Authors: Graham Crockford, Sarah Holmstrom and Greg Tieman | juin 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 has over 32 years of experience in the fields of consulting, environmental engineering, geology, and hydrogeology. He currently serves as a Unit Leader for TRC’s Environmental, Construction, and Remediation business, where he drives TRC’s strategic direction to serve our client and business goals. With decades of experience working with legacy coal-fired power generation, his focus is also directed to support our clients achieve their renewable energy and decarbonization goals. In this role, he fosters the connection of various TRC disciplines, and also engages in quality assurance, quality control and client experience. He also serves as a Client Services Manager/Project Manager for TRC's utility and industrial clients. Graham has a long history with the liquid/solid waste/CCR industry, including active-life and post-closure care. He has extensive experience in landfill permitting, wetland mitigation, and construction/operations. He also served as a program manager for a regional waste management firm for 4 years where he was responsible for implementing groundwater protection and compliance programs for over 12 TSDFs across the US. In the early 1990s Graham served on Michigan Waste Industry Association's technical standards subcommittee providing advocacy and industry perspective during development of Michigan’s Part 115 Solid Waste statute/rules in response to Subtitle D. Contact him at gcrockford@trccompanies.com.
Sarah Holmstrom
Greg Tieman
Greg has over 30 years of experience in environmental consulting. His qualifications include extensive hands-on planning, field investigation and construction management, design, permitting, cost estimating, and project management. Greg’s background includes performing extensive services for coal-fired power plants in the southeastern United States and implementation of the Coal Combustion Residuals (CCR) Rule. He delivers services including regulatory support, strategic planning, hydrogeological investigations, feasibility studies, and preparation of Annual Groundwater Monitoring and Corrective Action reports and Alternative Source Demonstrations (ASDs). Contact Greg at GTieman@trccompanies.com.