Comment submitted by America's Power

Summary: America’s Power, a national trade organization representing the coal-fired electricity supply chain, supports the EPA's proposed Option 1 to establish case-specific "best professional judgment" (BPJ) effluent limitations for unmanaged coal residual leachate. They argue that uniform national standards for mercury and arsenic are technically and economically unfeasible due to the high variability of groundwater-derived waste streams and advocate for similar BPJ flexibility for pumped and treated leachate as well as exclusions for retired plants.