BEST PRACTICES IN IMPLEMENTING THE FACILITY EVALUATION REPORT

Mark Rokoff, Burns & McDonnell

Description

CASE STUDY: BEST PRACTICES IN IMPLEMENTING THE FACILITY EVALUATION REPORT (PER THE LEGACY CCR SI RULE) Authors Mr. Mark Rokoff - United States - Burns & McDonnell Abstract Corresponding to the proposed Legacy CCR Surface Impoundment Rules (Legacy Rule) published on May 18, 2023, Owner/Operators must initiate the efforts for compliance by first understanding the areas where CCR has accumulated within a plant’s facility outside of a regulated CCR unit. More specifically, one of the first, new tasks to comply with the proposed rule is to develop a Facility Evaluation Report (FER) in which the presence/absence of a CCR management unit (CCRMU) and horizontal/vertical limits are to be determined and documented. The Legacy Rule is quite specific in the approach and requirements to (1) gather information, (2) evaluate information, (3) conduct interviews and a physical inspection of the site, (4) implement a possible field investigation, and (5) thoroughly document the effort/findings. Under 40 CFR §257.75(c), there are thirteen specific requirements to be considered and posted just three months after the Legacy Rule becomes effective. Subject to an aggressive schedule, the FER is no small undertaking with many nuisances to consider in properly implementing the requirement. Following the development of guidance documentation and initial implementation of FERs for current Owners/Operators since the proposed Legacy Rule was published in May 2023, this presentation will present best practices, lessons learned, possible pitfalls/challenges, and suggested next steps to prepare. This is a significant and highly impactful effort that will set the stage for the remaining tasks coming over the following years…getting it right is the only option!

 
May 14th, 1:00 PM May 14th, 1:30 PM

BEST PRACTICES IN IMPLEMENTING THE FACILITY EVALUATION REPORT

Grand Rapids, Michigan

CASE STUDY: BEST PRACTICES IN IMPLEMENTING THE FACILITY EVALUATION REPORT (PER THE LEGACY CCR SI RULE) Authors Mr. Mark Rokoff - United States - Burns & McDonnell Abstract Corresponding to the proposed Legacy CCR Surface Impoundment Rules (Legacy Rule) published on May 18, 2023, Owner/Operators must initiate the efforts for compliance by first understanding the areas where CCR has accumulated within a plant’s facility outside of a regulated CCR unit. More specifically, one of the first, new tasks to comply with the proposed rule is to develop a Facility Evaluation Report (FER) in which the presence/absence of a CCR management unit (CCRMU) and horizontal/vertical limits are to be determined and documented. The Legacy Rule is quite specific in the approach and requirements to (1) gather information, (2) evaluate information, (3) conduct interviews and a physical inspection of the site, (4) implement a possible field investigation, and (5) thoroughly document the effort/findings. Under 40 CFR §257.75(c), there are thirteen specific requirements to be considered and posted just three months after the Legacy Rule becomes effective. Subject to an aggressive schedule, the FER is no small undertaking with many nuisances to consider in properly implementing the requirement. Following the development of guidance documentation and initial implementation of FERs for current Owners/Operators since the proposed Legacy Rule was published in May 2023, this presentation will present best practices, lessons learned, possible pitfalls/challenges, and suggested next steps to prepare. This is a significant and highly impactful effort that will set the stage for the remaining tasks coming over the following years…getting it right is the only option!