Legacy Rule Insights and Challenges

Arica DiTullio, GAI Consultants, Inc.
Leigh Rounce, GAI Consultants, Inc.

Description

Legacy Rule Insights and Challenges Authors Mrs. Arica DiTullio - United States - GAI Consultants, Inc. Ms. Leigh Rounce - United States - GAI Consultants, Inc. Abstract This presentation will provide a summary of the proposed Legacy Impoundment Rule, which includes regulations for inactive impoundments and inactive landfill at inactive facilities. The discussion will include a review of the timeline for the Coal Combustion Residual (CCR) Rule and prudent definitions of terminology, such as Facility, Inactive Facility, Inactive Impoundment, Legacy Impoundment, Inactive Landfill, CCR Unit and CCR Management Unit. Summary and examples of Legacy CCR Surface Impoundment Applicability Documentation will be provided. Legacy impoundments need to implement most measures outlined in the CCR Rule, including inspections, monitoring of instrumentation, reporting, groundwater monitoring and reporting. CCRMUs facility evaluations must be initiated upon effective date of the Final Rule. Facilities must consult available records, complete a physical inspection, and complete necessary field investigations. The Facility Evaluation Report must be completed within 3 months of the Final Rule effective date and must be certified by a qualified professional engineer. This report must contain the results of the facility evaluation and additional information about the CCRMUs onsite. After identifying CCRMUs, facilities are required to implement some other measures outlined in the CCR Rule. The presentation will conclude with highlighting some of the challenges anticipated and hypothetical case examples.

 
May 14th, 2:00 PM May 14th, 2:30 PM

Legacy Rule Insights and Challenges

Grand Rapids, Michigan

Legacy Rule Insights and Challenges Authors Mrs. Arica DiTullio - United States - GAI Consultants, Inc. Ms. Leigh Rounce - United States - GAI Consultants, Inc. Abstract This presentation will provide a summary of the proposed Legacy Impoundment Rule, which includes regulations for inactive impoundments and inactive landfill at inactive facilities. The discussion will include a review of the timeline for the Coal Combustion Residual (CCR) Rule and prudent definitions of terminology, such as Facility, Inactive Facility, Inactive Impoundment, Legacy Impoundment, Inactive Landfill, CCR Unit and CCR Management Unit. Summary and examples of Legacy CCR Surface Impoundment Applicability Documentation will be provided. Legacy impoundments need to implement most measures outlined in the CCR Rule, including inspections, monitoring of instrumentation, reporting, groundwater monitoring and reporting. CCRMUs facility evaluations must be initiated upon effective date of the Final Rule. Facilities must consult available records, complete a physical inspection, and complete necessary field investigations. The Facility Evaluation Report must be completed within 3 months of the Final Rule effective date and must be certified by a qualified professional engineer. This report must contain the results of the facility evaluation and additional information about the CCRMUs onsite. After identifying CCRMUs, facilities are required to implement some other measures outlined in the CCR Rule. The presentation will conclude with highlighting some of the challenges anticipated and hypothetical case examples.