Comment submitted by American Electric Power (AEP)
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Summary: American Electric Power (AEP), a large electric utility, supports the EPA's proposal to apply arsenic and mercury effluent limitations to pumped unmanaged combustion residual leachate and to allow states to use Best Professional Judgement for functionally equivalent direct discharges. However, the company argues that zero-liquid discharge (ZLD) requirements are not economically achievable or technically available and requests that the EPA repeal the 2024 ELG Rule regarding ZLD.
American Electric Power's comments on the proposed Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category-Unmanaged Combustion Residual Leachate