TVA Allen Fossil Plant Remedial Investigation Work Plan

Transcription

1 TVA Allen Fossil Plant Remedial Investigation Work Plan Tennessee Valley Authority Allen Fossil Plant Memphis, Tennessee Prepared for: Tennessee Valley Authority Chattanooga, Tennessee Prepared by: Stantec Consulting Services Inc Guion Road, Suite B Indianapolis, IN September 15, 2017

2 Sign-off Sheet This document entitled TVA Allen Fossil Plant Remedial Investigation Work Plan was prepared by Stantec Consulting Services Inc. ( Stantec ) for the account of TVA (the Client ). Any reliance on this document by any third party is strictly prohibited. The material in it reflects Stantec s professional judgment in light of the scope, schedule and other limitations stated in the document and in the contract between Stantec and the Client. The opinions in the document are based on conditions and information existing at the time the document was published and do not take into account any subsequent changes. In preparing the document, Stantec did not verify information supplied to it by others. Any use which a third party makes of this document is the responsibility of such third party. Such third party agrees that Stantec shall not be responsible for costs or damages of any kind, if any, suffered by it or any other third party as a result of decisions made or actions taken based on this document. Prepared by Matthew J. Dagon (signature) Reviewed by Luisa Price (signature) Approved by John W. McInnes (signature)

3 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Table of Contents September 15, 2017 Table of Contents EXECUTIVE SUMMARY... iv 1.0 INTRODUCTION SITE BACKGROUND SITE DESCRIPTION SITE OPERATIONAL HISTORY ONGOING SITE INVESTIGATION USE OF COOLING WATER WELLS INSTALLED INTO THE MEMPHIS SAND AQUIFER CHARACTERIZATION OF ENVIRONMENTAL SETTING GEOGRAPHY CLIMATE DEMOGRAPHY GEOLOGY AND SOILS GROUNDWATER SURFACE WATER AND SEDIMENTS Mississippi River McKellar Lake ECOLOGY Vegetation Wildlife Aquatic Ecology Threatened and Endangered Species Wetlands SITE CONCEPTUAL MODEL SOURCE AREAS HYDROGEOLOGY SITE RELATED CHEMICALS SITE DATA NEEDS DATA QUALITY OBJECTIVES PHYSICAL CHARACTERIZATION ACTIVITIES Initial Direct Push Technology Investigation Additional Direct Push Technology Investigation Additional Investigation of Sewer Line Monitoring Well Installation Groundwater Sampling Stratigraphic Soil Borings ii

4 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Table of Contents September 15, Groundwater Modeling SAMPLING AND ANALYTICAL REQUIREMENTS DATA EVALUATION AND INTERPRETATION RI REPORT FORMAT SCHEDULE REFERENCES LIST OF FIGURES FIGURE 1 FIGURE 2 FIGURE 3 FIGURE 4 FIGURE 5 FIGURE 6 FIGURE 7 Site Location Aerial Map Allen Fossil Plant DPT Sampling Locations Proposed Monitoring Well Locations Conceptual Cross-Section Proposed Stratigraphic Boring Locations ALF Remedial Investigation Schedule LIST OF TABLES TABLE 1 TABLE 2 TABLE 3 Monitoring Well Construction Summary Proposed Monitoring Well Locations, Descriptions and Rationale Monitoring Well Network Summary LIST OF APPENDICES Sampling and Analysis Plan Quality Assurance Project Plan Site-Specific Health and Safety Plan Data Management Plan UM-USGS Groundwater Investigation Proposal iii

5 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Acronyms September 15, 2017 Executive Summary Groundwater monitoring wells proximal to the East Ash Disposal Area at the Allen Fossil Plant (ALF) were sampled and have detections of arsenic, lead and fluoride at concentrations above the United States Environmental Protection Agency (U.S. EPA) Maximum Contaminant Level (MCL). In response, the Tennessee Department of Environment and Conservation (TDEC) issued a letter dated July 18, 2017 requesting that the Tennessee Valley Authority (TVA) develop a Remedial Investigation (RI) Work Plan. This work plan was originally submitted to TDEC on August 18, Between September 5 and 15, 2017 TDEC provided their comments to the work plan, and this version reflects revisions made in response to those comments. The objectives of the RI Work Plan include the following: 1) Source area identification and delineation of Coal Combustion Residual (CCR) constituents as listed in Appendices III and IV in the U.S. EPA CCR Regulations, including arsenic, lead, and fluoride, in the subsurface soils; 2) Complete horizontal and vertical delineation of the groundwater contaminant plume(s) for CCR constituents, including arsenic, lead, and fluoride, in the Fluvial Aquifer beneath the Site through the installation and sampling of permanent monitoring wells; 3) Characterization of the Fluvial Aquifer with a network of shallow, intermediate, and deep permanent monitoring wells that will provide monitoring points for the future observation of groundwater quality and elevations at three depths within the Fluvial Aquifer. The monitoring well network will be used to evaluate the effects of operating nearby production wells installed in the Memphis Sand Aquifer; and 4) Completion of a three-dimensional groundwater flow and transport model for the site to evaluate groundwater flow and transport of CCR constituents in the Fluvial Aquifer under current conditions, as well as future conditions that may develop as a result of pumping from the Memphis Sand Aquifer. This Work Plan presents rationale and procedures to conduct the following: A screening level investigation to initially evaluate vertical and horizontal distribution of constituents of concern (CoCs) proximal to ALF-202, ALF-203, and within the western half of the East Ash Disposal Area; Installation and sampling of monitoring wells screened in the shallow, intermediate, and deep portions of the Fluvial Aquifer; Evaluation of horizontal and vertical gradients within the Fluvial Aquifer; iv

6 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Acronyms September 15, 2017 Measurement of hydraulic conductivity within the Fluvial Aquifer and underlying confining unit; and A plan from the U.S. Geological Survey to assess the potential for interaction between the Fluvial Aquifer and the Memphis Sand Aquifer (i.e., local drinking water resource) due to proposed operation of pumping wells at the Allen Combined Cycle Plant. v

7 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Acronyms September 15, 2017 Acronyms ACC Allen Combined Cycle Plant ALF Allen Fossil Plant ASTM American Society for Testing and Materials CAESER Center for Applied Earth Science and Engineering Research CCR Coal Combustion Residual CFR Code of Federal Regulations CoC Constituents of Concern DO Dissolved Oxygen DPT Direct Push Technology DQOs Data Quality Objectives GPS Global Positioning System GW Groundwater MCLs Maximum Contaminant Levels MERAS Mississippi Embayment Regional Aquifer System MLGW Memphis Light, Gas and Water Division vi

8 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Acronyms September 15, 2017 MRVA Memphis River Valley Alluvial NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System NTUs Nephelometric Turbidity Units ORP Oxidation-reduction potential Pace Pace Analytical Services, LLC PCBs Polychlorinated biphenyls ph Negative log of hydrogen concentration QA/QC Quality Assurance/Quality Control QAPP Quality Assurance Project Plan RI Remedial Investigation S.U. Standard Units SAP Sampling and Analysis Plan SPLP Synthetic Precipitation Leaching Procedure TCLP Toxicity Characteristic Leaching Procedure vii

9 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Acronyms September 15, 2017 TDEC Tennessee Department of Environment and Conservation TVA Tennessee Valley Authority µg/l Micrograms per Liter USACE United States Army Corps of Engineers USCS Unified Soil Classification System U.S. EPA United States Environmental Protection Agency USGS United States Geological Survey viii

10 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Introduction September 15, INTRODUCTION In response to the Tennessee Department of Environment and Conservation (TDEC) letter dated July 18, 2017, the Tennessee Valley Authority (TVA) has developed this Remedial Investigation (RI) Work Plan to characterize groundwater quality near the East Ash Disposal Area at the Allen Fossil Plant (ALF). This work plan was originally submitted to TDEC on August 18, Between September 5 and 15, 2017, TDEC provided their comments to the work plan, and this version reflects revisions made in response to those comments. The site location and surrounding area is presented on Figure 1. Site features are presented on Figure 2. The objectives of the RI Work Plan as specified in the TDEC letter dated July 18, 2017 include the following: 1) Source area identification and delineation of Coal Combustion Residual (CCR) constituents as listed in Appendices III & IV in the United States Environmental Protection Agency (U.S. EPA) CCR Regulations, including arsenic, lead, and fluoride, in the subsurface soils which are thought to be impacting shallow groundwater in the vicinity of the East Ash Disposal Area at the Site; 2) Complete horizontal and vertical delineation of the groundwater contaminant plume(s) for CCR constituents, including arsenic, lead, and fluoride, in the Fluvial Aquifer beneath the Site, through the installation and sampling of permanent monitoring wells; 3) Characterization of the Fluvial Aquifer with a network of shallow, intermediate, and deep permanent monitoring wells that will provide monitoring points for the future observation of potential contaminant migration in the shallow aquifer, as well as from the shallow aquifer to the deeper portions of the Fluvial Aquifer. The monitoring well network should be able to detect any changes in the constituent distribution and flow gradients once the Memphis Sand Aquifer production well operations begin; and 4) Completion of a three-dimensional groundwater flow and transport model for the Site to evaluate groundwater flow and contaminant migration in the Fluvial Aquifer under current conditions, as well as future conditions that may develop as a result of pumping from the Memphis Sand Aquifer. Groundwater extraction from the three TVA Memphis Sand production wells should be incorporated in the model at the various anticipated production rates. At a minimum, modeling shall be conducted for a ground water withdrawal rate of 3,000,000 gallon/day and a 5,000,000 gallon/day withdrawal rate. The model should be suitable for evaluating impacts from source contamination to the Fluvial Aquifer, potential contaminant migration pathways from the source area, potential water quality impacts to the Memphis Sand Aquifer, and ultimately the possibility of contaminant migration to potential wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 1.1

11 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Introduction September 15, 2017 receptors, via shallow migration or Memphis Light, Gas and Water Division (MLGW) wellfield impacts. Quality assurance and data quality objectives for this RI Work Plan are discussed in Section 5.1 below and in the Sampling and Analysis Plan (SAP) (Appendix A) and Quality Assurance Project Plan (QAPP) and QAPP Addendum 1 (Appendix B). wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 1.2

12 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Background September 15, SITE BACKGROUND 2.1 SITE DESCRIPTION ALF is a TVA coal-fired power plant located in Shelby County, southwest of the City of Memphis, Tennessee. ALF is located on the south shore of McKellar Lake, on the eastern bank of the Mississippi River (Figure 1) adjacent to a United States Army Corps of Engineers (USACE) floodcontrol levee. The local topography above the riverbank is relatively level except for the USACE levee and the CCR facility dikes, which rise approximately 20 to 25 feet above the surrounding land. Figure 2 shows the location of ALF and the TVA; Memphis Light, Gas and Water Division (MLGW); City of Memphis; and Shelby County property boundaries. Portions of CCR facilities are located on property that is leased from MLGW, City of Memphis and Shelby County. The property located southwest of ALF is occupied by the City of Memphis wastewater treatment plant. ALF contains two ash disposal areas, the East Ash Disposal Area and the West Ash Disposal Area (Figure 2). The East Ash Disposal Area is located to the east of the coal yard and combustion turbines. The USACE levee forms the north dike of the impoundment. The East Ash Disposal Area is an active impoundment and is subject to the CCR Rule. CCR and plant process flows discharge to the East Ash Disposal Area. The East Ash Disposal Area is permitted as a single wastewater treatment system and discharges to McKellar Lake, under a National Pollutant Discharge Elimination System (NPDES) permit. The West Ash Disposal Area is located to the west of the powerhouse and no longer accepts CCRs, though it continues to be a NPDES regulated unit. The USACE levee forms the south dike of the pond. The West Ash Disposal Area is inactive and exempt from CCR Rule. The West Ash Disposal Area was historically utilized for intermittent CCR disposal during maintenance and has not received CCR materials since Impoundment closure planning is currently in progress for the West Ash Disposal Area. 2.2 SITE OPERATIONAL HISTORY ALF was constructed in 1959 by MLGW and consisted of three coal-fired generating units. TVA began leasing the plant in 1965 and purchased it in From 1968 through 1978 several improvements were completed at ALF, including raising the dikes and redeveloping the original West and East Ash Disposal Areas. In 1978, plant discharges to the West Ash Disposal Area were ceased. After TVA purchased ALF in 1984, ash was excavated from the East and West Ash Disposal Areas for beneficial reuse by USACE from 1991 to There is no known documentation of specifically how the USACE beneficially re-used the ash. When the East Ash Disposal Area was taken off-line during excavation activities, the West Ash Disposal Area was re-opened and began receiving sluiced ash in In 1992, after excavation activities were completed, the East Ash wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 2.1

13 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Background September 15, 2017 Disposal Area was re-activated and the West Ash Disposal Area no longer received sluiced ash (TVA 1993). The East Ash Disposal Area dredge cell and diversion trench were constructed in January In 2015, the West Ash Disposal Area was retrofitted to no longer receive flows and does not impound water. The East Ash Disposal Area is scheduled to cease receiving CCR in ONGOING SITE INVESTIGATION TVA is currently in the process of conducting environmental investigations of the East Ash Disposal Area. A screening level investigation was initiated on July 6, 2017 to evaluate groundwater conditions proximal to ALF-202 and ALF-203 and to evaluate pore water conditions within the East Ash Disposal Area. This investigation has also included measurement of field parameters (e.g., ph, ORP, conductivity, temperature) in water from McKellar Lake. Additional details pertaining to this screening level investigation are presented in Section Concurrently, TVA has also initiated installation of the deep monitoring wells ( A wells) as discussed in Section The results of both investigations summarized above will be presented in the RI Report. 2.4 USE OF COOLING WATER WELLS INSTALLED INTO THE MEMPHIS SAND AQUIFER TVA received a letter from TDEC dated August 7, 2017 that requested supplemental information regarding use of the cooling water wells at the Allen Combined Cycle Plant (ACC). This letter included four questions and requested responses as part of this RI Work Plan. The following provides TVA s response to the questions posed in the August 7, 2017 letter: 1. Assuming the TVA ALF ground water investigation demonstrates that operation of the new facility will not affect the Memphis Sands aquifer, how many months will the Natural Gas Combined Cycle power plant be in test mode before full start-up? TVA s Response: Commissioning, i.e., testing, of ACC is expected to take up to 6 months and is scheduled to begin in September The plant would be available for commercial operation beginning CY Does TVA have plans in place for an alternative source of cooling water should TVA not be able to use the cooling water wells installed into the Memphis Sands? TVA s Response: ACC maximum total water need is approximately 5,300 gallons per minute (gpm). MLGW can supply 3,500 gpm continuously. Therefore, TVA would be required to find and develop other sources of water. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 2.2

14 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Background September 15, How much cooling water will be used daily for operation of the Natural Gas Combined Cycle power plant at routine power generation levels and peak generation levels? TVA s Response: Depending on ambient conditions, a routine day would be between 3 million gallons per day (mgd) and 4 mgd. On an extremely hot day, the peak cooling water need is expected to be approximately 5 to 5.5 mgd. 4. When does TVA anticipate that the coal-fired units at TVA ALF will be permanently removed from service? TVA s Response: At present, TVA anticipates removing the coal-fired units at ALF from service by December 31, wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 2.3

15 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Characterization of Environmental Setting September 15, CHARACTERIZATION OF ENVIRONMENTAL SETTING 3.1 GEOGRAPHY The ALF site is approximately 225 feet above mean sea level. Property topography is generally flat. Regional topography slopes towards McKellar Lake to the north and the Mississippi River to the west. The property is in Township 5 North, Range 9E of Shelby County Tennessee. 3.2 CLIMATE Precipitation in the Memphis area averages 49.1 inches per year. On average, there are 218 sunny days per year in Memphis, Tennessee, and there are 74 days per year with measurable precipitation. The 24-hour average temperatures for the City of Memphis range from a low of 53 F to a high of 72 F. The annual average high is around 91 F in July and the annual average low is 31 F in January (NOAA 2017). 3.3 DEMOGRAPHY According to the 2010 U.S. Census Bureau, there were 927,644 people, 350,971 households, and 231,407 families residing in Shelby County. The population density was 1,215.5 people per square mile and there were 398,274 housing units at an average density of per square mile. 3.4 GEOLOGY AND SOILS The Allen Fossil Plant is in the extreme southwestern corner of Tennessee just west of the City of Memphis. The plant is situated on the south shore of McKellar Lake and the eastern bank of the Mississippi River, on top of the Mississippi Embayment, in the Mississippi Alluvial Plain section of the Gulf Coast Coastal Plain. Geologic mapping shows the site to be underlain by artificial fills and Quaternary age alluvial deposits. The fill is noted to generally consist of alluvium dredged from the floodplain (or loess in select locations) and range in thickness from a few feet beneath residential areas to tens of feet beneath industrial areas in the floodplain of the river. The alluvial materials are described as consisting of irregular lenses of fine sand, silt, and clay in the upper part and coarse sands, gravelly sands, and sandy gravels in the lower part. The alluvium varies from about 45 feet to 90 feet in thickness adjacent to the loess bluffs along the eastern edge of the Geologic Map of the Tennessee Portion of the Fletcher Lake Quadrangle, Tennessee (Parks 1978) to as much as 175 feet well out in the floodplain. The mapping indicates the alluvium is underlain by the series of highly consolidated clays and dense sands comprising the Jackson-Claiborne confining layer. The Jackson-Claiborne unit ranges in thickness from approximately zero to 360 feet in the Memphis urban area and is underlain by the Memphis Sand Aquifer (Graham and Parks 1986). Near ALF, the Jackson-Claiborne unit is estimated to range in thickness from approximately 60 to 100 feet. South of ALF near the Davis well field area, the confining unit thickness ranges from wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 3.1

