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. U.S. Environmental Protection Agency	n-p-0173
I JO, % Office of Inspector General	March 23 2011
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At a Glance
Why We Did This Review
We initiated this review to
determine whether the U.S.
Environmental Protection
Agency (EPA) followed
accepted and standard
practices in determining that
coal combustion residuals
(CCRs) are safe for the
beneficial uses it had promoted
on its Coal Combustion
Products Partnership (C2P2)
program website.
Background
CCRs are generated from
burning coal. More than
136 million tons of CCRs were
generated in 2008. EPA
defines beneficial use of CCRs
as one that provides a
functional benefit, replaces the
use of an alternative material,
conserves natural resources,
and meets relevant product
specifications and regulatory
standards. Beneficial uses of
CCRs include concrete
manufacture or soil
enhancement, among others.
For further information,
contact our Office of
Congressional, Public Affairs
and Management at
(202) 566-2391.
The full report is at:
www.epa.aov/oia/reports/2011/
20110323-11 -P-0173.pdf
Catalyst for Improving the Environment
EPA Promoted the Use of Coal Ash Products
With Incomplete Risk Information
What We Found
EPA did not follow accepted and standard practices in determining the safety of
the 15 categories of CCR beneficial uses it promoted through the C2P2 program.
EPA's application of risk assessment, risk screening, and leachate testing and
modeling was significantly limited in scope and applicability. Without proper
protections, CCR contaminants can leach into ground water and migrate to
drinking water sources, posing significant public health concerns.
EPA officials told us they relied on individual state beneficial use programs to
review and approve specific CCR beneficial uses, and to manage associated risks.
EPA established, but did not implement, plans in 2005 to identify environmentally
safe and beneficial use practices. Had EPA implemented its plans, it may have
known earlier about risks from large-scale disposal of CCRs described as
beneficial use.
EPA documented these risks in damage cases presented in its June 2010 proposed
rule to regulate certain CCRs. EPA stated in the proposed rule that certain uses of
CCRs, in sand and gravel pits as well as large-scale fill operations, represent
disposal rather than beneficial use. After release of its proposed rule, EPA stopped
promoting beneficial uses of CCRs through the C2P2 program. Further, in response
to a recommendation from the OIG, EPA removed access to the C2P2 website.
In the proposed rule, EPA sought public comment on approaches for regulating
CCRs, to include information and data on beneficial uses, particularly
unencapsulated uses that may present a risk to human health and the environment.
Such information will help EPA make informed decisions about safe beneficial
use of CCRs. EPA should also have a sound process for evaluating and analyzing
risk information that forms the basis of Agency promotions on safe beneficial use
of CCRs.
What We Recommend
We recommend that EPA define and implement risk evaluation practices for
beneficial uses of CCRs, and that it determine if further action is warranted to
address historical CCR structural fill applications. EPA agreed with these
recommendations, which were revised in response to EPA suggestions. In its final
response to this report, EPA should describe its specific corrective actions to
address the recommendations and provide estimated completion dates for these
actions.

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