Kingston Ash Release March 2009 <strong>Corrective</strong> <strong>Action</strong> <strong>Plan</strong> 2-17
Kingston Ash Release March 2009 <strong>Corrective</strong> <strong>Action</strong> <strong>Plan</strong> approach for defining the criteria that a data collection design should satisfy including: what, when, where, and how to collect samples or measurements along with the number of samples to collect. DQOs define the purpose of the data collection effort, clarify what the data should represent to satisfy this purpose, and specify the performance requirements for the quality of information to be obtained from the data. In summary, the DQO process defines what question the data is to answer to support a decision and ensures that the necessary information is collected to answer the question. Once additional data collection activities are defined, the collection locations, frequency, methods, and quality control procedures are documented in the sampling and analysis plan(s) (SAPs). The data are then collected. Some information has already been identified by the various entities as being necessary to support final decision making. Data Collection. It has been suggested that TVA use an approach similar to a Natural Resource Damage Assessment and Restoration process, with appropriate state and federal trustees, as one process for characterizing and evaluating the potential and extent of damage or injury to natural resources, to design long-term monitoring needs related to the event, and to determine adequate compensation and/or restoration for damaged or injured natural resources, including lost uses. This activity will be conducted as part of the risk assessment. Some suggested data collection activities that have come out of the need to assess the natural resource damages include continuing TVA’s existing Reservoir Fish Assemblage Index and Reservoir Index of Benthic Integrity surveys to provide long-term data that will document spill impacts and recovery of fish and other aquatic life by comparing post-spill data to pre-spill data. Likewise, continuing the existing fish tissue analysis by TWRA, (supplemented by samples and analyses by TVA, TDEC and ORNL) will document changes to baseline conditions including recovery for fish captured near the spill site. This includes understanding the existing Department of Energy (DOE) related sediment contamination that resulted in the fish consumption advisory for fish caught in the KIF area that was in place before the spill event. Studies are being considered that will help determine the impact of ash deposition on a variety of aquatic organisms that are found in sediments of reservoir habitats like those that were affected by the spill. This testing could include various life history stages of bottom-dwelling (benthic) organisms, including several common, reservoir-tolerant mussel species. Typical toxicity tests do not include mussels, but recent technology and techniques have been developed that permit more accurate characterization of spill-related impacts to mussels or other sensitive bottom-dwelling aquatic life. The possible movement of chemicals from aquatic to terrestrial wildlife resources has been well documented. TVA, in conjunction with TWRA, EPA, U.S. FWS, and third party toxicologists, would examine the available terrestrial animal resources that exist in the vicinity of KIF. The biologists and toxicologists would identify the appropriate wildlife species to examine and document any movement of chemicals from the fly ash through various wildlife trophic levels. Potential terrestrial wildlife resources that may be examined include great blue herons, cliff swallows, raccoons, belted kingfisher, woodland songbirds, and bats. In addition to assessing the natural resources impact, data or information may be needed to refine residual ash volumes; to support modeling of sediment transport processes to help determine the ultimate fate of ash swept downstream by high flows; and to assess potential future impacts to groundwater. This information will be combined with existing groundwater, surface water, air, and ecological data. 2-18