Applying CCR Lessons Learned to Legacy Rule Implementation

Sarah Holmstrom, TRC
Greg Tieman, TRC

Description

Applying CCR Lessons Learned to Legacy Rule Implementation Authors Mrs. Sarah Holmstrom - United States - TRC Mr. Greg Tieman - United States - TRC Abstract Since the Coal Combustion Residuals (CCR) Rule first went into effect in 2015, compliance monitoring programs, closure plans and remedy selection strategies have been established and implemented to expeditiously comply with the self-implementing rule on a site-by-site basis. Over that timeframe, USEPA has released numerous decisions and opinions (e.g., Part A, Part B) regarding the achievement and demonstration of compliance with the CCR Rule, including but not limited to comments regarding adequacy of detection monitoring networks, statistical evaluation approaches and methodologies, and alternative source demonstrations. On May 18, 2023, USEPA published the proposed Legacy Surface Impoundments (Legacy) rule to regulate legacy CCR materials and introduce regulation of CCR management units (CCRMUs). It is anticipated this rule may become effective as early as the fall of 2024 and is expected to ensue at an aggressive pace. Several elements of the proposed Legacy rule differ from the 2015 CCR Rule, yet there are many common threads that will require thoughtful and pro-active approaches to achieve and maintain regulatory compliance. TRC has been tracking the USEPA’s commentary, while keeping in-mind the perspective gained by implementing the CCR Rule over the past eight years. TRC has applied that insight into developing several lessons learned, key takeaways, and considerations that can be applied to the forthcoming implementation of the proposed Legacy rule to help cultivate pragmatic and defensible strategies to manage compliance with the forthcoming CCR regulations.

 
May 14th, 11:00 AM May 14th, 11:30 AM

Applying CCR Lessons Learned to Legacy Rule Implementation

Grand Rapids, Michigan

Applying CCR Lessons Learned to Legacy Rule Implementation Authors Mrs. Sarah Holmstrom - United States - TRC Mr. Greg Tieman - United States - TRC Abstract Since the Coal Combustion Residuals (CCR) Rule first went into effect in 2015, compliance monitoring programs, closure plans and remedy selection strategies have been established and implemented to expeditiously comply with the self-implementing rule on a site-by-site basis. Over that timeframe, USEPA has released numerous decisions and opinions (e.g., Part A, Part B) regarding the achievement and demonstration of compliance with the CCR Rule, including but not limited to comments regarding adequacy of detection monitoring networks, statistical evaluation approaches and methodologies, and alternative source demonstrations. On May 18, 2023, USEPA published the proposed Legacy Surface Impoundments (Legacy) rule to regulate legacy CCR materials and introduce regulation of CCR management units (CCRMUs). It is anticipated this rule may become effective as early as the fall of 2024 and is expected to ensue at an aggressive pace. Several elements of the proposed Legacy rule differ from the 2015 CCR Rule, yet there are many common threads that will require thoughtful and pro-active approaches to achieve and maintain regulatory compliance. TRC has been tracking the USEPA’s commentary, while keeping in-mind the perspective gained by implementing the CCR Rule over the past eight years. TRC has applied that insight into developing several lessons learned, key takeaways, and considerations that can be applied to the forthcoming implementation of the proposed Legacy rule to help cultivate pragmatic and defensible strategies to manage compliance with the forthcoming CCR regulations.