16 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Characterization of Environmental Setting September 15, 2017 zero to 185 feet (Parks, et.al., 1995). The Memphis Sand Aquifer is characterized by predominantly sand with lenses of fine grained material and ranges in thickness from 400 to 890 feet. 3.5 GROUNDWATER Groundwater monitoring in the Fluvial Aquifer (also known as the alluvial aquifer) is currently in progress at ALF. The Fluvial Aquifer is separated from the underlying Memphis Sand Aquifer by the Jackson-Claiborne confining layer. The groundwater levels in the Fluvial Aquifer fluctuate up to 30 feet and are influenced water levels of the adjacent Lake McKellar, which are driven by seasonal fluctuations in the Mississippi River. Recharge to the Fluvial Aquifer is primarily by rainfall and periodically by rivers and streams during periods of high river levels. Typically, groundwater flows in a northerly direction towards Lake McKellar, although the Mississippi River does have the capacity to contribute reverse flow during seasonal elevated stages. The groundwater sampling list includes constituents listed in Title 40 of the Code of Federal Regulations Part 257 (40 CFR Part 257), Appendices III and IV, and Appendix I of TN Rule Analytical results indicate that arsenic was detected at concentrations greater than the U.S. EPA and TDEC MCL of 10 micrograms per liter (µg/l) in groundwater samples collected from the top 50 feet of the upper alluvial aquifer in six monitoring wells; ALF-202, ALF-203, ALF-204, ALF- 210, ALF-212 and ALF-213. Lead and fluoride were also detected in the groundwater samples collected from ALF-203 at concentrations greater than MCLs. Current information indicates that the Fluvial Aquifer is not used as a drinking water source near ALF. Memphis obtains its water supply from a series of well fields that withdraw water from the Memphis Sand Aquifer, which is the primary drinking water source in the surrounding area, including portions of eastern Arkansas and northern Mississippi. The Memphis Sand Aquifer is the most productive aquifer in the region, providing approximately 98 percent of the total pumpage to the City of Memphis in 1980 (Brahana and Broshears 2001), and it remains the primary supply in the area. The top of the Memphis Sand Aquifer is approximately 220 feet below surface grade in the vicinity of ALF. 3.6 SURFACE WATER AND SEDIMENTS Mississippi River ALF is located approximately 2.1 miles east of the Mississippi River on the south shore of McKellar Lake, located on the eastern bank of the Mississippi River. Mississippi River elevations fluctuate by approximately 30 to 40 feet from rainfall events in the Mississippi, Ohio, and Missouri river basins. Groundwater elevation at ALF varies widely, corresponding to these fluctuations in the Mississippi River level. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 3.2

17 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Characterization of Environmental Setting September 15, McKellar Lake The ALF plant is situated on McKellar Lake, which is also known as the Tennessee Chute. The lake is an artificial cut-off meander of the Mississippi River. The lake was created as a deep-water harbor for the City of Memphis, with the construction of a levee connecting President s Island to the mainland, beginning in TVA is authorized to discharge water from the East Ash Disposal Area to McKellar Lake under a NPDES permit. Dredged material obtained from excavation of McKellar Lake was used as fill under portions of ALF. Due to the proximity of McKellar Lake to ALF, groundwater elevations fluctuate with the water level in McKellar Lake. ALF is located within the Horn Lake-Nonconnah watershed and adjacent to McKellar Lake to the north. There are water quality concerns in many of the stream segments in the Horn Lake-Nonconnah watershed. McKellar Lake is part of this watershed. McKellar Lake is listed by TDEC to contain polychlorinated biphenyls (PCBs), dioxins and chlordane from contaminated sediments. It is also listed for Escherichia coli, low dissolved oxygen, Nitrate + Nitrite, and sedimentation/siltation from sanitary sewer overflows and discharges from municipal separate storm sewer systems. The nearby Mississippi River and the Horn Lake cutoff are generally listed for similar pollutants from similar sources (TDEC 2017). McKellar Lake is currently not meeting any of its designated uses; industrial water supply, agricultural water supply, aquatic habitat, or recreational use. Water quality data for McKellar Lake and its major tributary creeks indicate present day and historical impacts from organic chemicals and inorganic chemicals including arsenic. The Tennessee Department of Natural Resources has issued fish consumption advisories for the first 1.8 miles of Nonconnah Creek upstream from McKellar Lake, and for the entirety of McKellar Lake for chlordane, other organic chemicals, and mercury (TDEC 2017). 3.7 ECOLOGY Vegetation Plant communities proximal to the site consist primarily of mowed turf grasses, sporadic trees (cottonwoods), and ruderal/early successional habitat consisting of nonnative weedy species. Land use/land cover analysis indicates that cultivated crops is the dominant land cover feature in the permanent and temporary use areas (TVA 2016) Wildlife Terrestrial habitat near ALF includes some scattered trees and forested areas along the north side of the maintained berm adjacent to the McKellar Lake. Limited areas with standing water from rainfall within the ash impoundment could provide seasonal habitat for a variety of amphibians and reptiles. Bullfrogs, cricket frogs, and American toads were encountered during previous field wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 3.3

18 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Characterization of Environmental Setting September 15, 2017 investigations at the facility. Cottonmouths and many species of water snakes may occur in riparian zones within bottomland forests. Bobcats, raccoons, coyotes, and deer also use these areas (TVA 2016) Aquatic Ecology TVA evaluated the fish community in McKellar Lake using electrofishing sampling in 1974, and cove rotenone sampling in 1979 and 1980 (TVA 1995). During the study, 45 species were collected across four samples; this includes 15 commercially valuable and 21 recreationally valuable species: Common centrarchid species present at ALF included black crappie, white crappie, bluegill, green sunfish, long ear sunfish, orange-spotted sunfish, and warmouth. Benthic invertivore species were dominated by freshwater drum, while gizzard shad was the dominant species by number and biomass. Top carnivore species present included white bass, yellow bass, striped bass spotted bass, largemouth bass, black crappie, white crappie, sauger, spotted gar, bowfin, black bullhead catfish, walleye, yellow bullhead catfish, channel catfish and flathead catfish (TVA 1995) Threatened and Endangered Species A review of the TVA Natural Heritage Database in September 2015 revealed the occurrence of several federal- and state-listed species within a 2-mile radius of ALF. Two federally listed species, the endangered Indiana bat and threatened northern long-eared bat, are known throughout the region and have the potential to occur near ALF. Within the two-mile vicinity around ALF, occurrence records exist for two additional federally listed species (interior least tern and piping plover), two state listed species (lark sparrow and Mississippi kite), and one species tracked by the Tennessee Natural Heritage Program (striped whitelip). The bald eagle, subject to protection under the Bald and Golden Eagle Protection Act, has been recorded in the area near ALF (TVA 2016). No federal- or state-listed aquatic species and no federal- or state-listed plant species (or designated critical habitats) have been documented within a two-mile vicinity of ALF. Additionally, no federally listed plant species are known to occur in Shelby County, Tennessee (TVA 2016) Wetlands The ALF facility is located within the Mississippi Alluvial Plain Ecoregion (Griffith, et al. 2001). Compared to middle and eastern Tennessee, wetlands near ALF are more common. Oak-hickory wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 3.4

19 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Characterization of Environmental Setting September 15, 2017 and southern floodplain forests are the natural vegetation types, although much of the forest cover has been removed for cropland. Some less-disturbed bottomland forest and cypress-gum swamp habitats remain. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 3.5

20 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Conceptual Model September 15, SITE CONCEPTUAL MODEL 4.1 SOURCE AREAS As discussed in the July 18, 2017 TDEC letter, performance of this RI was prompted by the detection of concentrations of arsenic, lead, and fluoride in shallow groundwater near the East Ash Disposal Area which are greater than MCLs. ALF is in a heavily industrialized area near Memphis; therefore, the role and contribution of other potential sources should be considered when characterizing the East Ash Disposal Area. Evaluation of existing data has suggested a connection between the presence of high ph in groundwater with the occurrence of the highest arsenic concentrations. Arsenic is less adsorbent at higher ph and therefore may exhibit higher concentrations in groundwater under elevated ph conditions (Shuhua yao, 2014). Therefore, the evaluation of source areas will focus on the source of arsenic and other CoCs and the source of high ph. The evaluation of the potential relationship between ph and observed arsenic concentrations in soil, pore water and groundwater is ongoing and will be further developed as part of the RI. Historical and current land uses and conditions that will also be evaluated include: 1. CCR related operations at the ALF site; 2. The potential for historical use of lead-arsenical pesticides in proximity to the East Ash Disposal Area; 3. Groundwater monitoring data for the T.E. Maxson South Wastewater Treatment Plant have documented consistent concentrations of arsenic higher than 200 µg/l in shallow alluvial groundwater since 1995; 4. Impacts to McKellar Lake from industries on President s Island; and 5. Sewer lines that transect the East Ash Disposal Area. Multiple sewer lines that service nearby industry transect the East Ash Disposal Area. The potential exists for one or more of these sewer lines to serve as a source or preferential pathway for CCR constituents or high ph waters. These sewer lines include the following: President s Island Force Main This force main sewer line flows across the East Ash Disposal Area from north to south from President s Island (north of McKellar Lake) and extends to the USACE levee, after which it is a gravity sewer to the 96-inch Interceptor, described below. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 4.1

21 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Conceptual Model September 15, inch Interceptor - This gravity sewer line flows from east to west along the southern margins of the East Ash Disposal Area, to the City of Memphis TE Maxson Wastewater Treatment Facility west of ALF. 60-inch Sewer (Abandoned) This gravity sewer line formerly flowed beneath the East Ash Disposal Area from east to west, and it historically discharged at the TE Maxson plant. The sewer was abandoned during the mid-1970s after the 96-inch Interceptor was put into operation. Stantec is collecting information related to each of these areas for use in determining the presence or absence of alternate sources of arsenic or high ph levels. Field investigations are also being conducted to evaluate potential sources as discussed in Section HYDROGEOLOGY The Fluvial Aquifer, which consists of interbedded sand, gravel, silt, and clay is underlain by the Jackson-Claiborne layer, which consists of clay, silt, sand, and lignite. The Jackson-Claiborne unit ranges in thickness from approximately zero to 360 feet in the Memphis urban area and is underlain by the Memphis Sand Aquifer. Near ALF, the Jackson-Claiborne unit is estimated to range in thickness from approximately 60 to 100 feet. South of ALF near the Davis well field area, the confining unit thickness ranges from zero to 185 feet (Parks, et.al., 1995). These deposits form an aquitard separating the Memphis Sand Aquifer from shallower groundwater and surface water. To further address the presence and thickness of the lower confining unit, TVA has proposed the advancement of four stratigraphic borings (refer to Section of the RI Work Plan). The Fluvial Aquifer extends from approximately 20 feet to 140 feet below ground surface and is primarily recharged through infiltration of rainwater. Recharge also occurs through infiltration of Mississippi River water at high river levels. Groundwater elevations at ALF vary seasonally by approximately 30 to 40 feet per year and are affected by fluctuations in the Mississippi River level. At ALF, the observed hydraulic gradient tends to be toward McKellar Lake; however, the gradient has been observed to reverse and flow to the south during periods of high river levels. The TVA Summary of Groundwater Data at Allen Fossil Plant, 1988 report estimates the horizontal and vertical velocities through this aquifer to range from to 0.08 centimeters per second (cm/sec) and to 0.06 cm/sec, respectively. That report estimates hydraulic conductivity for the alluvium to be between 0.1 to 0.35 cm/sec. The Fluvial Aquifer is not a major groundwater source in the Memphis area, reportedly due to the hardness and high iron content of the water and availability as a water source (Brahana and Broshears 2001). The deeper Memphis Sand Aquifer provides better quality groundwater and is a more available source of water. However, the Fluvial Aquifer may be used as a source of irrigation water in some areas. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 4.2

22 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Conceptual Model September 15, SITE RELATED CHEMICALS Groundwater sampling results for ALF indicated that concentrations of arsenic, lead and fluoride were detected above U.S. EPA and TDEC MCLs in the top 50 feet of the upper alluvial aquifer. Additional field sampling activities are proposed to collect soil and groundwater data as discussed in Section 5 to further refine the conceptual site model. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 4.3

23 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, SITE DATA NEEDS The goal of the RI is to evaluate the source of CoC impact observed in the Fluvial Aquifer and characterize the horizontal and vertical extent of CoCs proximal to the East Ash Disposal Area. Data obtained during the RI will be used to delineate the extent of CoCs (Appendix III and IV parameters for CCR constituents) and to determine whether additional investigation is warranted. The RI data will also be used to support a risk assessment, as needed. The RI SAP presents approaches and the rationale for sampling soils and groundwater at ALF. The groundwater investigation for the RI will use existing and newly installed monitoring wells. The existing monitoring wells are used to monitor conditions in the shallow portion of the Fluvial Aquifer. New monitoring wells will be installed where specified to monitor conditions in the intermediate and deep portions of the Fluvial Aquifer and determine if CoCs are present. This monitoring well network will also be used to: Conduct horizontal and vertical delineation of CoCs in the Fluvial Aquifer beneath ALF; Provide monitoring points for groundwater quality in the shallow, intermediate, and deep portions of the Fluvial Aquifer; Determine the scope and necessity of additional horizontal or vertical characterization; Evaluate vertical hydraulic gradients prior to and after the Memphis Sand Aquifer production wells commence operation; and Complete a three-dimensional groundwater flow and transport model for ALF to evaluate groundwater flow and transport of CCR constituents in the Fluvial Aquifer under current and future conditions. 5.1 DATA QUALITY OBJECTIVES The Data Quality Objectives (DQOs) process is a tool employed during the project planning stage to ensure that data generated from an investigation are appropriate and of sufficient quality to address the investigation objectives. The DQO process was considered in developing the RI-specific SAP to guide the data collection efforts for the East Ash Disposal Area. Quality Assurance/Quality Control QA/QC procedures applicable to investigative activities presented in the SAP and QAPP include: Field Documentation Record Keeping wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.1

24 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, 2017 Equipment Testing/Inspection, Calibration, and Maintenance Equipment Decontamination Assessments and Response Actions Reporting Specific quantitative acceptance criteria for analytical precision and accuracy for the matrices included in this investigation are presented in the QAPP. Section 4.0 of the QAPP provides additional details on the DQO process. Quality assurance and quality control objectives are covered in Section 6.0 of the SAP. Site investigation work will be conducted under an approved site-specific Health and Safety Plan (HASP) for the ALF facility (included as Appendix C). The HASP will be in accordance with TVA Safety policies and procedures. Each site worker will be responsible for following the HASP. Data generated during the RI will be managed in accordance with the Data Management Plan included in Appendix D. 5.2 PHYSICAL CHARACTERIZATION ACTIVITIES Initial Direct Push Technology Investigation On July 6, 2017, a screening level investigation was initiated to evaluate groundwater conditions proximal to ALF-202 and ALF-203 and to evaluate pore water conditions within the East Ash Disposal Area. This investigation was also intended to obtain data relevant to determining potential sources of the CoCs. As of the date of this work plan, the investigation was in progress. Therefore, the following section is intended to provide an overview of the scope and approach. Data generated during the screening level investigation will be reported as part of the RI. A total of 72 potential drilling locations were identified with the expectation that only a subset of these locations would be sampled (i.e., not all 72 locations will be drilled and sampled). The intent was to initiate borings in proximity to ALF-202 and ALF-203 and progress outward based on field screening of ph. Direct push technology (DPT) was used to conduct sample collection. The DPT locations are presented on Figure 3. Initial borings were conducted in proximity to monitoring wells ALF-202 and ALF-203, and subsequent borings progressed radially outward based on the results of field screening data. The goal was to generally define the area(s) of groundwater that exhibit ph greater than 7.5 Standard Units (S.U.) and to collect laboratory analytical data to further evaluate the extent of CoCs. The objectives of the DPT investigation were to: wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.2

25 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, 2017 Conduct a screening level vertical characterization of arsenic and ph in proximity to wells ALF-202 and ALF-203. This investigation included collection of groundwater samples at multiple depth intervals to evaluate field measurements of ph. Based on these measurements, groundwater samples were collected for laboratory analysis. Conduct a screening level horizontal characterization of arsenic and ph in proximity to wells ALF-202 and ALF-203. This investigation included collection of groundwater samples at multiple DPT locations to evaluate field measurements of ph. Based on these measurements, groundwater samples were collected for laboratory analysis. Evaluate pore water conditions within East Ash Disposal Area. DPT borings were advanced at various locations within the East Ash Disposal Area to facilitate the collection of pore water samples for analysis. Evaluate the potential for the existing active and abandoned sewer lines that transect the East Ash Disposal Area to serve either as a source or migration pathway for ph and other CoCs. Several of the DPT locations were positioned in proximity to these features to facilitate this assessment. Borings outside of the East Ash Disposal Area were advanced to a depth of 50 feet below ground surface. Borings advanced within the East Ash Disposal Area, were advanced to a depth of 25 feet below ground surface or the bottom of observed ash, whichever was shallower. Investigation locations are illustrated on Figure 3. Samples were collected at 5-foot intervals using a groundwater sample probe (e.g., SP22 or similar) and following the procedures presented in SAP. After completion, each borehole was filled with a high-solids bentonite slurry. Drilling rods were decontaminated between sampling locations. The locations of completed borings will be surveyed for horizontal and vertical control by survey grade global positioning system (GPS) device. Field and laboratory results from this phase will be mapped to illustrate the distribution and concentration or magnitude of observed constituents Additional Direct Push Technology Investigation As discussed during the August 24, 2017 meeting with TDEC, four additional boring locations are proposed within the accessible portions of the East Ash Disposal Area to facilitate additional sampling. The proposed investigation locations are provided in Figure 3. These sampling locations will include the collection of ash samples and pore water samples to be analyzed for Appendix III and Appendix IV constituents. Pore water sampling and analysis has been selected instead of TCLP or SPLP analysis because it represents the actual concentrations in environmental media rather than an artificially generated leachate. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.3

