Comment submitted by Electric Power Research Institute, Inc. (EPRI)
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Summary: The Electric Power Research Institute (EPRI) provides technical comments highlighting the site-specific nature of unmanaged combustion residual leachate (UCRL) and the uncertainties surrounding its characterization, costs, and treatment feasibility. They argue that a lack of data and diverse hydrogeologic conditions make it difficult to establish nationwide effluent limitations and suggest that more research and site-specific evaluations are necessary.
Please find attached comments from the Electric Power Research Institute (EPRI) on the proposed Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category - Unmanaged Combustion Residual Leachate Rule (EPA-HQ-OW-2009-0819). Thank you for the opportunity to comment.
Jesse Cannon
Technical Leader III
EPRI
jcannon@epri.com
(980) 261-8474
3420 Hillview Avenue
Palo Alto, CA 94304