combustion residuals (CCR). The submission highlights numerous "damage cases" involving fugitive dust, groundwater contamination, and air quality risks to support the need for stricter federal regulations on CCR disposal.

Earthjustice submitted a set of attachments to the EPA supporting the proposed rule on coal ash disposal. The submission includes data on EPA-confirmed coal ash reuse damage cases and environmental justice data to highlight the risks associated with coal ash.

Teresa de Lima, a private resident of Palmer, Alaska, opposes the disposal of coal ash. She provides a detailed hypothetical analysis of how dumping coal ash in Fairbanks would contaminate local rivers, groundwater, and the Bering Sea over a century.

The Environmental Protection Agency (EPA) is proposing to deny a request from the Indiana-Kentucky Electric Corporation (IKEC) for an extension to continue using two coal combustion residuals (CCR) surface impoundments at the Clifty Creek Power Station. The EPA argues that IKEC failed to demonstrate a lack of off-site disposal capacity for certain wastestreams and failed to show compliance with specific groundwater monitoring and corrective action requirements.

The Ohio Utilities and Generation (OUG), an association of electric utilities, supports the EPA's Legacy Amendments, particularly regarding the rescission of CCR Management Unit provisions and expanded recognition of beneficial use. However, they argue that the rules should be further modified to focus on site-specific risk assessments rather than presumed risks and to ensure that work performed under other federal or state programs is not undermined by the new rules.

The Luminant Companies, a group of power generation facilities, support the EPA's proposed revisions to the coal combustion residuals (CCR) regulations. They argue that the proposed site-specific, risk-based approach is more consistent with statutory authority and real-world data than the previous "worst-case" one-size-fits-all standards.