26 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, Additional Investigation of Sewer Line Six additional boring locations are proposed within the accessible portions of the East Ash Disposal Area along the active force main line to facilitate additional sampling. The proposed investigation locations are provided in Figure 3. The results of this investigation will be used to evaluate the potential for the sewer lines to serve as either sources or migration pathways. The locations selected were based on accessibility within the East Ash Disposal Area. If results from the source area investigation suggest that the sewer lines are serving as a source or migration route, additional investigation may be conducted at other accessible locations Monitoring Well Installation TVA has installed eight shallow groundwater monitoring wells around the East Ash Disposal Area (ALF-201 through ALF-206, ALF-212 and ALF-213) and one shallow well to the west (ALF-210). These wells are screened in the upper part of the Fluvial Aquifer. Well construction details are summarized in Table 1. Additional shallow, intermediate and deep wells will be installed to facilitate evaluation of the horizontal and vertical extent of CoCs and measure horizontal and vertical flow gradients within the Fluvial Aquifer. The approach is to install 18 additional monitoring wells (four shallow, six intermediate (B) and eight deep wells (A)): Shallow wells - Screened intervals shallower than 55-feet: P-4-S, ALF-214, ALF-215 and ALF Intermediate wells (B) - Screened intervals ranging between feet to feet: ALF- 201B through ALF-205B and ALF-214B. Deep wells (A) Screened intervals ranging between feet to feet depending on depth of the lower clay unit: ALF-201A through ALF-205A, ALF-210A, ALF-212A and ALF- 214A. Proposed monitoring well locations are shown on Figure 4. The number and location of wells was selected to characterize the areal distribution and potential variability of vertical hydraulic gradients across the site. The intermediate and deep monitoring wells will serve three purposes: 1) allow for the collection of vadose zone soil samples; 2) provide points to measure groundwater levels for evaluation of horizontal and vertical gradients and 3) provide groundwater investigation sampling locations. The screened intervals for the deep monitoring wells are proposed to be placed near the bottom of the Fluvial Aquifer and above the Jackson-Claiborne confining layer between the Fluvial Aquifer and the underlying Memphis Sands Aquifer. The vertical placement near the bottom of the Fluvial Aquifer was selected to provide a sampling point to characterize groundwater quality at the deepest part of the Fluvial Aquifer for evaluation of the potential for CCR parameters to migrate from the East Ash Disposal Area to the Memphis Sands Aquifer. If CCR parameters wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.4

27 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, 2017 attributable to the East Ash Disposal Area are detected in the deep monitoring wells, then additional remedial investigations may be conducted to evaluate the Memphis Sands Aquifer. Based on the information gathered as described above, additional monitoring wells may be needed to fully characterize groundwater. If additional wells are needed, TVA, in communication with TDEC, will install these wells to obtain additional groundwater information. Results of all investigations to characterize groundwater flow directions will be included and described in the RI Report. The general location description, screened interval and rationale for each monitoring well are summarized on Table 2. The proposed wells will supplement the existing monitoring wells. The existing monitoring wells have screened intervals shallower than 55-feet and will be designated as the shallow wells. Proposed shallow wells (i.e., P-4-S, ALF-214, ALF-215 and ALF-216) will be screened between approximately 15 and 55 feet. In addition, the six intermediate (B) monitoring wells will be screened between approximately 70 and 90 feet (approximately 30 feet below the bottom of the adjacent existing shallow well). The eight deep (A) monitoring wells will be screened between 110 and 165 feet. The deep well screened interval will be based on the depth that a lower confining clay unit is encountered. A conceptual cross-section figure was developed and is included as Figure 5. This conceptual cross-section will be revised as additional subsurface data and monitoring well construction information is generated. Monitoring wells discussed above will be incorporated into the RI monitoring well network. A summary of the East Ash Disposal Area monitoring well network is presented in Table 3. No intermediate or deep wells along the eastern perimeter of the East Ash Disposal Area are proposed at this time. Existing monitoring wells have either exhibited arsenic concentrations below the MCL (ALF-206) or results that vary between below the MCL and slightly above the MCL (ALF-212 and ALF-213). The scope and necessity of intermediate or deep monitoring wells in these locations will be determined based on the results from the monitoring wells installed as part of this RI Monitoring Well Installation Procedures The following section provides a discussion of monitoring well installation procedures to be employed during the RI. Installation of the deep and intermediate monitoring wells was initiated on July 26, 2017, and the procedures presented below have generally been followed during installation. Monitoring well soil borings will be continuously sampled during drilling to allow for visual logging of the materials encountered at each monitoring well location. Soils will be described in the field in accordance with the Unified Soil Classification System (USCS). Drilling and sampling activities will be performed under the direction of a Professional Geologist, licensed in the State of Tennessee, who has sufficient experience to execute the work. The drilling will be performed by a wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.5

28 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, 2017 licensed well driller in Tennessee and Shelby County Well Permits will be obtained prior to drilling. The well permits will be kept on-site with the driller at all times. The field geologist will prepare a written installation log for each well. The log will document lithology and depth, groundwater depth, well location, well materials, well depth, and depth interval for each backfill material. As requested in the July 18, 2017 TDEC letter, drilling and sampling methods and protocols are detailed in the SAP. Specifically, the following is included in the SAP: Section A description of the drilling methods to install the proposed monitoring wells; Section The construction method, casing materials and dimensions, screened intervals, and slot size; and Section The methods to develop proposed monitoring wells. Each new monitoring well will be developed a minimum of 24 hours after installation by a combination of bailing, surging, and pumping. Target turbidity values of less than or equal to 10 Nephelometric turbidity units (NTUs) will be utilized for the wells. If the target turbidity value cannot practically be achieved, then the achieved value will be documented along with the efforts made and a suspected reason for the result. Following installation, the monitoring wells will be surveyed by a surveyor licensed in the State of Tennessee Soil Sampling Soil sampling will be conducted in the vadose zone to characterize CoC concentrations above the Fluvial Aquifer. The RI Work Plan presented herein includes the installation of multiple monitoring wells to be located near the perimeter of the East Ash Disposal Area (reference Figure 4). Each of the borings for these monitoring wells will be continuously sampled to the terminus of the boring. Data will include a description of the lithology encountered with depth (as discussed in Section 5.2.2). Continuous sampling in this manner will allow for stratigraphic characterization and the collection and laboratory analysis of soil samples from the vadose zone. In the case of nested monitoring wells, only the deepest monitoring well in each location will be continuously sampled. At each of the monitoring well locations (single or cluster) illustrated on Figure 4, soil sampling will be conducted as follows: Soil borings will be advanced using a roto-sonic drill rig and continuously sampled in accordance with the SAP. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.6

29 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, 2017 Grab soil samples from discreet two-foot depth intervals will be collected for laboratory analysis. Samples will be selected from two or three depths from each location: o o o The shallowest interval exhibiting the presence of native soil; An intermediate depth sample (as determined by field observations); and, The deepest interval above the observed water table. Soil samples will be collected, handled, and transported in accordance with the SAP. Laboratory analysis will be conducted by Pace Analytical Laboratories, Inc. for CCR Parameters (as defined in Section 5.3 below). Laboratory analysis will be conducted in accordance with the methods and procedures specified in the QAPP. TVA proposes to use the results of the proposed sampling as the basis for determining the scope, necessity, and priority of additional vadose zone soil investigation Hydraulic Conductivity Evaluation To evaluate groundwater flow rates in the Fluvial Aquifer under current conditions and under future conditions that may develop because of pumping from the Memphis Sand Aquifer, hydraulic conductivity data will be collected at various depths in the Fluvial Aquifer and from the clay that separates the upper aquifer from the Memphis Sand Aquifer. The following will be completed to evaluate hydraulic conductivity and permeability: To evaluate horizontal hydraulic conductivity of the Fluvial Aquifer, slug testing will be performed in the monitoring wells identified on Table 2. Slug testing will be conducted in accordance with procedures presented in the SAP. To evaluate permeability of the clay layer beneath the Fluvial Aquifer, Shelby tube soil samples may be collected when possible from the terminus of each deep well boring. The intent of the Shelby tube sampling will be to collect samples of the fine-grained layer (presumably the Jackson-Claiborne layer) to be analyzed to estimate the hydraulic conductivity by ASTM D5084. Penetrations into the Jackson-Claiborne layer will be sealed with bentonite Potentiometric Surface and Gradient Evaluation Groundwater elevations from the shallow monitoring wells and staff gauge elevations from McKellar Lake will be collected to determine the horizontal gradient of the shallow portion of the Fluvial Aquifer. Groundwater elevations will also be collected from the intermediate and deep monitoring well networks to determine horizontal gradients in the intermediate and deep portions wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.7

30 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, 2017 of the Fluvial Aquifer as well as vertical gradients between the shallow, intermediate, and deep portions of the Fluvial Aquifer. Additional existing wells will be gauged for groundwater elevations to provide more a comprehensive evaluation of groundwater flow direction and gradients. The water levels in each monitoring well will be measured in relation to a surveyed reference point (e.g., top of well casing) using an electronic water level indicator. Groundwater elevation data will be measured and recorded in accordance with the SAP. Surface water elevations of McKellar Lake will be obtained from data maintained by the United States Geological Survey (USGS). The locations of the proposed wells were selected to evaluate the horizontal gradient and vertical gradient within the Fluvial Aquifer proximal to the East Ash Disposal Area. As discussed above, groundwater flow direction has been observed to vary approximately 180 degrees due to changing water levels in McKellar Lake. The proposed monitoring well network includes monitoring points both north and south of the East Ash Disposal Area so that wells are positioned downgradient regardless of the groundwater flow direction Groundwater Sampling Groundwater sampling will be conducted to evaluate the groundwater quality proximal to the East Ash Disposal Area. Following monitoring well installation and development, the groundwater monitoring well network will be sampled for the CCR Parameters as defined in Section 5.3 below. For geochemical evaluation, major cations/anions not included in the CCR Parameters are included in the analyses for this work plan. The additional geochemical parameters include magnesium, potassium, sodium, carbonate and bicarbonate. Field parameters, including ph, conductivity, temperature, oxidation-reduction potential (ORP), dissolved oxygen (DO) and ferrous iron, will be collected from each monitoring well to demonstrate stability and further assess the solubility of CCR constituents. Details on sampling procedures, analytical methods, preservation and handling are provided in Section 5.3 of the SAP. Arsenic speciation testing was conducted on nine wells (ALF-201, ALF-202, ALF-203, ALF-204, ALF-205, ALF-206, P-4, ALF-212, and ALF-213) during May/June Additional speciation testing will be conducted on 28 wells (P-4, P-4S, ALF-201, ALF-201A, ALF-201B, ALF-202, ALF-202A, ALF-202B, ALF-203, ALF-203A, ALF-203B, ALF-204, ALF-204A, ALF-204B, ALF-205, ALF-205A, ALF-205B, ALF-206, ALF-210, ALF-210A, ALF-212, ALF-212A, ALF-213, ALF-214, ALF-214A, ALF-214B, ALF-215, and ALF-216) during September The results of the arsenic speciation testing will be evaluated as part of the RI and provided to TDEC. Laboratory analysis will be conducted by Pace Analytical Laboratories, Inc. for CCR Parameters (as defined in Section 5.3 below). Laboratory analysis will be conducted in accordance with the methods and procedures specified in the QAPP. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.8

31 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, 2017 The proposed RI monitoring well network will be sampled for three consecutive months following installation. The scope, necessity, and schedule of additional groundwater monitoring will be determined based on the results of the initial three monthly sampling events. Subsequent monitoring events may be scheduled to coincide with McKellar Lake low/medium/high pool events. The groundwater monitoring analytical results will be used to determine whether additional characterization is required to determine horizontal and vertical extent of CoCs. In addition to the monitoring wells described above, there are two wells near the East Ash Disposal Area that are owned by Harsco. Reportedly, one well is used for ongoing Harsco operations and the second well is operated infrequently for irrigation. TVA will provide available well details and locations (as available) in the RI report. The operating Harsco well was sampled during performance of the DPT investigation and the results will be presented in the RI Report. This sample was analyzed for Appendix III and IV constituents. TVA s intent is to conduct similar sampling of the second Harsco well (identified above) assuming that access to do so is granted. The results of this sampling will be used as the basis to determine the scope and necessity of additional sampling of these wells. A potential seep (location is identified on Figure 3) was identified and sampled during the DPT investigation. The sample from this seep was analyzed for Appendix III and IV constituents and the results will be reported in the RI. The results of this sample will be used as the basis for determining the scope and necessity of additional sampling of this potential seep. In response to comments from TDEC, the ph of the water used in the ash sluicing process will be measured as it enters the eastern ash disposal area prior to any treatment or NPDES discharge. This sampling event will be conducted in coordination with the first monthly groundwater monitoring event. Procedures for ph measurement are presented in the SAP and QAPP Stratigraphic Soil Borings To evaluate the thickness and lateral continuity of the Jackson-Claiborne formation that separates the Fluvial Aquifer from the Memphis Sand Aquifer, stratigraphic data will be collected from four continuously sampled stratigraphic soil borings. The following will be completed: Four soil borings will be installed in the locations illustrated on Figure 6. Borings will be advanced to at least 10 feet into the Memphis sands (approximately 220 to 230 feet) to evaluate the thickness and continuity the Jackson-Claiborne Formation. Stratigraphic soil borings will be sealed with cement-bentonite grout mixture from the bottom of the borehole using Tremie methods in accordance with the procedures in the SAP. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.9

32 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, Groundwater Modeling In response to Objective 4 of the July 19, 2017 TDEC letter the USGS, in collaboration with the University of Memphis Center for Applied Earth Sciences and Engineering Research, has proposed an "Investigation of Groundwater Conditions at the Tennessee Valley Authority Allen Combined Cycle Plant, Memphis, Tennessee". This is presented as Appendix E. In response to comments from TDEC, USGS also prepared Proposal Addendum Work Plan for Test Pumping of new Production Wells at Tennessee Valley Authority Allen Combined Cycle Power Plant, Memphis, Tennessee which is included in Appendix E. The flow rates and duration for the pumping test are presented in Appendix E. It is recognized that the pumping tests must be conducted in compliance with TVAs existing plans and permits that regulate the volume and rate of water discharge. These include a City of Memphis Industrial Monitoring & Pretreatment Program Industrial Wastewater Discharge Permit (S-NO01-260) and a State of Tennessee National Pollutant Discharge Elimination System (NPDES) permit (TNR191505). In conjunction with the performance of this test, reasonable efforts will be made to identify nearby pumping wells in the fluvial aquifer (including the Harsco wells) and to take steps to minimize potential interference with the test due to the pumping of these wells. It is noted that TVA may not have the ability to control the pumping of wells it does not own. 5.3 SAMPLING AND ANALYTICAL REQUIREMENTS Soil and groundwater sampling procedures and analytical requirements are presented in the SAP (Appendix A). The QAPP included as Appendix B, further details the QA/QC aspects of the laboratory analytical methods, sample container preservation requirements, holding times and laboratory third party certifications. Soil and groundwater samples collected as part of this RI will be analyzed for CCR related constituents listed in 40 CFR 257, Appendices III and IV. In addition, five inorganic constituents listed in Appendix I of TN Rule , and not included in the 40 CFR 257 Appendices III and IV, will be analyzed to maintain continuity with TDEC environmental programs. The additional constituents listed in TDEC Appendix I include the following metals: copper, nickel, silver, vanadium, and zinc. The combined federal CCR Appendices III and IV constituents, and TDEC Appendix I inorganic constituents, are referenced collectively herein as CCR Parameters. 5.4 DATA EVALUATION AND INTERPRETATION Data collected during the RI will be used to determine the horizontal and vertical extent of CoCs, groundwater flow rate and direction, and further develop the conceptual site model proximal to the East Ash Disposal Area. Groundwater analytical and field parameter data will be evaluated to characterize the horizontal and vertical distribution of CCR constituents in the shallow, intermediate, and deep portions of the Fluvial Aquifer surrounding the East Ash Disposal Area. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.10

33 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, 2017 These results will be compared to the MCLs for arsenic, lead, and fluoride to evaluate horizontal and vertical delineation. Data generated during the RI will be managed in accordance with the Data Management Plan included in Appendix D. Depending on the observed concentrations and extent, specific two-dimensional or three-dimensional representations of CoCs and/or groundwater field parameters in groundwater may be generated. Methods of data evaluation will include, but not be limited to: analytical data review, field data review, mapping of CoC concentrations, statistical evaluations of groundwater data trends with time and/or space, geologic mapping from borehole data, groundwater flow modeling results, and slug test data analysis. This evaluation will be used as the basis for determining the scope and necessity of additional investigation to further define horizontal and vertical extent. Soil analytical data will be evaluated to characterize the horizontal and vertical distribution of CCR constituents in vadose zone soils surrounding the East Ash Disposal Area. Depending on the observed concentrations and extent, specific two-dimensional or three-dimensional representations of CoCs in soils may be generated. Groundwater elevation and surface water elevation data will be used to create groundwater contour maps to illustrate groundwater flow direction in the shallow, intermediate, and deep portions of the Fluvial Aquifer. These data will also be used to evaluate vertical hydraulic gradients in the Fluvial Aquifer. Slug testing data will be used to calculate formation hydraulic conductivity. The site-specific horizontal gradient and hydraulic conductivity data and an estimated effective porosity will be used to generate a linear groundwater flow velocity. Vertical permeability data from the basal clay unit will provide data for eventual use in a three-dimensional groundwater flow model. 5.5 RI REPORT FORMAT The results of the RI will be presented in a report generally conforming to the following outline: 1) Introduction a) Purpose and Scope b) Overview / RI Objectives 2) Site Background and Environmental Setting a) Site Description b) Surrounding Land Use wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.11

