Comment submitted by Duke Energy

Summary: Duke Energy Corporation opposes the EPA's proposed definition of "unmanaged combustion residual leachate" (unmanaged CRL) because it improperly classifies diffuse groundwater seepage from coal ash units as "point source" discharges under the Clean Water Act. The company argues that these releases are more appropriately regulated under the existing RCRA CCR Rule and that NPDES permitting for such diffuse seepage is technically and administratively impracticable.