Review of the Environmental Sampling and Monitoring Plans for the Kingston Ash Spill

Marshall Miller & Associates, Inc. (Marshall Miller) was hired by the Office of Inspector General (OIG) to review the sampling and monitoring plans prepared by the Tennessee Valley Authority (TVA) for its Kingston Fossil Plant located in Harriman, Tennessee, following an ash release that occurred on December 22, 2008. Marshall Miller evaluated the adequacy and completeness of TVA's environmental recovery plans to determine whether these plans provide comprehensive and effective measures to adequately monitor the potential short- and long-term impacts to human and ecological receptors. The scope of the review included TVA's environmental recovery plans available through June 2010. In summary, Marshall Miller found no significant deficiencies in the plans or procedures used by TVA or its contractors in characterizing impacts resulting from the ash release or recovery efforts. It should be noted that the assessment of long-term impacts will be an ongoing process during and after the recovery effort.While Marshall Miller did not find any significant deficiencies, early in the recovery process some of the analytical results did not pass prescribed quality assurance/quality control standards, and the data were invalidated. When the deficiency was noted, TVA took appropriate steps to correct the situation, and it does not appear that any decisions regarding the clean-up efforts were affected by the data quality.Marshall Miller noted the following:Bureau Veritas Laboratories used an incorrect analytical method for particulate monitoring from September 2009 to January 2010. This resulted in the Environmental Protection Agency invalidating the Particulate Matter data.There has been limited research on how the ash and the metals associated with ash will affect the various organisms in the river system. Additional investigations by a variety of research organizations are underway, primarily in support of the River System Engineering Evaluation/Cost Assessment.Data from air testing for metals and groundwater testing are not readily available to the public.Due to "legacy" contaminants in the sediment in the lower 1.8 miles of the Emory River (associated with activities at the Oak Ridge National Laboratory) and the difficulty in removing the ash without distributing existing "legacy" and native river sediments, some ash will remain in the river after dredging is complete.TVA management provided additional information on the findings and recommendations in this report. Marshall Miller incorporated TVA management's comments into the report as appropriate and provided additional comments where needed. TVA agreed with Marshall Miller's recommendations and has taken or plans to take action based on the recommendations.