34 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, 2017 c) Site History and Operations d) Site and Regional Environmental Setting 3) Field Investigation Program a) Remedial Investigation i) Potential Source Characterization ii) Soil Sampling iii) Groundwater Characterization iv) Pump Testing (USGS Pump Test Report to be included as Appendix E) 4) Nature and Extent of Contamination a) Contamination Characterization i) Screening Values ii) Analytical Results b) Evaluation of Analytical Results 5) Conclusion of RI Findings 6) References RI Report Tables, Figures and Appendices are expected to include: Tabulated analytical results; Graphical representations of analytical results; Potentiometric surface maps; Updated geologic cross-sections; Laboratory reports (electronic format only), and the analysis of the ACC pump test provided by USGS and University of Memphis. 5.6 SCHEDULE Elements of this RI have already been initiated. Both the initial DPT investigation (Section 5.2.1) and the installation of monitoring wells (Section 5.2.4) are currently in progress and completion of the field work is anticipated by late-september. Evaluation of hydraulic conductivity, groundwater elevation, gradient, and collection of groundwater will be completed as soon as practical after installation of the wells. The timing of submittal for an RI Report is dependent on the results of the investigation and ongoing communication with TDEC. Submittal of the RI wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.12

35 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Site Data Needs September 15, 2017 Report and related data is currently scheduled for February of 2018, but that schedule may be modified upon mutual consent. Stratigraphic and hydrogeologic data collected during this investigation will be shared with the USGS and the University of Memphis to be incorporated in their investigation described in Appendix E. The estimated schedule of work to be conducted during this RI is presented as Figure 7. This schedule is based on the current understanding of the RI scope and subject to modification due to a variety of conditions that are outside TVA s control. TVA will proactively communicate changes in the schedule to TDEC. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx 5.13

36 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Figures September 15, REFERENCES Brahana, J.V. and R.E. Broshears (2001). Hydrogeology and Groundwater Flow in Memphis and Fort Pillow Aquifers in the Memphis Area, Tennessee. U.S. Geological Survey, Water Resources Investigations Report Grahams, D.D. and W.S. Parks (1986). Potential for Leakage Among Principal Aquifers in the Memphis Area, Tennessee. Griffith, G. E., J. M. Omernik, J. A. Comstock, S. Lawrence, G. Martin, A. Goddard, V. J. Hulcher and T. Foster (2001). Ecoregions of Tennessee, Reston, Virginia, U.S. Geological Survey. NOAA, NCDC (2017). Climate and Precipitation of Memphis, TN. National Oceanic and Atmospheric Administration, National Centers for Environmental Information. Parks, W.S., Mirecki, J.E. and Kingsbury, J.A. (1995). Hydrogeology, Groundwater Quality, and Source of Groundwater Causing Water Quality Changes in the Davis Well Field at Memphis, Tennessee. U.S. Geological Survey Water Resources Investigations Report Parks, W.S. (1978). Geologic Map of the Tennessee Portion of the Fletcher Lake Quadrangle, Tennessee. Shuhua Yao, Ziru Liu and Zhongliang Shi1. Journal of Environmental Health Science & Engineering 2014, vol 12 pp Tennessee Department of Environment and Conservation (2017). Nonconnah Creek Watershed ( ) of the Mississippi River Basin. Retrieved from Tennessee Valley Authority (2014). Allen Fossil Plant Emission Control Project, Final Environmental Assessment. Tennessee Valley Authority (1993). Allen Fossil Plant - Fossil Engineering Inspection of Ash Disposal Areas. July. Tennessee Valley Authority (1995). Allen Steam-Electric Plan NPDES Permit Renewal. Tennessee Valley Authority (2016). Final Ash Impoundment Closure Programmatic EIS, Part II Site-Specific NEPA Review: Allen Fossil Plant. June. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx

37 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Figures September 15, 2017 FIGURES wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx

38 ± Allen Fossil Plant C:\Users\tspear\Desktop\Site Location Map - ALF.mxd Revised: By: tspear 0 1,250 2,500 5,000 Feet August 2017 ** Approximate distance from ALF to Mississippi River: 10,900 FT ** Client/Project Tennessee Valley Authority Allen Fossil Plant Memphis, Shelby County, Tennessee Notes 1. Coordinate System: WGS 1984 Web Mercator Auxiliary Sphere 2. Topographic data: ESRI Online ^_ Allen Fossil Plant Figure No. 1 Title Site Location

39 ( $ $ Figure No. 2 Title Aerial Map Allen Fossil Plant Client/Project Tennessee Valley Authority Allen Fossil Plant Project Location Prepared by TR on Technical Review by TM on Memphis, Tennessee ,200 1,600 Feet 1:4,800 (At original document size of 22x34) Legend Current Impoundment (Approximate) Former Disposal Area (Approximate) City of Memphis and MLGW Levee City of Memphis and Shelby County Chemical Treatment Pond West Ash Disposal Area TVA Property Boundary TVA Harsco Corporation Area (Beneficial Reuse Area) East Ash Disposal Area Normal Pool Elevation = feet Ash Disposal Easement Area No. 4 (City of Memphis and MLGW) (West Ash Disposal Area) Powerhouse Coal Yard City of Memphis and MLGW Ash Disposal Easement Area No. 1 (City of Memphis and Shelby County) (East Ash Disposal Area) Coal Yard Runoff Pond Notes 1. Coordinate System: NAD 1983 StatePlane Tennessee FIPS 4100 Feet 2. Imagery Provided by Terraserver (2016) & TVA (2015) 3. The West Ash Disposal Area does not impound water; therefore, a water surface elevation is not applicable to the West Ash Disposal Area. 4. The water surface elevation for the East Ash Disposal Area is referenced to the National Geodetic Vertical Datum of TVA property boundary is referenced from TVA Drawing 421 P 504 Allen Fossil Plant Reservation. U:\TVA-EIP\ \gis\mxds\ACC\ALF_MOA_Easement.mxd Revised: By: trink Cross Future Combined Cycle Plant Under Construction Tennessee Crittenden Arkansas Shelby _ ^ St. Francis Fayette Allen Fossil Plant DeSoto Lee Mississippi Marshall Benton Tunica Tate Disclaimer: Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data. Page 01 of 01

40 ( $ $ 1 G P-4 # V A 8 B ALF WW 23 C 24 D * & Gro und wa t e rmo nit oring W e ll # V Obs e rva t ion Mo nit o ring W e ll * & P ro p os e d DP TL o ca t io ns ain-3 0-inc 37 Forc em F eet S e e p Wa t e rsa m p le L oca t ion h P ot e nt ia ldp TBo ring s ( 72) * & GP ALF-206 GP ALF Legend P re p a re d byt Ro n T e chnica lre vie w byl P o n : 1, 800( Ato rig ina ld o cum e nts ize o f 22x 34) T e nne s s e e Va lle yaut ho rit y Alle n Fo s s ilp la nt 0 1-WW Clie nt / P roje ct East Ash Pond Complex DPT Sample Locations ALF-204 F T it le Me m p his,t e nne s s e e P ro je ctl o ca t io n 74 E 4 P F ig ure No. Act ive Sa nit a ryse we r GP-83 * & I na ct ive Sa nit a ryse we r GP-85 GP-81 * & * & GP-86 * & 39 Forc B/P- e Main 30-in ch * & GP-87 * & Gravity ( Aband)-6 0 -inch Grav it y-42 * & ALF-213 GP-88 -inch 44 GP-82 Notes 1. Co o rd ina t e Syst e m :NAD1983St at e P la ne T e nne s s e e F I P S4100F eet 2. I m a g e ryp ro vid e d byt e rra S e rve r ( 2016)& T VA( 2015) 3. Bo ring s wille x t e nd t o a d e pt h o f 50 be lo w g ro und s urfa ce o r t he bo t t om of t he a s h,whiche ve r is s ha llo we r. 46 * & GP-89 U: \T VAEI P \ \g is\m x d s \ACC\AL F _ Ea s t As hp o nd _ DP T _L oca t ions. mx d Re vis e d : By:T Rink Gravity -9 6-inch ALF Arkansas De S ot o L ee Mississippi 71 Alle n F o s s ilp la nt ALF F a ye t t e 62 S he lby _ ^ S t.f ra ncis Tennessee Crit t e nd e n Cros s ALF Ma rs ha ll Be nt on 72 T unica T at e Dis cla im e r:s t a nt e ca s s um e s no re s p o ns ibilit yfo r d a t a s up p lie d in e le ct ro nicfo rm a t.t he re cip ie nta cce p t s fullre s p o ns ibilit yfo r ve rifying t he a ccura cya nd co m p le t e ne s s o f t he d a t a.t he re cip ie ntre le a s e s St a nt e c,it s o ffice rs,e m p lo ye e s,co ns ult a nt s a nd a g e nt s,fro m a nya nd a llcla im s a ris ing in a nywa yfro m t he co nt e nto r p ro vis io n o f t he d a t a. P a g e 01o f 01

41 ( Figure No. 4 Title $ $ # V P-2 # V Client/Project Tennessee Valley Authority Allen Fossil Plant Project Location P Prepared by TR on Technical Review by LP on Memphis, Tennessee # V P-4-S P-4 # A ALF-203-B ALF-203-A ALF-203 ALF-204 ALF-204-B ALF-204-A ALF-205 Harsco Well :3,000 (At original document size of 22x34) ALF-205-B ALF-205-A 1,000 Feet Legend ( Abandoned ( ALF-206 ( ALF-210-A Proposed Monitoring Well Locations ( Groundwater Monitoring Well # V Observation Monitoring A Proposed Nested Groundwater Monitoring Well # V Staff Gauge Location * & 2017 Production Well ALF-213 ( ALF-210 A ALF-214 ALF-214-B A ALF-201-B ALF-201-A ALF-201 A ALF-202-B ALF-201-A ( A ALF-212-A A ( Notes Well #4 ALF-215 * A Well #5 U:\TVA-EIP\ \gis\mxds\ACC\ALF_Proposed_Nested_Monitoring_Wells_ mxd Revised: By: TRink * & A Well #3 * & 1. Coordinate System: NAD 1983 StatePlane Tennessee FIPS 4100 Feet 2. Imagery Provided by TVA (2015) 3. Exisiting Monitoring Wells are referenced from TVA Drawing 10W Allen Fossil Plant Reservation. 4. The total depth of the deep wells will depend on the observed depths of the underlying confing layer. Upon completion, the well ID will incorporate the depth of the screen interval (e.g. ALF-201-B will be named ALF Cross Well #2 Arkansas Well #1 * & Shelby _ ^ St. Francis * & Tennessee Crittenden Fayette Allen Fossil Plant DeSoto Lee Mississippi Marshall Benton Tunica Tate Disclaimer: Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data. Page 01 of 01

42 Figure No. 5 Title East Ash Pond Complex Conceptual Cross Section Client/Project Tennessee Valley Authority Allen Fossil Plant Project Location Crittenden Revised: By: TRink U:\TVA-EIP\ \gis\mxds\ACC\ALF_EastAshPond_Concept_XS.mxd Prepared by TR on Technical Review by LP on Memphis, Tennessee _ ^ Tennessee Shelby Allen Fossil Plant Fayette DeSoto Tunica Disclaimer: Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data. Mississippi Marshall Page 01 of 01

43 ( $ $ Figure No. 6 Title Proposed Stratigraphic Boring Locations Client/Project Tennessee Valley Authority Allen Fossil Plant Project Location Prepared by TCS on Technical Review by TM on Memphis, Tennessee ,000 Feet 1:2,400 (At original document size of 22x34) A Proposed Stratigraphic A Alternate Proposed Stratigraphic Boring Notes 1. Coordinate System: NAD 1983 StatePlane Tennessee FIPS 4100 Feet 2. Imagery Provided by TVA (2015) 3. Exisiting Monitoring Wells are referenced from TVA Drawing 10W Allen Fossil Plant Reservation. U:\TVA-EIP\ \ALF_Proposed_Stratigraphic_Boring_Locations.mxd Revised: By: tspear Arkansas Cross Crittenden _ ^ St. Francis DeSoto Lee Shelby Tennessee Fayette Allen Fossil Plant Mississippi Marshall Benton Tunica Tate Disclaimer: Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data. Page 01 of 01

44 FIGURE 7 ALF REMEDIAL INVESTIGATION SCHEDULE Allen Fossil Plant Shelby County, Tennessee Activity Well Sampling 1st round of monthly monitoring well sampling ACC Production Well Sampling 2nd round of monthly monitoring well sampling ACC Production Well Sampling 3rd round of monthly monitoring well sampling ACC Production Well Sampling Early Date 9/18/2017 9/20/ /16/ /18/ /20/ /22/2017 Late Date Field Investigation Stratigraphic borings 9/18/ /2/2017 DPT borings 10/2/ /16/2017 Pump test ACC Production Wells Initial pump test analysis submitted to TDEC from USGS Initial start up operations 10/3/ /8/ /27/ /1/ /10/2017 RI Report RI Report 2/2/2018 Page 1 of 1

45 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Tables September 15, 2017 TABLES wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\text\ _alf_riwp_rpt.docx

46 TABLE 1 MONITORING WELL CONSTRUCTION SUMMARY REMEDIAL INVESTIGATION WORK PLAN ALLEN FOSSIL PLANT Well ID Top of Casing Elevation (ft. NGVD29) Depth (ft btoc) Bottom of Well* Screened Interval* Bottom of Borehole Elevation (ft. NGVD29) Depth (ft btoc) Elevation (ft. NGVD29) Depth (ft bgs) Elevation (ft. NGVD29) ALF ALF ALF ALF ALF ALF ALF ALF ALF Notes: * - Based on downhole video performed by Stantec on October 13 and 16, 2016 and November 3, 2016 ft NGVD29 - feet National Geodetic Vertical Datum 1929 ft btoc - feet below top of casing ft bgs - feet below ground surface Page 1 of 1

47 TABLE 2 PROPOSED MONITORING WELL LOCATIONS, DESCRIPTIONS AND RATIONALE REMEDIAL INVESTIGATION WORK PLAN ALLEN FOSSIL PLANT Well ID Location Screen Interval (approx. ft bgs) Purpose ALF-201-B ALF-201-A ALF-202-B ALF-202-A ALF-203-B ALF-203-A ALF-204-B ALF-204-A ALF-205A ALF-205-B Near ALF-201. South of East Ash Disposal Area Near ALF-201. South of East Ash Disposal Area Near ALF-202. South of East Ash Disposal Area Near ALF-202. South of East Ash Disposal Area Near ALF-203. North of East Ash Disposal Area Near ALF-203. North of East Ash Disposal Area Near ALF-204. North of East Ash Disposal Area Near ALF-204. North of East Ash Disposal Area Near ALF-205. North of East Ash Disposal Area Near ALF-205. North of East Ash Disposal Area Intermediate Deep Intermediate Deep Intermediate Deep Intermediate Deep Deep Intermediate Define western and vertical extent of CoCs identified in ALF-202. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and the production wells. Define western and vertical extent of CoCs identified in ALF-202. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and the production wells. Define vertical extent of CoCs identified in ALF Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and the production wells. Define vertical extent of CoCs identified in ALF Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and the production wells. Define vertical extent of CoCs identified in ALF Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and the production wells. Define vertical extent of CoCs identified in ALF Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and the production wells. Define eastern and vertical extent of CoCs identified in ALF-203. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and McKellar Lake. Define eastern and vertical extent of CoCs identified in ALF-203. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and McKellar Lake. Define eastern and vertical extent of CoCs identified in ALF-204. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and McKellar Lake Define eastern and vertical extent of CoCs identified in ALF-204. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and McKellar Lake. Page 1 of 2

48 TABLE 2 PROPOSED MONITORING WELL LOCATIONS, DESCRIPTIONS AND RATIONALE REMEDIAL INVESTIGATION WORK PLAN ALLEN FOSSIL PLANT Well ID Location Screen Interval (approx. ft bgs) Purpose ALF-210-A ALF-212-A ALF-214 ALF-214-B ALF-214-A P-4-S ALF-215 Near ALF-210. Southwest of East Ash Disposal Area Near ALF-212. Southeast of East Ash Disposal Area West of ALF-201. Southwest of East Ash Disposal Area West of ALF-201. Southwest of East Ash Disposal Area West of ALF-201. Southwest of East Ash Disposal Area Near Intermediate well P-4. Northwest of East Ash Disposal Area South of ALF-202 Deep Deep Shallow Intermediate Deep Shallow Shallow Determine the presence of absence of CoCs southwest of the East Ash Disposal Area. Monitor vertical gradient in the fluvial aquifer west of the East Ash Disposal Area and the production wells. Determine the presence of absence of CoCs at southeastern margin of the East Ash Disposal Area. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and the production wells. Determine the presence of absence of CoCs at southwestern margins of the East Ash Disposal Area. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and the production wells. Determine the presence of absence of CoCs at southwestern margins of the East Ash Disposal Area. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and the production wells. Determine the presence of absence of CoCs at southwestern margins of the East Ash Disposal Area. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and the production wells. Confirm the horizontal extent of CoCs in the shallow zone to the west of ALF-203 and northwest of the East Ash Disposal Area. Monitor vertical gradient in the fluvial aquifer between the East Ash Disposal Area and McKellar Lake using existing intermediate well P-4. Evaluate the presence or absence of CCR constituents northwest of East Ash Disposal Area using P-4-S and P-4. Define southern extent of CoCs observed in ALF ALF-216 Southwest of ALF South of East Ash Disposal Area Shallow Confirm horizontal extent of CoCs observed in ALF- 202 to the south-southwest. Note: The final well screen interval for deep wells will be based on the depth that a clay layer is encountered Page 2 of 2

