Author: Graham Crockford, Sarah Holmstrom and Greg Tieman | June 8, 2023

Preparing for New Compliance Obligations

On May 18, 2023, EPA published the proposed Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy CCR Surface Impoundments to amend subpart D of part 257 of Title 40 (Legacy CCR Surface Impoundments). The proposed rule would regulate Legacy CCR Surface Impoundments under the existing Subpart D of part 257 of Title 40, known as the CCR Rule, which became effective on October 19, 2015.

TRC’s white paper describes the key implications of the Proposed CCR Legacy Surface Impoundments Rule for regulated utilities.

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Graham Crockford

Graham Crockford, VP has over 36 years of professional experience in the environmental consulting industry and has been at TRC for over 28 years. He currently serves as an Account Leader and Solid Waste Initiative Director in the Engineering, Construction and Remediation practice for TRC, and co-leads TRC Coal Combustion Residuals (CCR) CORE team with Sarah Holmstrom. He also serves as a Program Manager for TRC's utility and industrial clients where he assists utilities with addressing their environmental liabilities as they achieve their renewable energy and decarbonization goals. Graham has a long history with Resource Conservation and Recovery Act (RCRA) compliance related to the liquid, solid waste and coal combustion residuals (CCR) industry, including active-life/post-closure care. He has extensive experience in landfill permitting, groundwater compliance monitoring and remediation and landfill construction and operation. He also served as a program manager for a regional liquid and solid waste management firm where he was responsible for implementing groundwater protection and compliance programs for over 12 TSDFs across the U.S. Graham has served on several technical committees providing advocacy and industry perspective during development of solid waste rules in response to RCRA Subtitle D. His extensive background in solid waste compliance; groundwater data management; investigation; reporting; and remediation for municipal, industrial and CCR waste disposal facilities brings value to the effective management of groundwater and remediation-related issues resulting from their disposal. He also has decades of contaminant investigation and remediation experience focused on recalcitrant solvent contamination, and metals. Graham also provides litigation support services, including expert and fact witness for TRC’s clients.

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Sarah Holmstrom

Sarah Holmstrom, P.G., is a Senior Hydrogeologist and Project Manager in TRC’s Engineering, Construction, and Remediation practice. She has nearly 20 years of experience in regulatory compliance, focused heavily on the Federal Coal Combustion Residuals (CCR) Rule, Resource Conservation and Recovery Act (RCRA) Solid Waste, Michigan Part 115 solid waste and Part 201 remediation programs, serving as co-lead to TRC’s National CCR Program focused on advancing technical expertise across the TRC organization. She specializes in site characterization, hydrogeological investigations, conceptual site model (CSM) development, RCRA groundwater monitoring programs, risk-based corrective actions, and regulatory support. Contact Sarah at sholmstrom@trccompanies.com

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Greg Tieman

Greg Tieman has 40 years of professional experience in the environmental consulting industry, and has been with TRC for over 11 years. He currently serves as a Senior Client Services Manager/ coal combustion residuals (CCR) Subject Matter Expert (SME) in the Engineering, Construction, and Remediation practice for TRC. He also serves as a Project Manager/ Senior Hydrogeologist for TRC's governmental, commercial, and industrial clients under various State risk-based voluntary remediation programs. Greg has a long history with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Toxic Substances Control Act (TSCA) to address PCB assessment and cleanup issues, and the Resource Conservation and Recovery Act (RCRA) related to solid waste and CCR management, including active facility operations, closure, and post-closure care. Greg also has a long history with State Leaking Underground Storage Tank (LUST) programs. He has extensive experience in solid and hazardous waste landfill permitting and design, groundwater monitoring and remediation, and landfill construction and operation. His extensive background in solid and hazardous waste compliance; soil and groundwater investigation; reporting; and remediation for municipal, commercial, industrial, and CCR waste disposal facilities brings value to the effective management of groundwater and remediation-related issues resulting from their disposal.