Comment submitted by American Public Power Association (APPA)
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Summary: The American Public Power Association (APPA), representing not-for-profit, community-owned utilities, supports the EPA's proposal to reconsider the 2024 ELG Rule's requirements for unmanaged combustion residual leachate (UCRL). They advocate for a site-specific permitting framework (Option 1) for certain leachate types, the retention of national arsenic and mercury limits with a 2034 deadline for pumped UCRL, and the repeal of zero-liquid discharge (ZLD) requirements for other wastestreams.
The American Public Power Association (APPA) appreciates the opportunity to submit comments on the Environmental Protection Agency’s (EPA or Agency) proposed rule to revise the technology-based effluent limitation guidelines for unmanaged combustion residual leachate (UCRL) in the 2024 Supplemental Effluent Limitation Guidelines and Standards for Steam Electric Power Generating Point Source Category (2024 ELG Rule).