49 TABLE 3 MONITORING WELL NETWORK SUMMARY REMEDIAL INVESTIGATION WORK PLAN ALLEN FOSSIL PLANT Monitoring Well Nest ALF-201 ALF-202 ALF-203 ALF-204 ALF-205 ALF-206 ALF-210 ALF-212 ALF-213 ALF-214 ALF-215 ALF-216 P-4-S Screened Intervals Shallow, Intermediate, Deep Shallow, Intermediate, Deep Shallow, Intermediate, Deep Shallow, Intermediate, Deep Shallow, Intermediate, Deep Shallow Shallow, Deep Shallow, Deep Shallow Shallow, Intermediate, Deep Shallow Shallow Shallow Note: Screened intervals identified in bold are to be installed as part of this Remedial Investigation. Page 1 of 1

50 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Appendix A Sampling and Analysis Plan September 15, 2017 SAMPLING AND ANALYSIS PLAN

51 Sampling and Analysis Plan Allen Fossil Plant Revision 0 Allen Fossil Plant Memphis, Tennessee Prepared for: Tennessee Valley Authority Chattanooga, Tennessee Prepared by: Stantec Consulting Services Inc. Lexington, Kentucky September 15, 2017

52 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Table of Contents 1.0 BACKGROUND OBJECTIVES HEALTH AND SAFETY INVESTIGATION ACTIVITIES DIRECT PUSH TECHNOLOGY INVESTIGATION MONITORING WELL INSTALLATION SOIL SAMPLING GROUNDWATER SAMPLING SCOPE GROUNDWATER SAMPLING FREQUENCY FIELD ACTIVITY PROCEDURES PREPARATION FOR FIELD ACTIVITIES DRILLING AND SAMPLING METHODS AND PROTOCOL Drilling, Logging, and Survey - DPT Investigation Drilling, Logging, and Survey Monitoring Wells Monitoring Well Installation Installation of Dedicated Sampling Pumps Field Equipment Description, Testing/Inspection, and Maintenance Field Documentation Equipment Decontamination Procedures Monitoring Well Installation Waste Management GROUNDWATER SAMPLE COLLECTION AND FIELD ACTIVITY PROCEDURES Preparation for Field Activities Sampling Methods and Protocol QUALITY ASSURANCE/QUALITY CONTROL OBJECTIVES QUALITY CONTROL CHECKS Soil Sampling Groundwater Sampling ASSUMPTIONS AND LIMITATIONS REFERENCES...8.1

53 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT LIST OF TABLES TABLE 1. TABLE 2. TABLE 3. TABLE 4. TABLE CFR Part 257 Appendix III Constituents 40 CFR Part 257 Appendix IV Constituents TN Rule , Appendix 1 Inorganic Constituents Additional Geochemical Parameters Groundwater Analytical Methods, Preservatives, Containers, and Holding Times LIST OF ATTACHMENTS ATTACHMENT A Figures FIGURE 1. FIGURE 2. DPT Sampling Locations Proposed Monitoring Well Locations

54 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Background September 15, BACKGROUND In response to the Tennessee Department of Environment and Conservation (TDEC) letter dated July 18, 2017, the Tennessee Valley Authority (TVA) has developed a Remedial Investigation (RI) Work Plan to characterize soil and groundwater quality near the East Ash Disposal Area at the Allen Fossil Plant (ALF). This RI Sampling and Analysis Plan (SAP) is an appendix document to the RI Work Plan. This RI SAP provides procedures and methods to investigate soil and groundwater conditions in the Fluvial Aquifer at the ALF plant. Figures for the SAP are provided in Attachment A. Figure 1 shows direct push technology (DPT) sampling locations for an initial groundwater screening investigation. Figure 2 shows the proposed area to install monitoring wells and collect soil and groundwater samples. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 1.1

55 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Objectives September 15, OBJECTIVES The objectives of the RI Work Plan as specified in the TDEC letter dated July 18, 2017 include the following: 1) Source area identification and delineation of Coal Combustion Residual (CCR) constituents as listed in Appendices III & IV in the U.S. EPA CCR Regulations, including arsenic, lead, and fluoride, in the subsurface soils which are thought to be impacting shallow groundwater in the vicinity of the East Ash Disposal Area at the Site; 2) Complete horizontal and vertical delineation of the groundwater contaminant plume(s) for CCR constituents, including arsenic, lead, and fluoride, in the Fluvial Aquifer beneath the Site, through the installation and sampling of permanent monitoring wells; 3) Characterization of the Fluvial Aquifer with a network of shallow, intermediate, and deep permanent monitoring wells that will provide monitoring points for the future observation of potential contaminant migration in the shallow aquifer, as well as from the shallow aquifer to the deeper portions of the Fluvial Aquifer. The monitoring well network should be able to detect any changes in the constituent distribution and flow gradients once the Memphis Sand Aquifer production well operations begin; and 4) Completion of a three-dimensional groundwater flow and transport model for the Site to evaluate groundwater flow and contaminant migration in the Fluvial Aquifer under current conditions, as well as future conditions that may develop as a result of pumping from the Memphis Sand Aquifer. Groundwater extraction from the three TVA Memphis Sand production wells should be incorporated in the model at the various anticipated production rates. At a minimum, modeling shall be conducted for a ground water withdrawal rate of 3,000,000 gallon/day and a 5,000,000 gallon/day withdrawal rate. The model should be suitable for evaluating impacts from source contamination to the Fluvial Aquifer, potential contaminant migration pathways from the source area, potential water quality impacts to the Memphis Sand Aquifer, and ultimately the possibility of contaminant migration to potential receptors, via shallow migration or MLGW wellfield impacts. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 2.1

56 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Health and Safety September 15, HEALTH AND SAFETY This work will be conducted under an approved site-specific Health and Safety Plan (HASP) for the ALF facility. The HASP will be in accordance with TVA Safety policies and procedures. Each site worker will be responsible for following the HASP. Personnel conducting RI activities will have completed required training, understand safety procedures and be qualified to conduct the work. The HASP will include a job safety analysis (JSAs) for each task described in this SAP and provide control methods to protect personnel. Personal protective equipment (PPE) requirements and safety, security, health, and environmental procedures are defined in the HASP. In addition, authorized field personnel will attend TVA required safety training and site orientation. Safety briefings will be conducted each day prior to beginning work and mid-shift or after lunch breaks. The designated site safety officer will document these meetings to include the names of those in attendance and items discussed. TVA-specific protocols will be followed, including the completion of 2-Minute Rule cards at each work site. The JSAs will be updated if site conditions change. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 3.1

57 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Investigation Activities September 15, INVESTIGATION ACTIVITIES TVA has investigative activities underway that will provide information that can be used to characterize the hydrogeology of ALF. Some of this work has been or is being conducted, but final reports have not been produced and the results of those investigations are not yet available. However, TVA will incorporate pertinent data from those investigations that meet the QA/QC requirements of the QAPP to meet the objectives listed in Section DIRECT PUSH TECHNOLOGY INVESTIGATION The initial phase of work involved boring installation, the collection of vertical groundwater samples, and analysis of screening level data, most importantly ph. Initial borings were conducted in proximity to monitoring wells ALF-202 and ALF-203, and subsequent borings progressed outward based on the results of field screening data (reference Figure 1). A total of 72 potential sampling locations were identified, but the specific number of borings completed depended upon the results of the screening level data. The goal was to generally define the area(s) of groundwater that exhibited the following characteristics: ph greater than 7.5 Standard Units (S.U.) Temperature greater than 17.5 degrees Celsius Each boring was advanced to a depth of 50 feet below ground surface or the base of the ash within the pond, whichever was shallower. Grab groundwater or pore water samples for analysis of field parameters and (in some cases) additional CCR constituents were collected at 5-foot intervals in the DPT borings. In addition to field parameters (ph and temperature), 15 to 20 groundwater samples were alsocollected for laboratory analysis of CCR parameters as defined in Section 4.4 of this SAP. The number of samples was determined in the field. Field and laboratory results will be mapped to illustrate the distribution and concentration/magnitude of observed constituents. The geochemical profile of groundwater at each location will also be evaluated. The installation of additional monitoring wells. The number and locations of wells will be selected to enable groundwater monitoring around the perimeter and within the areas of groundwater exhibiting constituents above threshold concentrations (e.g., ph greater than 7.5 S.U.) Additional Direct Push Technology Investigation As discussed during the August 24, 2017 meeting with TDEC, four additional boring locations are proposed within the accessible portions of the East Ash Disposal Area to facilitate additional sampling. The proposed investigation locations are provided in Figure 1. These sampling locations v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 4.1

58 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Investigation Activities September 15, 2017 will include the collection of ash samples and pore water samples to be analyzed for Appendix III and Appendix IV constituents. Pore water sampling and analysis has been selected instead of TCLP or SPLP analysis because it represents the actual concentrations in environmental media rather than an artificially generated leachate Additional Investigation of Sewer Line As discussed during the August 24, 2017 meeting with TDEC, six additional boring locations are proposed within the accessible portions of the East Ash Disposal Area along the active force main line to facilitate additional sampling. The proposed investigation locations are provided in Figure 1. The results of this investigation will be used to evaluate the potential for the sewer lines to serve as either sources or migration pathways. The locations selected were based on accessibility within the East Ash Disposal Area. If results from the source area investigation suggest that the sewer lines are serving as a source or migration route, additional investigation may be conducted at other accessible locations. 4.2 MONITORING WELL INSTALLATION TVA has installed eight shallow groundwater monitoring wells around the East Ash Disposal Area (ALF-201 through ALF-206, ALF-212 and ALF-213) and one shallow well to the west (ALF-210). These wells are screened in the upper part of the Fluvial Aquifer. Additional shallow, intermediate and deep wells will be installed to facilitate evaluation of the horizontal and vertical extent of CoCs and measure horizontal and vertical flow gradients within the Fluvial Aquifer. The approach is to install 18 additional monitoring wells (four shallow, six intermediate (B) and eight deep wells (A)): Shallow wells - Screened intervals shallower than 55-feet: P-4-S, ALF-214, ALF-215 and ALF Intermediate wells (B) - Screened intervals ranging between and feet: ALF-201B through ALF-205B and ALF-214B. Deep wells (A) Screened intervals between feet to feet depending on depth of the lower clay unit: ALF-201A through ALF-205A, ALF-210A, ALF-212A and ALF-214A. Proposed monitoring well locations are shown on Figure 2. The number and location of wells was selected to characterize the areal distribution and potential variability of vertical hydraulic gradients across the site. The intermediate and deep monitoring wells will serve three purposes: 1) allow for the collection of vadose zone soil samples; 2) provide points to measure groundwater levels for evaluation of horizontal and vertical gradients and 3) provide groundwater investigation sampling locations. The screened intervals for the deep monitoring wells are proposed to be placed near the bottom of the Fluvial Aquifer and above the Jackson-Claiborne confining layer between the Fluvial v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 4.2

59 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Investigation Activities September 15, 2017 Aquifer and the underlying Memphis Sands Aquifer. The vertical placement near the bottom of the Fluvial Aquifer was selected to provide a sampling point to characterize groundwater quality at the deepest part of the Fluvial Aquifer for evaluation of the potential for CCR parameters to migrate from the East Ash Disposal Area to the Memphis Sands Aquifer. If CCR parameters attributable to the East Ash Disposal Area are detected in the deep monitoring wells, then additional remedial investigations may be conducted to evaluate the Memphis Sands Aquifer. Based on the information gathered as described above, additional monitoring wells may be needed to fully characterize groundwater. If additional wells are needed, TVA, in communication with TDEC, will install these wells to obtain additional groundwater information. Results of all investigations to characterize groundwater flow directions will be included and described in the RI Report. 4.3 SOIL SAMPLING Soil sampling will be conducted in the vadose zone to characterize constituent of concern (CoC) concentrations above the Fluvial Aquifer. Each of the borings for the proposed monitoring wells will be continuously sampled to the terminus of the boring. In the case of nested monitoring wells, only the deepest monitoring well in each location will be continuously sampled. Data will include a description of the lithology encountered with depth logged by a Tennessee Licensed Professional Geologist or Engineer. Continuous sampling in this manner will allow for stratigraphic characterization and the collection and laboratory analysis of soil samples from the vadose zone. At each of the monitoring well locations (single or cluster) illustrated on Figure 2, soil sampling will be conducted as follows: Soil borings will be advanced using a roto-sonic drill rig and continuously sampled in accordance with the SAP (Section 5.2.2). Grab soil samples from discreet two-foot depth intervals will be collected for laboratory analysis. Samples will be selected from two or three depths at each location: o o o The shallowest interval exhibiting the presence of native soil; An intermediate depth sample (as determined by field observations); and, The deepest interval above the observed water table. Soil samples will be collected, handled, and transported in accordance with the QAPP. Laboratory analysis will be conducted by Pace Analytical Laboratories, Inc. for CCR Parameters in accordance with the methods and procedures specified in the QAPP. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 4.3

60 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Investigation Activities September 15, 2017 Soil samples collected as part of this RI will be analyzed for CCR related constituents listed in 40 CFR 257, Appendices III and IV. In addition, five inorganic constituents listed in Appendix I of TN Rule , and not included in the 40 CFR 257 Appendices III and IV, will be analyzed to maintain continuity with TDEC environmental programs. The additional constituents listed in TDEC Appendix I include the following metals: copper, nickel, silver, vanadium, and zinc. The combined federal CCR Appendices III and IV constituents, and TDEC Appendix I inorganic constituents, are referenced collectively herein as CCR Parameters. In addition, samples of cohesive soils, if encountered in borings drilled to install the deep monitoring wells, will be collected as detailed in Section GROUNDWATER SAMPLING SCOPE TVA will measure groundwater level elevations at the following monitoring and observation well locations across the site: Existing locations ALF-201 through ALF-206, ALF-210, ALF-212, ALF-213 and P-2 through P-4. Proposed monitoring well locations ALF-201A/B through ALF-205A/B, ALF-210A, ALF-212A, ALF-214 triplet, ALF-215, ALF-216 and P-4-S. Surface water elevations will be measured at the gauging station in McKellar Lake. Groundwater samples will be collected from the existing and proposed monitoring wells and submitted for laboratory analysis. Groundwater samples collected as part of this RI will be analyzed for CCR related constituents listed in 40 CFR 257, Appendices III and IV. In addition, five inorganic constituents listed in Appendix I of TN Rule , and not included in the 40 CFR 257 Appendices III and IV, will be analyzed to maintain continuity with TDEC environmental programs. The additional constituents listed in TDEC Appendix I include the following metals: copper, nickel, silver, vanadium, and zinc. The combined federal CCR Appendices III and IV constituents, and TDEC Appendix I inorganic constituents, are referenced collectively herein as CCR Parameters. Figure 2 shows the existing and proposed monitoring well locations that will be sampled. This figure will be updated to show the actual locations for newly installed wells after execution of the RI Work Plan. 4.5 GROUNDWATER SAMPLING FREQUENCY TVA plans to conduct three monthlysampling events as part of the RI to characterize groundwater flow direction, rates and quality. The setting of ALF is potentially influenced by seasonal variations in the elevation of water levels in McKellar Lake as well as seasonal patterns in climate; therefore, three consecutive months of sampling is proposed. Data from these three sampling events will be v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 4.4

61 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Investigation Activities September 15, 2017 provided in the RI Report and used to determine the scope and necessity of additional groundwater monitoring. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 4.5

62 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, FIELD ACTIVITY PROCEDURES This section provides details of procedures that will be used to prepare for field activities, install groundwater monitoring wells and collect soil and groundwater samples. A complete description of the ALF RI QA requirements is provided in the QAPP. Monitoring well installation and soil and groundwater sampling will adhere to applicable American Society for Testing and Materials (ASTM) and TVA Environmental Technical Instruction (TI) documents. A project field book and field forms will be maintained by the Investigation Consultant sampling team leader to record field measurements, analyses, and observations. Field activities will be documented according to TVA TI ENV-TI , Field Record Keeping. 5.1 PREPARATION FOR FIELD ACTIVITIES As part of field mobilization activities, the field sampling team will: Complete required health and safety paperwork and confirm field team members have completed required training. Coordinate activities with the drilling subcontractor. Clear Site Access Proposed monitoring and observation well locations will be marked using a wooden stake or survey flag with the position surveyed using GPS. Suitability of each location will be evaluated for logistical issues including access, grubbing needs, overhead and underground utility clearance, and proximity to site features. Access improvements, including clearing and grubbing or road building, will be completed prior to the investigation start date. Perform Environmental Review As required by the National Environmental Policy Act (NEPA), an environmental review must be completed to document and mitigate any potential impact of the work described herein. The level of review required for this work is anticipated to be a categorical exclusion, which would be documented by TVA with a categorical exclusion checklist (CEC). A CEC will require a number of signatories from TVA. It is understood that the environmental review is to be completed before implementation of the field work. Plant staff will not issue an excavation permit ahead of the completed environmental review. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.1

63 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 Complete Utility Locate(s) / Excavation Permit(s) - Prior to initiating subsurface activities, subsurface utility clearance will be sought via the plant engineering department and/or the TN 811 service. At locations within ALF site, plant engineering will provide primary utility clearance assurance in addition to TN 811 being notified. At all other drilling locations, TVA or 3rd party underground locators will be engaged to clear boring locations. For drilling locations outside the plant (e.g., along public roads and rights-of-way), utility avoidance assurance will be supplemented by the TN 811 service and the TVA or 3rd party underground locators. An excavation permit is required prior to initiating any digging or boring at the site. A key component to the completion of the excavation permit is consensus on the drilling locations with pertinent TVA staff. Identify Water Source During implementation of the RI, a source of available water will be required to complete several investigation tasks, including certain drilling methods and decontamination procedures. Obtain required functional and calibrated field instruments, including health and safety equipment. Obtain County Permits - Shelby County requires that TVA obtain a permit prior to installing monitoring wells. 5.2 DRILLING AND SAMPLING METHODS AND PROTOCOL TVA proposes to perform soil sampling to assist with the subsurface characterization as part of the RI. The following sections present drilling and soil sampling procedures required to complete the tasks presented. Once completed, soil borings and monitoring wells will be surveyed for horizontal and vertical control by survey grade GPS Drilling, Logging, and Survey - DPT Investigation Borings will be advanced using a DPT or other compatible technology based on field conditions and rig availability equipped to collect grab groundwater samples. To collect vertical groundwater samples, borings will be advanced through unconsolidated soils to a depth of approximately 50 feet below the ground surface, or to a depth of approximately the base of the ash pond. The rods will be decontaminated between sampling locations in accordance with TVA TI ENV-TI , Field Sampling Equipment Cleaning and Decontamination. The depth to groundwater will be estimated using groundwater elevations in nearby wells. The DPT sample rod will be advanced to approximately 3 feet above the estimated depth, and a soil sample will be collected to confirm that the saturated zone has been tagged. The rod will be retracted and the liner removed from the sampling rod and placed on clean plastic sheeting. After saturated soil conditions are encountered, groundwater samples will be collected using the DPT drilling rig equipped with a groundwater sample probe (e.g., SP22 or similar), and following v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.2

