Review of TVA's Plans for Offsite Transportation and Disposal of Ash from Kingston

Marshall Miller & Associates, Inc. (Marshall Miller) was engaged by the Tennessee Valley Authority (TVA) Office of Inspector General to review the Transportation and Disposal Plans prepared by the Tennessee Valley Authority (TVA) in response to the ash release that occurred on December 22, 2008 at its Kingston Fossil Plant (KIF). Specifically, Marshall Miller was asked to determine if appropriate steps are being taken to minimize the environmental impacts and if regulatory requirements are being met. In summary, Marshall Miller found that TVA is taking appropriate steps to minimize the environmental impacts of transporting ash from KIF to the Arrowhead Landfill in Perry County, Alabama. Furthermore, no significant deficiencies in documents reviewed, regulatory requirements, or in the landfill operations were found. Marshall Miller found at the Arrowhead Landfill that the (1) ash removal and rail car wash systems and procedures appear to be adequate for minimizing the potential for residual ash to enter the nearby surface water, (2) storm water management practices appear to be effective for segregating and managing storm water runoff, (3) roads, work, and vegetated areas appear to be maintained such that sediment runoff is minimized, (4) surface water features in the immediate vicinity did not exhibit signs of excess sedimentation, debris build-up, or other potential adverse impacts that could be associated with a landfill, and (5) leachate management and disposal practices appear to minimize, to the extent practicable, the potential for off-site exposure from ash constituents.While Marshall Miller did not find significant deficiencies in the operation of the landfill, several areas were noted where improvements could be made. The Rail Yard and Landfill Best Management Practice Plans do not effectively describe and document the actual activities, procedures, equipment and operations that were observed during Marshall Miller's site visit on April 21, 2010. The Spill Prevention Control and Countermeasures Plans appear to provide adequate protection; however, the Plans do not include spill volume estimates for certain spill scenarios, discussion of secondary containment for mobile tankers, and locations for spill kits and equipment. Lastly, Marshall Miller noted one of the National Pollutant Discharge Elimination System discharge points is located at a point that could be affected by runoff from land that is not part of the landfill. This issue had already been identified and is currently being addressed by the landfill owner.TVA management agreed with the recommendations and we concur with their planned and completed actions.