Review of Legacy Rule Changes & Implementation Strategies

The EPA will announce changes to the CCR Legacy Rule, with the Notice of Proposed Rule Making expected in early 2026. While the scope is not yet clear, possible updates include new closure requirements for CCR units, allowance of risk-based approaches, and possible removal of CCR Management Units from the regulation. This presentation will cover the proposed changes and utility owner actions. While the proposed Rule contents are unknown, it is anticipated that this presentation will include the following topics: • Rule change overview • Compliance strategies • Implementing risk-based approaches • Working with state regulators • Beneficial use and asset repurposing Topics will be tailored based on the changes outlined in the proposed Rule. This presentation will focus on helping utilities prepare for implementing the upcoming CCR Legacy Rule changes.