64 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 the procedures presented in Sections through DPT sample rods will be driven in a continuous run until the desired soil boring depth is achieved (as described above). Once sample collection is complete at each boring, the boreholes will be filled with a high-solids bentonite slurry. Rods will be decontaminated between sampling locations Drilling, Logging, and Survey Monitoring Wells The monitoring well borings are proposed to be advanced utilizing rotasonic vibratory drilling until proposed boring termination depth. Continuous soil sampling will be performed during drilling to allow for visual logging of the materials encountered at each location. In the case of nested monitoring wells, only the deepest monitoring well at each location will be logged. The soil boring logs will provide additional understanding of the subsurface profile including the saturated soils. If silty or clayey soils are encountered in the deepest portion of samples retrieved during drilling, then a Shelby tube sample may be collected from the interval directly below the interval where silt or clay was observed to evaluate the vertical hydraulic conductivity. If silty or clayey soils are not encountered in the Shelby tube or the Shelby tube cannot be collected, then the observed silty or clayey interval will be targeted in other borings for collection of Shelby tube samples. Drilling and sampling activities will be performed under the direction of a Professional Geologist or Engineer, licensed in the State of Tennessee, who has sufficient experience to execute the work. The field geologist or engineer will prepare a written field log for each boring. In addition to describing each recovered soil sample, the log will document litholgy, boring location, drilling personnel, tooling/equipment used, drilling performance, depth to water, sample number, sample recovery, and other relevant observations. Similarly, the field geologist or engineer will prepare a written installation log for each well. The log will document soil description, well location, well materials, well depth and depth interval for each backfill material. Field documentation will also be prepared for development and slug testing of each well Soil Sampling Soil sampling will be conducted in the vadose zone to characterize CoC concentrations above the Fluvial Aquifer during monitoring well installation. Each of the monitoring well locations (single or cluster) illustrated on Figure 2 will include soil sampling. Grab soil samples from discreet two-foot depth intervals will be collected for laboratory analysis. Samples will be selected from two or three depths from each location: o o The shallowest interval exhibiting the presence of native soil; An intermediate depth sample (as determined by field observations); and, v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.3

65 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 o The deepest interval above the observed water table. Laboratory analysis will be conducted by Pace Analytical Laboratories, Inc. for CCR Parameters (as defined in Section 4.3). Sample containers, sample mass, preservation requirements, holding times and laboratory analytical methods will be conducted in accordance with Appendix E of the QAPP Shelby Tube Sampling Shelby tube soil samples may be collected from some deep well borings if silty or clayey soils are observed beneath the Fluvial Aquifer during the RI. Soil samples will be analyzed to estimate the hydraulic conductivity of the ex-situ soils by ASTM D Monitoring Well Installation Monitoring wells will be installed by qualified drill crews under the direction of a licensed Tennessee driller and a Professional Geologist or Engineer, licensed in the State of Tennessee. TVA and contractor personnel will assist by providing excavation (drill) permitting, utility clearances, and access to locations along with other site coordination. Monitoring wells will be installed in accordance with TVA s Technical Instruction Monitoring Well and Piezometer Installation and Development (ENV-TI ) Materials and Installation The monitoring wells will be installed using current industry and regulatory protocols to reduce potential for introducing contaminants during the drilling and installation process. Decontamination processes will be in accordance with TVA-ENV-TI , Field Sampling Equipment Cleaning and Decontamination. These procedures include, in part, decontamination of the drilling equipment and tools before and after each well by washing with hot, potable water delivered under high pressure, using new well screen and riser that have been cleaned and sealed in plastic at the factory, and placing washed filter pack sand that is certified by NSF International. Other steps employed during the installations include the workers donning clean, nitrile gloves during the handling of downhole equipment and well materials, and using potable water for grouting purposes. Monitoring wells will consist of a four-inch diameter Schedule 40 PVC U-Pack well screen ( inch slots) and riser. The screen and riser will consist of flush-joint, threaded PVC pipe. The screen length will be selected based on the results of the boring and the target stratum. Screen lengths will be 20 feet long for shallow wells to account for fluctuations in McKellar Lake. Intermediate and deep wells will have 10-ft. long screens. The intermediate wells will generally be screened approximately 20 feet deeper than the shallow wells. The deep wells will be screened on top of the lower confining clay unit. A four-inch diameter Schedule 40 PVC bottom well plug measuring v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.4

66 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 approximately five inches in length will be threaded onto the bottom of the screen. The PVC riser will extend above (2.5 feet minimum) the ground surface and will be capped with a temporary plug or slip cap. The annular space will be backfilled with a sand filter pack (20/40 mesh) extending a minimum of two feet above and six inches below the screen. A minimum two-foot thick bentonite pellet seal will be placed on top of the sand filter pack. After the bentonite pellet seal has sufficiently hydrated, the remaining annular space will be backfilled with a 30% solids bentonite grout. The grout will be placed by Tremie method. Subsequent wellhead construction will consist of an above-grade, steel locking protective cover anchored to a concrete surface pad. The protective cover will extend above the concrete pad and the annular space will be filled with sand or pea gravel to about six inches below the top of PVC casing. Steel protective bollards filled with concrete will be installed near each corner of the concrete pad Well Development Each new shallow monitoring well will be developed by a combination of bailing, surging, and pumping. Equipment will be decontaminated per TVA-ENV-TI First, a bailer will be lowered and raised within the screened intervals to create a slight surging action to dislodge particles within the wells and sand filter packs. A baseline reading of turbidity, ph, temperature, and specific conductance will be measured using a properly calibrated Oakton turbidity and PCSTestr 35 water testing meters (or equivalent). If the well contains heavy sediment, further bailing will be performed before continuation of development with surge blocks and submersible pumps. A surge block will be used within the screened interval to move water and particles through the screen and sand filter packs. This process may be repeated several times to decrease the water turbidity within the wells. Lastly, a submersible pump will be employed to further develop the wells until an acceptable level of turbidity is achieved. A target turbidity value of less than or equal to ten (10) Nephelometric turbidity units (NTUs) will be utilized for the wells. If the target turbidity value cannot practically be achieved, the achieved value will be documented along with the efforts made and a suspected reason for the result. Intermediate and deep monitoring wells will be developed with surge blocks and submersible pumps Slug Testing After development, slug testing will be performed in each monitoring well to measure hydraulic conductivity. Equipment will be decontaminated per TVA-ENV-TI The slug tests will be performed in accordance with ASTM D4044, Standard Test Method for (Field Procedure) for Instantaneous Change in Head (Slug) Tests for Determining Hydraulic Properties of Aquifers. A pressure transducer with a data recorder will be used to collect water level information from the wells. As part of the slug testing, each well will be tested by taking an initial measurement of the static water level followed by the insertion of the pressure transducer into the well. After the transducer v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.5

67 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 has been installed, a solid slug (e.g., acrylic rod) will be introduced into the well to cause a nearly instantaneous change in the water level. The water levels will then be recorded at regular intervals until reaching near static levels. After reaching static levels, the test will be terminated and a second slug test will be conducted by instantaneously removing the slug and monitoring water levels until static levels are reached again. The results will be recorded electronically and downloaded into a data collector. Raw data will be checked in the field for discrepancies prior to demobilizing from the site. The field data, once collected and returned to the office, will be reduced using a software program to estimate the hydraulic conductivity of the in-situ soils Installation of Dedicated Sampling Pumps New dedicated sampling pumps will be installed in the new groundwater monitoring wells after well development and slug testing are completed. The well depths and static groundwater levels will be measured during well development to place the pumps at the proper intake depths for future well sampling. The pump intake depth will be located at approximately the mid-point of the well screen or the mid-point of the saturated portion of the well screen. Well pump placement depths and additional pump installation calculations and details will be recorded on field forms Field Equipment Description, Testing/Inspection, and Maintenance Field equipment will be inspected, tested, and calibrated (as applicable) prior to initiation of fieldwork by the field team members and, if necessary, repairs will be made prior to equipment use. If equipment is not in the proper working condition, that piece of equipment will be repaired or taken out of service and replaced prior to use. Additional information regarding field equipment inspection and testing is included in Section 12.1 of the QAPP. For instruments requiring field calibration, documented calibrations will be conducted at the frequency recommended by the manufacturer, TVA TIs, or the QAPP. Personnel performing instrument calibrations/standardizations shall be trained in its proper operation and calibration. Records of instrument calibration/standardization will be maintained in the project files. Additional information regarding field equipment calibration is included in Sections 13.0 and 13.1 of the QAPP Water Quality Meter Calibration Requirements Manufacturer s instructions will be followed for water quality instrument calibration. The water quality meter(s) will be equipped with automatic temperature correction for ph and therefore calibration of the instruments will account for any changes in buffer temperature. It is noted that field ph meters will not be calibrated according to the acceptance criteria published in SW-846 Method 9040C (this is a fixed laboratory method). The acceptance criteria of +/- 0.1 ph units (EPA Region 4 SESDPROC-100-R3, January 2013) has been established for regulatory applications by v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.6

68 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 EPA Region 4 Science and Ecosystem Support Division and are appropriate for field ph readings under the ALF RI. A one-point water saturated air method of calibration will be used for the dissolved oxygen probe on the water quality meter Field Documentation Field documentation will be maintained in accordance with TVA TI ENV , Field Record Keeping and the QAPP. Field documentation associated with RI activities will primarily be recorded on site-specific field forms logbooks and/or on digital media (e.g., GIS/GPS documentation). Additional information regarding field documentation is provided below and included in Sections 6.0 and 6.1 of the QAPP Daily Field Activities Field observations and measurements will be recorded and maintained daily to chronologically document field activities, including sample collection and management. Field observations and measurements will be recorded in bound, waterproof, sequentially paginated field logbooks and/or on digital media and field forms. Deviations from applicable work plans will be documented in the field logbook during sampling and data collection operations. The TVA Technical Lead and the QA Oversight Manager or designee will approve deviations before they occur Field Forms Project-specific field forms will be used to record field measurements and observations for specific tasks. Boring log forms will be used to document lithologic conditions and field observations at each boring location. Monitoring well construction diagrams will be prepared for each well. Field documentation will also be prepared for development of each monitoring well Photographs In addition to documentation of field activities as previously described, photographs of site activities will also be used to document the field investigation. A photo log will be developed, and each photo in the log will include the location, date taken, and a brief description of the photo content, including direction facing for orientation purposes Equipment Decontamination Procedures Monitoring Well Installation Documented decontamination will be performed for drilling equipment, tooling, and instruments in contact with subsurface materials in accordance with TVA TI ENV-TI , Field Sampling Equipment Cleaning and Decontamination to prevent cross-contamination. Decontamination fluids will be containerized, if required, and disposed of in accordance with ALF waste disposal v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.7

69 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 policies. If collection and containerization of decontamination fluids is required, then, decontamination pads will be constructed for decontamination of large downhole tooling (augers, drill rods, etc.) using a high-pressure washer/steam cleaner. Decontamination pads will be constructed at locations designated by TVA personnel using poly sheeting with sufficient berms to contain decontamination fluids and prevent potential runoff to uncontrolled areas. Following decontamination, fluids will be pumped into a drum for storage, transportation, and ultimately disposal in accordance with ALF waste disposal policies. Decontamination activities will be performed away from surface water bodies and areas of potential impacts. Decontamination of non-disposable sampling equipment or instruments can be performed using water and Liquinox and/or other appropriate non-phosphatic detergent in 5-gallon buckets. Decontamination of sampling equipment and instruments (e.g., water level meters, pumps for well development, etc.) will be performed prior to use and between sampling locations. Decontamination activities will be documented in the logbook field notes. Additional information regarding equipment decontamination procedures is located in Section 8.2 of the QAPP Waste Management Investigation-derived waste (IDW) generated at the site during this RI may include soil cuttings, development water, decontamination fluids, and general trash. Soil cuttings and well development water generated during drilling will be thin-spread or discharged at the ground surface adjacent to the boreholes in most locations. In some areas, it may be necessary to capture cuttings due to the sensitive nature of the drill site or volume of cuttings generated. In these cases, IDW will be transported to an area approved by plant personnel. Distribution of cuttings and discharge of water should also be performed in a manner so as not to not create a safety hazard. General trash will be containerized and disposed of as municipal waste or recycled as appropriate. Disposal of IDW will be coordinated with plant personnel. If directed by TVA, soil cuttings and well development water will be containerized in drums for transport and storage. In these cases, IDW will be transported to an area approved by plant personnel. Decontamination fluids will be containerized and disposed of in accordance with TVA waste disposal policies. 5.3 GROUNDWATER SAMPLE COLLECTION AND FIELD ACTIVITY PROCEDURES This section provides details of procedures that will be used to prepare for field activities, collect groundwater samples and take groundwater and surface water elevation measurements. A v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.8

70 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 complete description of the ALF environmental investigation QA requirements is provided in Section 11 of the QAPP. Groundwater sampling will adhere to applicable U.S. EPA and TVA Environmental Technical Instruction (TI) documents. A project field book and field forms will be maintained by the sampling team leader to record field measurements, analyses, and observations. Field activities will be documented according to TVA TI ENV-TI , Field Record Keeping Preparation for Field Activities As part of field mobilization activities, the field sampling team will conduct the following: Complete required health and safety documentation and confirm field team members have completed required training; Coordinate field activities with the Laboratory Coordinator, including ordering sample bottles and preservatives, obtaining coolers and distilled water, if needed, and notifying the laboratory of sampling dates; Obtain required field instruments, including health and safety equipment, water level meters, and equipment needed for measuring parameters that define stability during well purging; Obtain a control box for dedicated pumps; and Complete sample documentation to the extent possible, including chain-of-custody forms and sample labels. The field team will obtain ice prior to sample collection for sample preservation Sampling Methods and Protocol Groundwater Level Measurements Prior to sampling, each monitoring well and staff gauge will be inspected for damage or indications that the well integrity has been compromised. If field observations indicate the need for well or staff gauge maintenance or repairs, the field team leader will notify TVA. After the monitoring well and staff gauge integrity inspection is completed, the water level in each well and at each staff gauge will be measured in relation to a surveyed reference point (e.g., top of well casing) using an electronic water level indicator. Groundwater elevation data will be measured and recorded in accordance with TVA s Environmental TI document TVA-ENV-TI , Groundwater Level and Well Depth Measurement. The elevation will be recorded to the nearest 0.01 foot. To the extent possible, the field team will minimize the length of time between v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.9

71 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 collection of the first and last water level measurement for the monitoring well network and staff gauges. At a minimum, measurements will be made within the same day. The water level indicator will be decontaminated between each well by following the decontamination procedures provided below in Section Well Purging Following the measurement of groundwater levels, monitoring wells will be purged using pumps dedicated to each well. Purging will continue until field measurements of water quality parameters stabilize during three consecutive readings at 3 to 5 minute intervals per the criteria listed in TVA s Environmental TI document ENV-TI : Groundwater Sampling. The stabilization criteria follow: ph - ±0.1; Specific conductivity - ±5%; Dissolved oxygen (DO) - ±10% for 0.5 mg/l or <0.5 mg/l; and Turbidity - below 10 NTUs or ±10% for values above 10 NTUs. Field measurements, including ph, specific conductivity, turbidity, oxidation/reduction potential, temperature, and ferrous iron (using field test kits) will be collected during purging using a flowthrough cell. Once the field parameters have stabilized after three consecutive readings, samples will be collected. For low yield wells, field parameters will be measured at the time of sample collection in an open sample container using a multi-parameter probe. Final turbidity and water level measurements will be made after each sample is collected. If after two hours of purging field parameters have not stabilized, then groundwater samples will be collected and the efforts to stabilize parameters will be recorded in the field log book and field data sheet. A final turbidity measurement will be made after each sample is collected. Low-flow purging techniques will be used to collect a representative sample from the water bearing formation unless the wells do not yield sufficient water. If the well has been sampled historically using low-flow sampling methods, then the well will be purged at the rate known to induce minimal drawdown. If pump settings are unknown, purging will begin at a minimum pumping rate of 0.1 liter per minute (L/min) and will be slowly increased to a setting that induces little or no drawdown, if possible. Pumping rates will not exceed 0.5 L/min. If drawdown exceeds 0.3 feet, but reaches stability, purging of the well will continue and the current flow rate, drawdown, and time will be recorded on the field data sheet by the sampler. For vertical groundwater samples, the purge time will be reduced to no more than 30 minutes or less depending on field conditions. Groundwater samples for laboratory analysis will be collected v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.10

