​On January 31, 2020, NRECA filed comments on the CCR Closure Part A proposal by the Environmental Protection Agency (EPA). NRECA appreciates EPA's efforts to provide the opportunity for extensions to the deadline due to the lack of alternative disposal capacity for both CCR and non-CCR wastes.  While urging the agency to move expeditiously to finalize this and the upcoming Part B proposal, we also offer three recommendations to improve this proposed rule:

  1. Do not shorten the construction timeline from October 31, 2020 but extend the deadline to January 15, 2021 as recommended and justified by the USWAG analysis and recommendation;
  2. Revise the proposed extensions to better accommodate events beyond a plant's control (e.g. weather) and remove the proposed language (and related notifications) making the extensions mutually exclusive per Appendix A; and
  3. Finalize the CCR Part A and Part B rules concurrently and in coordination with the final ELG rule.