IT’S HERE NOW!​.pdf

Mark Rokoff, Burns & McDonnell

Description

IT’S HERE NOW! SUMMARIZING KEY ELEMENTS IN THE NEW LEGACY CCR SI RULE Authors Mr. Mark Rokoff - United States - Burns & McDonnell Abstract Subject to a formal consent decree, the EPA has agreed to issue the final Legacy CCR Surface Impoundment Rules (Legacy Rule) by May 6, 2024, following the recent publication of the proposed version of the same rule on May 18, 2023. The EPA is intent on completing the Legacy Rule further documenting their intent in the “Fall Unified Agenda” where it states that the rule will be finalized in April 2024. The Legacy Rule is highly impactful for Owner/Operators by applying requirements to groundwater monitoring, corrective action, closure, and more to a new subset of CCR units – legacy CCR surface impoundments. However, it additionally requires very similar actions to be taken on any area of land on which any non-containerized accumulation of CCR is received, placed, or otherwise managed at any time, that is not a CCR unit – known as CCR management units (CCRMUs). The projected number of Legacy SIs and CCRMUs is staggering for which a new set of requirements are defined for implementation in an aggressive timeframe. This presentation will summarize the key elements of the new Legacy CCR SI Rule in a succinct format to best characterize what is new (and different from the proposed version). It will also highlight key requirements and timelines for compliance while discussing key next steps to best prepare.

 
May 15th, 9:00 AM May 15th, 9:30 AM

IT’S HERE NOW!​.pdf

Grand Rapids, Michigan

IT’S HERE NOW! SUMMARIZING KEY ELEMENTS IN THE NEW LEGACY CCR SI RULE Authors Mr. Mark Rokoff - United States - Burns & McDonnell Abstract Subject to a formal consent decree, the EPA has agreed to issue the final Legacy CCR Surface Impoundment Rules (Legacy Rule) by May 6, 2024, following the recent publication of the proposed version of the same rule on May 18, 2023. The EPA is intent on completing the Legacy Rule further documenting their intent in the “Fall Unified Agenda” where it states that the rule will be finalized in April 2024. The Legacy Rule is highly impactful for Owner/Operators by applying requirements to groundwater monitoring, corrective action, closure, and more to a new subset of CCR units – legacy CCR surface impoundments. However, it additionally requires very similar actions to be taken on any area of land on which any non-containerized accumulation of CCR is received, placed, or otherwise managed at any time, that is not a CCR unit – known as CCR management units (CCRMUs). The projected number of Legacy SIs and CCRMUs is staggering for which a new set of requirements are defined for implementation in an aggressive timeframe. This presentation will summarize the key elements of the new Legacy CCR SI Rule in a succinct format to best characterize what is new (and different from the proposed version). It will also highlight key requirements and timelines for compliance while discussing key next steps to best prepare.