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 adequately 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 truly interested in ensuring 

that the public has a full and complete opportunity to comment on the information the agency has identified as having the potential to impact 

decisions in developing a final rule, then more than a 30-day period should be allowed to evaluate the validity and propriety of 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 involvement of 

those who are intended to benefit from and those expected to be burdened by any regulation (including, specifically, State, local, and tribal 

officials). In addition, each agency should afford the public a meaningful opportunity to comment on any proposed regulation, which 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 final 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.

Manager - 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@scana.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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