Fix or Fight- EPA’s Part A and Part B Groundwater Deficiency Findings.pdf

Kevin Solie, Barr Engineering Co.
Kaela Nerhus, Barr Engineering Co.
Jim Aiken, Barr Engineering Co.

Description

Fix or Fight: EPA’s Part A and Part B groundwater monitoring deficiency findings Authors Mr. Kevin Solie - United States - Barr Engineering Co. Ms. Kaela Nerhus - United States - Barr Engineering Co. Mr. Jim Aiken - United States - Barr Engineering Co. Abstract The EPA’s proposed and final CCR Rule Part A and Part B determinations are in essence denials, based largely on EPA’s evaluation of the adequacy of groundwater monitoring systems at the facilities. In almost all cases, EPA has found fault (often without accompanying supporting evidence) asserting various elements of the CCR Rule groundwater monitoring systems including statistical methodologies, monitoring well networks and certifications, and previously completed Alternate Source Demonstrations (ASDs) are incomplete or otherwise inadequate. The purpose of this presentation is to offer a critical examination of the EPA positions set forth in its Part A and Part B determinations, and to suggest practical solutions to challenge EPA’s potentially unwarranted positions. Fix or fight? The best answer is likely somewhere in between.

 
May 15th, 1:00 PM May 15th, 1:30 PM

Fix or Fight- EPA’s Part A and Part B Groundwater Deficiency Findings.pdf

Grand Rapids, Michigan

Fix or Fight: EPA’s Part A and Part B groundwater monitoring deficiency findings Authors Mr. Kevin Solie - United States - Barr Engineering Co. Ms. Kaela Nerhus - United States - Barr Engineering Co. Mr. Jim Aiken - United States - Barr Engineering Co. Abstract The EPA’s proposed and final CCR Rule Part A and Part B determinations are in essence denials, based largely on EPA’s evaluation of the adequacy of groundwater monitoring systems at the facilities. In almost all cases, EPA has found fault (often without accompanying supporting evidence) asserting various elements of the CCR Rule groundwater monitoring systems including statistical methodologies, monitoring well networks and certifications, and previously completed Alternate Source Demonstrations (ASDs) are incomplete or otherwise inadequate. The purpose of this presentation is to offer a critical examination of the EPA positions set forth in its Part A and Part B determinations, and to suggest practical solutions to challenge EPA’s potentially unwarranted positions. Fix or fight? The best answer is likely somewhere in between.