72 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 if the ph is 7.5 SU or greater. Purged groundwater with a ph of 7.5 or higher will be collected for analysis prior to disposal. Purging beginning and end times, pumping rates, water quality parameter readings, and groundwater levels will be recorded throughout the purging operation on field sampling forms. The total volume purged at each well may vary based on recharge rates and stabilization of water quality parameters. Low yield wells will be purged until standing water is removed. Groundwater samples will be collected with a low-flow pump, as soon as sufficient water returns within the well bore to obtain the necessary sample volume, but no later than 24 hours after the well purge Collection of Samples Groundwater Sampling A final reading of water quality parameters will be conducted and documented on field sampling forms at the time of sample collection, but these measurements will not be from the sample itself. Unfiltered groundwater samples will be collected in appropriate, laboratory provided, pre-preserved sample containers. Samples will be collected directly from the pump discharge line. The sampler will wear clean latex (or equivalent) gloves when handling sample containers and will not touch the interior of containers or container caps. New gloves will be used when handling each sample set. When filling sample bottles, care will be taken to minimize sample aeration (i.e., water will be directed down the inner walls of the sample bottle) and avoid overfilling and diluting preservatives. Each sample bottle will be capped before filling the next bottle. It will be necessary to collect filtered (dissolved) inorganic constituent samples, in addition to unfiltered (total) inorganic constituent samples, if the final turbidity value prior to sampling exceeds 10 NTUs. Dissolved sample collection will be accomplished in accordance with ENV-TI Issues that could affect the quality of samples will be recorded on the field data sheet or in the log book along with the action(s) taken to resolve the issue. These could include observations such as clogged sampling tubes, highly turbid samples or defective materials or equipment. Preservation and Handling Sample containers will be labeled in accordance with TVA TI ENV , Sample Labeling and Custody. Once each sample container is filled, the rim and threads will be cleaned by wiping with a clean paper towel and capped, and a signed and dated individual custody seal will be applied. Each sample container will be checked to ensure that it is sealed, labeled legibly, and externally clean. Sample containers will be packaged in a manner to prevent breakage during shipment. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.11

73 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 Coolers will be prepared for shipment in accordance with TVA TI ENV , Handling and Shipping of Samples by taping the cooler drain shut and lining the bottom of the cooler with packing material or bubble wrap. Sample containers will be placed in the cooler in an upright single layer. Small uniformly sized containers will be stacked in an upright configuration, and packing material will be placed between layers. Plastic containers will be placed between glass containers when possible. A temperature blank will be placed inside each cooler to measure sample temperature upon arrival at the laboratory. Loose ice will be placed around and among the sample containers to ensure that the samples remain less than 6 degrees Celsius (ºC) during shipment. The cooler will be filled with additional packing material to ensure containers are secure. The original COC form will be placed in a resealable plastic bag taped to the inside lid of the cooler. A copy of the COC form will be retained with the field notes in the project files. A unique cooler ID number will be written on the COC form and the shipping label placed on the outside of the cooler. The total number of coolers required to ship the samples will be recorded on the COC form. If multiple coolers are required to ship samples contained on a single COC form the original copy will be placed in cooler 1 of X with copies (marked as such) placed in the additional coolers. Two signed/dated custody seals will be placed on alternate sides of the cooler lid. Packaging tape (i.e., strapping tape) will be wrapped around the cooler to secure the sample shipment. Upon receipt of the samples, the analytical laboratory will open the cooler and will sign "received by laboratory" on each COC form. The laboratory will verify that the custody seals have not been broken previously and that the seal number corresponds with the number on the COC form. The laboratory will note the condition and temperature of the samples upon receipt and will identify any discrepancies between the contents of the cooler and COC form. If there are any discrepancies the laboratory project manager will immediately call the Laboratory Coordinator and Field Team Leader to resolve the issue and note the resolution on the laboratory check-in sheet. The analytical laboratory will then forward the back copy of the COC form to the QA Manager and Investigation Consultant Project Manager Sample Analyses Groundwater samples will be submitted to the TVA-approved laboratory for analysis. Samples will be analyzed for the CCR related constituents listed in Title 40 of the Code of Federal Regulations Part 257 (40 CFR 257), Appendices III and IV. In addition, five inorganic constituents listed in Appendix 1 of TN Rule (i.e., TDEC regulations), and not included in the 40 CFR 257Appendices III and IV, will be analyzed to maintain continuity with TDEC environmental programs. The additional constituents listed in TDEC Appendix 1 include the following metals: copper, nickel, silver, vanadium, and zinc. The combined federal CCR Appendices III and IV constituents, and TDEC Appendix 1 inorganic constituents, will hereafter be referred to collectively as CCR Parameters. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.12

74 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 For geochemical evaluation, major cations/anions not included in the CCR Parameters are included in the analyses for this SAP. The additional geochemical parameters include magnesium, potassium, sodium, carbonate and bicarbonate. Table 1 through Table 4 summarize the constituents requiring analysis. Analytical methods, preservation requirements, container size, and holding times for each chemical analysis are presented in Table 5. Additional sampling and laboratory-specific information is covered in more detail in Sections 8 through 10 of the QAPP. Table CFR Part 257 Appendix III Constituents Appendix III Constituents Boron Calcium Chloride Fluoride ph Sulfate Total Dissolved Solids Table CFR Part 257 Appendix IV Constituents Appendix IV Constituents Antimony Arsenic Barium Beryllium Cadmium Chromium Cobalt Fluoride Lead Lithium Mercury v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.13

75 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 Appendix IV Constituents Molybdenum Selenium Thallium Radium 226 and 228 Combined Table 3. TN Rule , Appendix 1 Inorganic Constituents TDEC Appendix 1 Constituents* Copper Nickel Silver Vanadium Zinc * Constituents not listed in CCR Appendices III and IV Table 4. Additional Geochemical Parameters Major Cations/Anions Bicarbonate Carbonate Magnesium Potassium Sodium * Constituents not included in the CCR Parameters v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.14

76 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 Table 5. Parameter Groundwater Analytical Methods, Preservatives, Containers, and Holding Times Analytical Methods Preservative(s) Container(s) Holding Times Metals, dissolved SW HNO3 to ph < 2 Cool to <6 C Metals, total SW HNO3 to ph < 2 Cool to <6 C 250-mL HDPE 250-mL HDPE 180 days 180 days Mercury, dissolved SW HNO3 to ph < 2 Cool to <6 C Mercury, total SW HNO3 to ph < 2 Cool to <6 C Arsenic Species Pace SOP S-MN-I- 608_rev.01 EDTA Cool to <6 C Radium 226 EPA HNO3 to ph < 2 Cool to <6 C Radium 228 EPA HNO3 to ph < 2 Cool to <6 C 250-mL HDPE 250-mL HDPE 250-mL HDPE* 28 days 28 days 28 days 1 L HDPE 180 days 2 L HDPE 180 days Chloride SW Cool to <6 C 250-mL HDPE 28 days Fluoride SW Cool to <6 C 250-mL HDPE 28 days Sulfate SW C 250-mL HDPE 28 days ph Alkalinity (Total, Carbonate, and Bicarbonate) (field measurement) The ph of groundwater samples will be measured in the field. NA NA 15 minutes SM2320B Cool to <6 C 250-mL HDPE 14 days *The volume for arsenic species will be field-filtered Field Documentation Field documentation will be maintained in accordance with TVA TI ENV , Field Record Keeping. Field documentation associated with investigation activities will primarily be recorded in site-specific field forms logbooks and/or on digital media (e.g., GIS/GPS documentation). Daily Field Activities Field observations and measurements will be recorded and maintained daily to chronologically document field activities, including sample collection and management. Field observations and v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.15

77 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Field Activity Procedures September 15, 2017 measurements will be recorded in bound, waterproof, sequentially paginated field logbooks and/or on digital media and field forms. Deviations from applicable work plans will be documented in the field logbook during sampling and data collection operations. The TVA Technical Lead and the QA Oversight Manager or designee will approve deviations before they occur. Field Forms Project-specific field forms will be used to record field measurements and observations for specific tasks. TVA groundwater sampling forms will be used to document groundwater level measurements, stabilization parameters and field observations at each monitoring well location. Chain-of-Custody Forms For the environmental samples to be collected, chain-of-custody (COC) forms, shipping documents, and sample logs will be prepared and retained. Field QC samples and field measured ph values will be documented in both the field notes (logbooks and field forms) and on sample COC records. Such records will be reviewed daily by the Field Team Leader and Field Oversight Coordinator for completeness and a QC check of samples in each cooler compared to sample IDs on the corresponding COC form. The Investigation Consultant will staff the project with a field sample manager during sample collection activities. Additional information regarding COC forms is included in Section of this SAP and Section of the QAPP Equipment Decontamination Procedures Groundwater Sampling Documented decontamination will be performed for non-dedicated groundwater sampling equipment in contact with groundwater or surface water in accordance with TVA TI ENV-TI , Field Sampling Equipment Cleaning and Decontamination to prevent crosscontamination. Pumps are dedicated to each well and do not need to be decontaminated. Decontamination activities will be performed away from surface water bodies and areas of potential impacts. Decontamination of non-disposable sampling equipment or instruments can be performed using water and Liquinox and/or other appropriate non-phosphate detergent in 5-gallon buckets. Following decontamination, fluids will be disposal in accordance with TVA waste disposal policies. Decontamination of sampling equipment and instruments (i.e., water level meters, etc.) will be performed prior to use and between sampling locations. Decontamination activities will be documented in the logbook field notes. Additional information regarding equipment decontamination procedures is located in Section 8.2 of the QAPP. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 5.16

78 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Quality Assurance/Quality Control September 15, QUALITY ASSURANCE/QUALITY CONTROL The QAPP describes quality assurance (QA)/quality control (QC) requirements for the overall ALF RI. The following sections provide details regarding QA/QC objectives and quality control checks for the installation of groundwater monitoring and observation wells. 6.1 OBJECTIVES The Data Quality Objectives (DQOs) process is a tool employed during the project planning stage to ensure that data generated from an investigation are appropriate and of sufficient quality to address the investigation objectives. TVA and the Investigation Consultant informally considered key components of the DQO process in developing this RI-specific SAP to guide the data collection efforts for the ALF RI. QA/QC procedures applicable to RI activities presented in this SAP include: Field Documentation Record Keeping Equipment Testing/Inspection, Calibration, and Maintenance Equipment Decontamination Specific quantitative acceptance criteria for analytical precision and accuracy for the matrices included in this investigation are presented in Section 19 of the QAPP. 6.2 QUALITY CONTROL CHECKS The accuracy of the drilling, monitoring well installation, soil sampling, groundwater sampling, and slug testing processes must be maintained throughout the investigation. In addition, planned drilling and installation methods must be confirmed during field activities to provide confidence that soil samples, groundwater samples and water level measurements collected as part of this SAP provide representative analytical results and data. Field personnel will be responsible for performing checks to confirm that the SAP has been followed. This consists of the completion of applicable field forms and documentation of field activities. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 6.1

79 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Quality Assurance/Quality Control September 15, Soil Sampling Four types of field QA/QC samples will be collected during soil sampling activities: field duplicate samples, matrix spike/matrix spike duplicate (MS/MSD) samples, equipment blanks and field blanks. QA/QC samples will be collected in accordance with TVA TI ENV-TI , Field Sampling Quality Control. Criteria for the number and type of QA/QC samples to be collected for each analytical parameter are specified below. A complete description of the ALF environmental investigation QA requirements is provided in QAPP Section Duplicate Samples One duplicate sample will be collected for every ten soil samples or once per sampling event. Duplicates samples will be prepared as blind duplicates and will be collected in two sets of identical, laboratory-prepared sample bottles. The primary and duplicate samples will be labeled according to the procedures in Section Sample identifier information will not be used to identify the duplicated samples. Actual sample identifiers for duplicate samples will be noted in the field logbook. The duplicate sample will be analyzed for the same parameters as the primary sample. MS/MSD Samples A sufficient quantity of soil will be collected for use as the MS/MSD. MS/MSD samples will be collected to allow matrix spike samples to be run to assess the effects of matrix on the accuracy and precision of the analyses. One MS/MSD sample will be analyzed for every 20 soil samples collected or once per sampling event. Additional sample quantity intended for use as the MS/MSD must be identified in the comments field on the COC records and sample labels. The location of sample collection will be noted in the log book. The MS/MSD sample will be analyzed for the same analytes as the primary sample, with the exception of parameters that are not amenable to MS/MSD. Equipment Blanks (Rinsate Blanks) One equipment (rinsate) blank will be collected for each sampling event. The equipment blank will be collected at a soil sampling location by pouring laboratory-provided deionized water into or over the decontaminated sampling equipment (e.g., a decontaminated DPT liner or similar down-hole sampling equipment), then into the appropriate sample containers. The time and location of collecting the equipment blank will be noted in the log book. The sample will be analyzed for the same analytes as the sample collected from the soil sampling location where the equipment blank is prepared. Field Blanks One field blank sample will be prepared per day using laboratory-supplied deionized water. Field blanks will be prepared in the field by pouring deionized water into sample containers. The field blanks will be preserved, packaged and sealed in the manner used for environmental samples. The blanks will be labeled in accordance with Section and will be submitted blind to the laboratory. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 6.2

80 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Quality Assurance/Quality Control September 15, Groundwater Sampling Five types of field QA/QC samples will be collected during groundwater sampling activities: field duplicate samples, matrix spike/matrix spike duplicate (MS/MSD) samples, equipment blanks, field blanks, and filter blanks. QA/QC samples will be collected in accordance with TVA TI ENV-TI , Field Sampling Quality Control. Criteria for the number and type of QA/QC samples to be collected for each analytical parameter are specified below. A complete description of the ALF environmental investigation QA requirements is provided in QAPP Section Duplicate Samples One duplicate sample will be collected for every ten groundwater samples or once per sampling event. Duplicates samples will be prepared as blind duplicates and will be collected in two sets of identical, laboratory-prepared sample bottles. The primary and duplicate samples will be labeled according to the procedures in Section Sample identifier information will not be used to identify the duplicated samples. Actual sample identifiers for duplicate samples will be noted in the field logbook. The duplicate sample will be analyzed for the same parameters as the primary sample. MS/MSD Samples A sufficient volume of groundwater will be collected for use as the MS/MSD. MS/MSD samples will be collected to allow matrix spike samples to be run to assess the effects of matrix on the accuracy and precision of the analyses. One MS/MSD sample will be analyzed for every 20 groundwater samples collected or once per sampling event. Additional sample volume intended for use as the MS/MSD must be identified in the comments field on the COC records and sample labels. The location of sample collection will be noted in the log book. The MS/MSD sample will be analyzed for the same analytes as the primary sample, with the exception of parameters that are not amenable to MS/MSD. Equipment Blanks (Rinsate Blanks) One equipment (rinsate) blank will be collected for each sampling event. The equipment blank will be collected at a groundwater sampling location by pouring laboratory-provided deionized water into or over the decontaminated sampling equipment (e.g., a decontaminated water level meter), then into the appropriate sample containers. The time and location of collecting the equipment blank will be noted in the log book. The sample will be analyzed for the same analytes as the sample collected from the monitoring well location where the equipment blank is prepared. Field Blanks One field blank sample will be prepared per day using laboratory-supplied deionized water. Field blanks will be prepared in the field by pouring deionized water into sample containers. The field blanks will be preserved, packaged and sealed in the manner used for environmental samples. The blanks will be labeled in accordance with Section and will be submitted blind to the laboratory. Filter Blanks One filter blank will be collected during each day of the groundwater sampling activities when dissolved parameters are collected for analysis. The filter blank will be collected at a groundwater sampling location by passing laboratory-supplied deionized water through in- v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 6.3

81 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Quality Assurance/Quality Control September 15, 2017 line filters used in the collection of dissolved metals (or other analytes), then into the appropriate sample containers. The time and location of collecting the filter blank will be noted in the log book. The sample will be analyzed for the same analytes as the sample collected from the location where the filter blank is prepared. In addition, one filter blank will be collected per lot of filters used. The filter lot check is to be performed one per lot of filters used and scheduled in a manner to allow for laboratory to report data prior to investigative sample collection Sample Labels and Identification System Sample IDs will be recorded on all sample container labels, custody records, and field sheets in accordance with TVA TIs ENV-TI , Sample Labelling and Custody and ENV-TI , Field Record Keeping. Each sample container will have a sample label affixed and secured with clear package tape as necessary to ensure the label is not removed. Information on sample labels will be recorded in waterproof, non-erasable ink. Specific information regarding sampling labeling and identification is included in Appendix D of the QAPP Chain-of-Custody The possession and handling of individual samples must be traceable from the time of sample collection until the time the analytical laboratory reports the results of sample analyses to the appropriate parties. Field staff will be responsible for sample security and record keeping in the field. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 6.4

82 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Assumptions and Limitations September 15, ASSUMPTIONS AND LIMITATIONS This SAP was prepared based on the following assumptions: Field locations may be adjusted based on actual site conditions; Proposed monitoring and observation well locations can be safely accessed; The confining unit at the base of the Fluvial Aquifer is present and readily identifiable at the proposed monitoring well locations; and Access to well locations will be provided prior to the field preparation start date for each round of sampling. v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 7.1

83 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT References September 15, REFERENCES ASTM D4044, Standard Test Method for (Field Procedure) for Instantaneous Change in Head (Slug) Tests for Determining Hydraulic Properties of Aquifers. ASTM D5084, Standard Test Methods for Measurement of Hydraulic Conductivity of Saturated Porous Materials Using a Flexible Wall Permeameter. ENV-TI , Groundwater Sampling ENV-TI , Field Record Keeping ENV-TI , Groundwater Level and Well Depth Measurement ENV-TI , Handling and Shipping of Samples ENV-TI , Field Sampling Equipment Cleaning and Decontamination ENV-TI , Field Sampling Quality Control ENV-TI , Sample Labelling and Custody ENV-TI , Field Measurement Using a Multi-Parameter Sonde ENV-TI , Field Record Keeping ENV-TI , Field Sampling Equipment Cleaning and Decontamination ENV-TI , Monitoring Well and Piezometer Installation and Development Field Standardization of Instruments Form (TVA [ ]) U.S. EPA Region 4. Environmental Investigations Standard Operating Procedures and Quality Assurance Manual, November US EPA Region 4. Field ph Measurement, SESDRPOC-100-R3, January v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx 8.1

