On June 16, AMWA submitted comments on EPA’s proposed revisions to the steam electric effluent limit guidelines for coal-fired power plants. EPA's proposed changes would revise wastewater discharge rules for coal-fired power plants by relaxing the requirements that apply to unmanaged combustion residual leachate that can leak from coal ash landfills and impoundments into the subsurface. EPA proposes to shift from uniform national limits on mercury and arsenic to state-by-state best professional judgment determinations for discharges that are the functional equivalent of a direct discharge.
AMWA’s comments emphasize the importance of protecting drinking water sources when these site-specific discharge limits are established. The Association urged EPA to include regulatory language to ensure that site-specific effluent limitations explicitly consider potential impacts to drinking water systems and to notify potentially affected systems so they can participate meaningfully in the permitting process. AMWA also raised concerns that EPA's economic analysis does not account for potential costs to drinking water systems if less stringent discharge requirements result in additional source water contamination.
AMWA has previously commented on efforts to relax or delay ELG standards for coal-fired power plants. The association will continue to track changes to these standards and advocate for consideration of source water protection for drinking water systems