Challenge
An electric utility had managed their coal ash, or coal combustion residuals (CCRs) for decades through beneficial use and disposal in state-regulated landfills and ash ponds. In 2015, the U.S. EPA released a final rule regulating CCRs from electric utilities under Subtitle D of the Resource Conservation and Recovery Act (Rule). The Rule finalized national regulations to provide a comprehensive set of requirements for the safe disposal of CCRs. The client had established a program to meet the Rule, but in 2022 they were seeking a third party to verify they were meeting their compliance obligations and adequately managing their risk and approached TRC for assistance with this task.
Solution
TRC established an audit approach that aligned our national CCR experts, including engineers, scientists, and geologists that routinely manage and remediate CCR sites, with our national environmental, health and safety audit experts to evaluate the client’s practices for management of its CCR compliance obligations and risks.
The audit approach involved:
- Reviewing and evaluating the company’s external-facing CCR website to understand the client’s management of its CCR units and to verify compliance obligations to share information with the public.
- Securing objective evidence through interviews with client corporate staff, site environmental compliance and contracted staff, review of documents and records, and observations of site operations to verify the client’s compliance and potential gaps with CCR federal and state regulations.
- Presenting to the client’s staff on their good management practices, regulatory compliance gaps, and proposed corrective actions to close the gaps and address root causes.
- Coordinating with the client to incorporate corrective actions into the client’s tracking system, resulting in findings being assigned and tracked to closure.
Results
The client gained a deeper understanding of the Rule, environmental risks and underlying causes. With this understanding, the client has implemented improvements to its CCR management systems and procedures to consistently maintain its regulatory compliance, and control and minimize its environmental risks.