Advocacy submits Comments to EPA on Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals From Electric Utilities; Amendments to the National Minimum Criteria
April 27, 2018
The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA) proposed rule, “Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals (CCR) From Electric Utilities; Amendments to the National Minimum Criteria (Phase One).”
Advocacy is concerned about the impact of the changes on small businesses. Advocacy recommends that EPA address its concerns by extending the upcoming October 2018 deadlines and by allowing the risk-based alternative performance standards to be applicable to the existing self-implementing rule. Advocacy further recommends that the agency provide flexibilities to manage non-CCR wastestreams and for the use of CCR for final cover systems. Finally, Advocacy suggests that the agency leave boron off the list of constituents in Appendix IV. Advocacy urges EPA to carefully address these small business concerns and to consider providing appropriate and timely regulatory flexibilities to small businesses while still accomplishing the agency’s regulatory objective.