### 1 Attachment

October 18, 2011

Steve Souders Office of Resource Conservation and Recovery (5304P) U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW. Washington, DC 20460–0002

ATTENTION: Docket ID No. EPA–HQ–RCRA–2011–0392

Dear Mr. Souders:

SCANA Corporation and its principal subsidiary, South Carolina Electric & Gas Company, requests an additional 60 days to adequa tely review, analyze and develop comments on data/information the EPA has made available related to the proposed CCR rule (76 FR63252).

The EPA indicates that most of the information referenced in the Federal Register notice, including specific comments, is in a docket supporting the notice. However, the agency also directs readers to websites at internet addresses provided in the notice. If the EPA is trul y interested in ensuring that the public has a full and complete opportunity to comment on the information the agency has identified as having the poten tial to impact decisions in developing a final rule, then more than a 30-day period should be allowed to evaluate the validity and propriety o f using the newly acquired information, data, and potential analyses.

Additionally, we would urge the EPA to abide by the spirit of Executive Order 12866 which reads as follows:

Section 6(a) Agency Responsibilities.

(1) Each agency shall (consistent with its own rules, regulations, or procedures) provide the public with meaningful participation in the regulatory process. In particular, before issuing a notice of proposed rulemaking, each agency should, where appropriate, seek the involve ment of those who are intended to benefit from and those expected to be burdened by any regulation (including, specifically, State, loc al, and tribal officials). In addition, each agency should afford the public a meaningful opportunity to comment on any proposed regulation, w hich in most cases should include a comment period of not less than 60 days. Each agency also is directed to explore and, where appropriate, use consensual mechanisms for developing regulations, including negotiated rulemaking.

Since the EPA itself is still in the process of evaluating the new information and data and deliberating the provisions of a fi nal rule, we ask that the agency also allow the public and entities that will be impacted by the final rule ample time to thoroughly review and evaluate the information and data

in Docket EPA–HQ–RCRA–2011–0392 as well as information on specified websites. We believe an additional 60 days will allow time for evaluating and preparing comments on the new CCR information and data.



## Mana g er - Environmental Services FW: CCR NODA -- Docket ID No. EPA–HQ–RCRA–2011–0392 EFFINGER, THOMAS N

to:
Steve Souders

10/18/2011 03:07 PM

Cc: "YOUNAN, JEAN-CLAUDE", "PRESTON, JOHN W JR", "RUFFIN, SHIRLEY M", "LANDRETH, JAMES M", "HAMILTON, J. HAGOOD JR", "MANGAN-BRYSON, SUZETTE", "MAHAN, RANDOLPH R", "LINDSAY, RONALD", "DOVELL, SHARON K"

Hide Details From: "EFFINGER, THOMAS N" <TEFFINGER@scana.com> Sort List...

To: Steve Souders/DC/USEPA/US@EPA

Cc: "YOUNAN, JEAN-CLAUDE" <JYOUNAN@scana.com>, "PRESTON, JOHN W JR" <JPRESTON@scana. com>, "RUFFIN, SHIRLEY M" <SRUFFIN@scana.com>, "LANDRETH, JAMES M" <JLANDRETH@scan a.com>, "HAMILTON, J. HAGOOD JR" <JHAMILTON@scana.com>, "MANGAN-BRYSON, SUZETTE" <SMANGAN-BRYSON@scana.com>, "MAHAN, RANDOLPH R" <RMAHAN@scana.com>, "LINDSAY, RONALD" <RONALD.LINDSAY@scana.com>, "DOVELL, SHARON K" <SDOVELL@scana.com>

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## SCANA

Mail Code C-221 220 Operation Way Cayce, SC 29033-3701

803-217-9367 office

803-608-3303 cell 

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