EPN Comments on Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category-Unmanaged Combustion Residual Leachate

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On June 17, 2026, Environmental Protection Network submitted formal comments opposing the EPA’s rollback of the 2024 mercury and arsenic discharge limits for unmanaged combustion residual leachate.

EPN argues that EPA relies on speculative assumptions regarding future coal plant operations, contested emergency orders, delayed compliance deadlines, and uncertain future permitting outcomes while discounting the substantial public health, drinking water, ecological, Tribal, and environmental justice benefits of reducing toxic pollutant discharges. The rule also unfairly exempts retired facilities, ignoring ongoing groundwater contamination pathways from coal ash units where hazardous waste is simply left in place. EPA should withdraw the proposed rollback, retain the 2024 mercury and arsenic limitations for unmanaged combustion residual leachate, and maintain nationally consistent technology-based standards that protect public health, water quality, and environmental integrity.

Read the full comments.

EPN Work Topics
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