Review of the Long Term Environmental Recovery Plan for Kingston

Marshall Miller & Associates, Inc. (Marshall Miller) was engaged by the Tennessee Valley Authority (TVA) Office of Inspector General to review the adequacy and completeness of environmental recovery plans prepared by TVA in response to the ash spill that occurred on December 22, 2008, at the Kingston Fossil Plant (KIF). Generally, Marshall Miller found no significant deficiencies in any of the proposed alternatives for the restoration of the Swan Pond Embayment, including the selected alternative. The documents prepared by TVA appear to be substantially in compliance with applicable regulatory requirements stated in the Administrative Order and Agreement on Consent between TVA and the United States Environmental Protection Agency (EPA) and meet the removal action objectives outlined in the Non-Time Critical Removal Action Embayment/Dredge Cell Engineering Evaluation/Cost Analysis or as is more commonly known the EE/CA. There were some discrepancies noted in the Human Health Risk Assessment, with regard to certain selected input parameters, such as toxicity and exposure factors. However, since the selected alternative includes the removal of all ash, any risk associated with leaving the ash in place is reduced, and revisions to the risk assessment are not necessary. TVA has committed to incorporating the findings in future Human Health Risk Assessments. While Marshall Miller found no significant deficiencies in any of the proposed alternatives, the following observations were noted:Both the EE/CA and Non-Time Critical Removal Action Embayment/Dredge Cell Action Memorandum (Action Memorandum) are intended to provide only a conceptual design of each of the three alternatives. Since an alternative has been selected, a more detailed design will be needed, along with revised sampling plans for monitoring potential environmental impacts during excavation of the ash and closure of the Dredge Cell. Additionally, the EE/CA provides limited detail on the long-term monitoring of various media for potential environmental impacts.A more detailed understanding of groundwater flow and associated contaminant migration from the Dredge Cell to adjacent surface water is required in order to properly establish locations for long-term monitoring of wells.TVA management agreed with our findings and recommendations and plans to take or has taken corrective actions.