Comment to EPA before Nov. 19, 2010 on Coal Combustion Waste Regulation
Time is running out!

                 November 17, 2010

                                   from J.K.
                                   and the Environmental Integrity Project


Please send comments by Nov. 19 to USEPA asking them to:

1. Regulate Coal Combustion Wastes under RCRA Subtitle C as Special Waste *not* Solid Waste. Studies show that ash is hazardous, and that ground water under ash impoundments violates water quality standards. West Virginia does not limit contamination! We need federal oversight on this!!

1. Tighten the loopholes for ''Beneficial Use'' -- especially in mine land applications.  Much of the coal ash in northern West Virginia is exempted because it is dumped on mine sites as a so-called ''beneficial use.''  Under this provision, the mine is exempted from requirements for liners, leachate collection, ground water monitoring, and more.  In fact, if EPA adopts their proposed rule, it may push even more ash onto these mine sites, threatening our ground water. Please tell EPA that the example of West Virginia shows why tougher regulation is needed, that state regulation is NOT working, and the rule needs to be strengthened by closing the beneficial use loopholes.

More information is in the Federal Register announcement available here.


SEVERAL WAYS TO COMMENT (by Nov. 19th):

• Go to www.regulations.gov and follow the on-line instructions for submitting comments.

• Email comments to rcra-docket@epa.gov  Subject: Attention Docket ID No. EPA-HQ-RCRA-2009-0640.

• Fax to 202-566-0272; Attention Docket ID No. EPA-HQRCRA-2009-0640.

• Fill in the Earth Justice form letter with your contact information and submit it.

• Mail your comments (time is running out!) to the

  Hazardous Waste Management System

  Identification and Listing of Special Wastes;

  Disposal of Coal Combustion Residuals From Electric Utilities Docket

  Attention: Docket ID No. EPA-HQ-RCRA-2009-0640

  Environmental Protection Agency

  Mailcode 5305T

  1200 Pennsylvania Ave NW

  Washington, DC 20460
  
  

  Please include a total of two copies of your comments if sending them by mail.
  
  

  Thanks!
  paula