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Inspection and Maintenance of Coal Combustion Residual Storage Facilities

Report Information

Date Issued
Report Number
2025-17544
Report Type
Inspection / Evaluation
Description
In April 2015, the United States Environmental Protection Agency published the Disposal of Coal Combustion Residuals [CCR] from Electric Utilities (commonly referred to as the CCR Rule), which set forth national regulations for the safe disposal of coal ash from coal-fired power plants.  On May 8, 2024, the United States Environmental Protection Agency finalized changes to the CCR Rule to include additional classes of regulated CCR storage facilities.  The CCR Rule requires that applicable CCR units be inspected both weekly for any appearances of actual or potential structural weakness and annually to ensure that the design, construction, operation, and maintenance of the CCR unit is consistent with recognized engineering standards.  In addition, the CCR Rule requires monthly monitoring of all CCR unit instrumentation for surface impoundments.   We determined TVA performed required inspections and maintenance of CCR storage facilities.  Additionally, inspections identified no significant deficiencies, and all deficiencies and high priority instrumentation maintenance issues identified were resolved timely or had plans in place for resolution. However, we also determined (1) TVA did not maintain a comprehensive list of instrumentation requiring monitoring, (2) some issues were not identified in inspections and some instrumentation issues were not resolved, (3) remediation of minor issues identified during annual inspections was not documented, (4) annual inspection reports did not document review of weekly inspections, and (5) some inspectors did not have required training.
Joint Report
No
Agency Wide
Yes (agency-wide)
Questioned Costs
$0
Funds for Better Use
$0

Recommendations

We recommend the Senior Vice President, Generation Projects and Fleet Services, document the coal combustion residuals storage facility instrumentation requiring monthly monitoring under the Disposal of Coal Combustion Residuals from Electric Utilities (CCR Rule).

We recommend the Senior Vice President, Generation Projects and Fleet Services, confirm that instrumentation included in monthly and annual reports is accurate.

We recommend the Senior Vice President, Generation Projects and Fleet Services, reinforce the importance of identifying existing issues during weekly inspections.

We recommend the Senior Vice President, Generation Projects and Fleet Services, complete corrective actions on the unresolved instrumentation maintenance issues identified in monthly instrumentation monitoring reports.

We recommend the Senior Vice President, Generation Projects and Fleet Services, consider documenting the resolution of minor issues identified in annual inspections.