84 SAMPLING AND ANALYSIS PLAN ALLEN FOSSIL PLANT Attachment A - Figures September 15, 2017 ATTACHMENT A FIGURES v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_a_sap\ _sap_alf_remedial.docx

85 ( $ $ 1 G P-4 # V A 8 B ALF WW 23 C 24 D * & Gro und wa t e rmo nit oring W e ll # V Obs e rva t ion Mo nit o ring W e ll * & P ro p os e d DP TL o ca t io ns ain-3 0-inc 37 Forc em F eet S e e p Wa t e rsa m p le L oca t ion h P ot e nt ia ldp TBo ring s ( 72) * & GP ALF-206 GP ALF Legend P re p a re d byt Ro n T e chnica lre vie w byl P o n : 1, 800( Ato rig ina ld o cum e nts ize o f 22x 34) T e nne s s e e Va lle yaut ho rit y Alle n Fo s s ilp la nt 0 1-WW Clie nt / P roje ct East Ash Pond Complex DPT Sample Locations ALF-204 F T it le Me m p his,t e nne s s e e P ro je ctl o ca t io n 74 E 4 P F ig ure No. Act ive Sa nit a ryse we r GP-83 * & I na ct ive Sa nit a ryse we r GP-85 GP-81 * & * & GP-86 * & 39 Forc B/P- e Main 30-in ch * & GP-87 * & Gravity ( Aband)-6 0 -inch Grav it y-42 * & ALF-213 GP-88 -inch 44 GP-82 Notes 1. Co o rd ina t e Syst e m :NAD1983St at e P la ne T e nne s s e e F I P S4100F eet 2. I m a g e ryp ro vid e d byt e rra S e rve r ( 2016)& T VA( 2015) 3. Bo ring s wille x t e nd t o a d e pt h o f 50 be lo w g ro und s urfa ce o r t he bo t t om of t he a s h,whiche ve r is s ha llo we r. 46 * & GP-89 U: \T VAEI P \ \g is\m x d s \ACC\AL F _ Ea s t As hp o nd _ DP T _L oca t ions. mx d Re vis e d : By:T Rink Gravity -9 6-inch ALF Arkansas De S ot o L ee Mississippi 71 Alle n F o s s ilp la nt ALF F a ye t t e 62 S he lby _ ^ S t.f ra ncis Tennessee Crit t e nd e n Cros s ALF Ma rs ha ll Be nt on 72 T unica T at e Dis cla im e r:s t a nt e ca s s um e s no re s p o ns ibilit yfo r d a t a s up p lie d in e le ct ro nicfo rm a t.t he re cip ie nta cce p t s fullre s p o ns ibilit yfo r ve rifying t he a ccura cya nd co m p le t e ne s s o f t he d a t a.t he re cip ie ntre le a s e s St a nt e c,it s o ffice rs,e m p lo ye e s,co ns ult a nt s a nd a g e nt s,fro m a nya nd a llcla im s a ris ing in a nywa yfro m t he co nt e nto r p ro vis io n o f t he d a t a. P a g e 01o f 01

86 ( Figure No. 2 Title $ $ # V P-2 # V Client/Project Tennessee Valley Authority Allen Fossil Plant Project Location P Prepared by TR on Technical Review by LP on Memphis, Tennessee # V P-4-S P-4 # A ALF-203-B ALF-203-A ALF-203 ALF-204 ALF-204-B ALF-204-A ALF-205 Harsco Well :3,000 (At original document size of 22x34) ALF-205-B ALF-205-A 1,000 Feet Legend ( Abandoned ( ALF-206 ( ALF-210-A Proposed Monitoring Well Locations ( Groundwater Monitoring Well # V Observation Monitoring A Proposed Nested Groundwater Monitoring Well # V Staff Gauge Location * & 2017 Production Well ALF-213 ( ALF-210 A ALF-214 ALF-214-B A ALF-201-B ALF-201-A ALF-201 A ALF-202-B ALF-201-A ( A ALF-212-A A ( Notes Well #4 ALF-215 * A Well #5 U:\TVA-EIP\ \gis\mxds\ACC\ALF_Proposed_Nested_Monitoring_Wells_ mxd Revised: By: TRink * & A Well #3 * & 1. Coordinate System: NAD 1983 StatePlane Tennessee FIPS 4100 Feet 2. Imagery Provided by TVA (2015) 3. Exisiting Monitoring Wells are referenced from TVA Drawing 10W Allen Fossil Plant Reservation. 4. The total depth of the deep wells will depend on the observed depths of the underlying confing layer. Upon completion, the well ID will incorporate the depth of the screen interval (e.g. ALF-201-B will be named ALF Cross Well #2 Arkansas Well #1 * & Shelby _ ^ St. Francis * & Tennessee Crittenden Fayette Allen Fossil Plant DeSoto Lee Mississippi Marshall Benton Tunica Tate Disclaimer: Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data. Page 01 of 01

87 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Appendix B Quality Assurance Project Plan September 15, 2017 QUALITY ASSURANCE PROJECT PLAN

88 QUALITY ASSURANCE PROJECT PLAN FOR THE TENNESSEE VALLEY AUTHORITY ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION Revision 0 September 2017 Prepared by: ENVIRONMENTAL STANDARDS, INC Valley Forge Road P.O. Box 810 Valley Forge, PA Prepared for: TENNESSEE VALLEY AUTHORITY 1101 Market Street Chattanooga, TN Environmental Standards, Inc. - All Rights Reserved

89 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September TABLE OF CONTENTS 1.0 TABLE OF CONTENTS QUALITY ASSURANCE PROJECT PLAN DESCRIPTION BACKGROUND QUALITY ASSURANCE PROGRAM ORGANIZATION, MANAGEMENT, AND RESPONSIBILITIES TVA Compliance Lead TVA Technical Lead Investigation Consultant Project Manager Field Team Leaders Field Sampling Personnel Analytical Laboratories Laboratory QA Officer... 9 Laboratory Project Manager Laboratory Sample Custodian Laboratory Analyst QA Functions QA Oversight Manager Data Validators Field Oversight Coordinators Data Manager PROJECT DESCRIPTION AND APPLICABILITY PURPOSE AND SCOPE SCHEDULE QAPP DISTRIBUTION AND REVISION DATA QUALITY OBJECTIVES PROCESS SPECIAL TRAINING/CERTIFICATIONS DOCUMENTATION AND RECORDS FIELD DATA DOCUMENTATION LABORATORY DATA DOCUMENTATION Laboratory Data Reporting/Deliverable Package RECORD KEEPING DATA ARCHIVAL SAMPLING PROCESS DESIGN SAMPLING METHODS REQUIREMENTS SAMPLE CONTAINERS, PRESERVATION, AND HOLDING TIMES DECONTAMINATION SAMPLE HANDLING AND CUSTODY REQUIREMENTS SAMPLE DOCUMENTATION Chain of Custody Record Sample Custody in the Field SAMPLE PACKAGING AND SHIPMENT SAMPLE CUSTODY IN THE LABORATORY Sample Receipt Sample Storage

90 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September Sample Tracking SAMPLE ARCHIVE ANALYTICAL METHODS REQUIREMENTS FIELD ANALYSIS LABORATORY ANALYSIS QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS GENERAL FIELD AND LABORATORY QUALITY CONTROL SAMPLES Equipment Rinsate Blanks Field Blanks Filter Blank Samples Field Duplicate Samples Matrix Spike/Matrix Spike Duplicate Laboratory Method Blanks Laboratory Control Samples/Laboratory Control Sample Duplicates Laboratory Duplicate Samples INSTRUMENT/EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE REQUIREMENTS FIELD EQUIPMENT SUPPLIES AND CONSUMABLES LABORATORY EQUIPMENT Instrument Maintenance Logbooks Instrument Calibration and Maintenance INSTRUMENT CALIBRATION AND FREQUENCY FIELD EQUIPMENT CALIBRATION AND PROCEDURES LABORATORY EQUIPMENT CALIBRATION DATA ACQUISITION REQUIREMENTS FOR NON-DIRECT MEASUREMENTS DATA MANAGEMENT ASSESSMENTS AND RESPONSE ACTIONS FIELD ACTIVITIES LABORATORY ANALYSIS Data Reduction Laboratory Data Review PERFORMANCE AND SYSTEM AUDITS Performance Audits System Audits FEEDBACK AND CORRECTIVE ACTION Feedback Mechanism Corrective Action for Field Activities Laboratory Corrective Action REPORTS TO MANAGEMENT FIELD QA REPORTS LABORATORY QA REPORTS INTERNAL PERFORMANCE AND SYSTEM AUDIT/ASSESSMENT REPORTS

91 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September DATA REVIEW, VERIFICATION, AND VALIDATION VERIFICATION AND VALIDATION METHODS PRECISION ACCURACY COMPLETENESS REPRESENTATIVENESS COMPARABILITY RECONCILIATION OF DATA TO PROJECT OBJECTIVES REFERENCES Figures Figure 2-1 Organization Chart and Lines of Communication for the ALF RI... 5 Figure 16-1 Critical Path for Laboratory Correction Action Tables Table 2-1: Analytical Laboratories for ALF RI... 9 Table 11-1: Field Quality Control Sample Minimum Frequency Attachments Attachment A: Data Package Deliverables Requirements... A-1 Attachment B: Sampling Procedures List... B-1 Attachment C: Example Chain of Custody Record... C-1 Attachment D: Sample Nomenclature... D-1 Attachment E: Investigation-Specific Quality Control Requirements, Soil Sampling... E-1 Attachment F: Investigation-Specific Quality Control Requirements, Groundwater Investigation Sampling... F-1 3

92 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September QUALITY ASSURANCE PROJECT PLAN DESCRIPTION 2.1 Background The primary goal of this Tennessee Valley Authority (TVA) Allen Fossil Plant (ALF) Remedial Investigation Quality Assurance Project Plan (ALF RI QAPP) is to confirm that the objectives of the ALF RI are met by TVA consultants and contractors generating documented, high-quality, reliable investigative/analytical data. This document describes the quality assurance (QA) requirements for work performed under the TVA Allen Fossil Plant Remedial Investigation Work Plan (RI Work Plan, Revision 1; September 2017) and provides QA procedures and quality control (QC) measures to be applied to associated sampling and monitoring activities. This ALF RI QAPP governs the quality aspects of the RI Work Plan and RI SAP. This QAPP describes the QA implementation for the ALF RI and identifies the obligations of the various entities responsible for generating environmental data. Specific details on the various sampling programs and project-specific quality objectives are presented in this QAPP and/or the RI SAP, with TVA Technical Instructions (TIs) or standard operating procedures (SOPs) guiding the specific activities performed under these plans. The QAPP describes the generation and use of environmental data associated with the ALF RI and is applicable to current sampling associated with the project. Data generated under the ALF RI will be managed in accordance with the ALF RI Data Management Plan (ALF RI DMP). 2.2 Quality Assurance Program Organization, Management, and Responsibilities Successful implementation of a QA program requires clear lines of reporting and authority, along with defined responsibilities for key individuals implementing and administrating the QA Program. This section describes the organizational structure, lines of authority, and responsibilities of key individuals accountable for the implementation and administration of the ALF RI requirements. Project activities are performed within the framework of the organization and functions described in this section. The organizational structure showing relationships of individuals with key responsibilities is presented in Figure 2-1. The organizational structure in Figure 2-1 represents a subsection of the overall organizational structure for the project as directly related to implementation of the ALF RI QAPP. The QA Oversight Consultant provides independent QA support to TVA including QA oversight of field and laboratory personnel. The organizational structure is designed to provide clear lines of responsibility and authority, regardless of the individuals filling particular roles. This organizational structure encompasses the following activities: Identifying lines of communication and coordination. Monitoring project schedules and performance. Managing technical resources. Providing periodic progress reports. Coordinating support functions such as laboratory analysis and data management. Rectifying deficiencies and issues that could impact data quality. Field and laboratory personnel providing services in support of project efforts must perform work in compliance with the appropriate technical specifications for the activity. 4

93 TVA Allen Fossil Plant Remediation Investigation Quality Assurance Project Plan Revision 0 September 2017 Figure 2-1. Organization Chart and Lines of Communication for the ALF RI TVA Compliance Lead TVA Technical Lead QA Oversight Manager Analytical Laboratories Data Manager Investigation Consultant Project Manager Laboratory Coordinator Data Validators Field Oversight Coordinators Laboratory QA Officer Field Team Leaders Field Sampling Personnel Laboratory Project Manager Laboratory Sample Custodian Laboratory Analyst 5

94 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 The sections below detail the roles and responsibilities for the positions involved in the ALF RI TVA Compliance Lead The TVA Compliance Lead is responsible for the coordination and direction of the ALF RI. The TVA Compliance Lead is ultimately responsible for design and implementation of the Program. The TVA Compliance Lead interfaces with TVA Legal Counsel as necessary and provides reports to TVA Senior Management. TVA Compliance Lead s responsibilities and duties include: Identifying lines of communication and coordination. Managing key technical resources. Providing periodic progress reports to TVA Senior Management. Reviewing and approving the RI strategy. Reviewing and approving RI quality objectives. Reviewing and approving SAPs. Rectifying deficiencies and issues. Participating in meetings with Tennessee Department of Environment and Conservation (TDEC). Providing compliance support to TVA Technical Lead TVA Technical Lead The TVA Technical Lead is responsible for providing technical guidance for the ALF RI. The TVA Technical Lead directs the Sampling Contractor and independent QA Oversight Manager and is ultimately responsible for design and implementation of the Program. The TVA Technical Lead interfaces with TVA Legal Counsel as necessary and provides reports to TVA Senior Management. TVA Technical Lead s responsibilities and duties include: Developing and reviewing the RI strategy. Developing and reviewing RI quality objectives. Reviewing and approving SAPs. Reviewing and analyzing overall task performance relative to planned QA requirements. Coordinating support functions such as laboratory analysis and data management. Rectifying deficiencies and issues. Providing technical support to the TVA Compliance Lead. Overseeing the budget. Monitoring project schedules and performance. 6

95 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September Investigation Consultant Project Manager The Investigation Consultant Project Manager plans, coordinates, and oversees the performance of all investigation and sample collection activities. Investigation Consultant responsibilities include: Developing the SAP. Planning and coordinating field personnel for investigation and sampling events. Reviewing field logbooks for completeness, consistency, and accuracy. Managing and reviewing field sample Chain-of-Custody (COC) Records and associated documentation. Obtaining the appropriate field gear and supplies. Notifying management of situations requiring corrective action. Responding to, and implementing corrective action, as described in Section Field Team Leaders The Field Team Leaders are the primary contacts in the field and are responsible for field activities, as listed below. Provide coordination and management of field personnel and subcontractors involved in field investigation, sampling or calibration activities. Submit analytical requests to the Laboratory Coordinator. Ensure Field Personnel are familiar with field procedures and that these procedures are followed to achieve the data objectives. Review field logbooks and field data sheets for completeness, consistency, and accuracy. Coordinate submittal of field data to the Data Manager Field Sampling Personnel Field Personnel are responsible for the performance of field activities as required by the program-specific SAPs and associated field TIs. Field Personnel document compliance with project requirements by recording field activities and observations in a field logbook at the time of the activity or observation. In addition, Field Personnel are responsible for collecting samples, submitting them to laboratories, and maintaining COC Records. Field Personnel are responsible for field activities, including: Plan investigation and sample events and interface with the analytical laboratories. Collect, label, and package samples. Ensure field procedures are followed to achieve the data objectives. Review field notebooks/logbooks for completeness, consistency, and accuracy. Provide coordination of sample delivery to project laboratories for analysis. 7

96 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 If there are problems encountered during any field activities, Field Personnel will inform the appropriate Field Team Leader and/or the Investigation Consultant Project Manager Analytical Laboratories The functional roles for project analytical laboratories are described in this subsection. From the Project perspective, the structure is designed to facilitate information exchange about planning, technical requirements, schedules, and QA measures among the laboratories, Investigation Consultant, QA Oversight personnel, and TVA personnel. Project information exchange specifically includes sample identification; preservation procedures; sample container requirements; sample collection procedures; decontamination protocols; and sample labeling, packing, holding times, and shipping. Although internal laboratory structures may differ depending on the specific contractor, key functional roles include division management, technical direction, subcontracting coordination, data review, and data management. The responsibilities of the analytical laboratories include, but are not limited to: Preparing and analyzing samples in a manner consistent with the analytical request, the ALF RI QAPP, and any applicable TVA TIs or other work instructions. Communicating with the QA Program Team. Adhering to the laboratory QA Program. Implementing QC procedures for each test parameter. Reviewing analytical results, including raw data, calculations, and laboratory logbooks. Monitoring proper documentation and maintenance records. Identifying and implementing training requirements for the laboratory analytical personnel. Identifying QA problems and recommending appropriate corrective action. Preparing status reports (progress, problems, and recommended solutions). Preparing reports documenting completion of corrective actions. Providing electronic data deliverables (EDDs) in a format consistent with project requirements. Laboratories will be selected based on a number of factors including capability, capacity, and ability to generate quality data that meet project objectives. The primary contracted laboratories may subcontract samples for special studies or non-routine analyte lists. In the event that samples are subcontracted, the primary laboratory is responsible for ensuring that analyses conform to the ALF RI QAPP requirements and the associated investigation-specific SAP. Data for subcontracted analyses will be reported through the primary contracted laboratory, which remains responsible for data quality. The primary analytical laboratories expected to analyze samples associated with the ALF RI are presented on Table

97 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Table 2-1. Analytical Laboratories for ALF RI Parameter/ Sample Type Laboratory Facility Address Laboratory Project Manager Metals and arsenic species Pace Analytical Services, LLC 1800 Elm St SE Minneapolis, MN Ms. Nicole Gasiorowski (nicole.gasiorowski@pacelabs.com) General Chemistry Parameters Radiological Parameters 2225 Riverside Drive Asheville, NC Roseytown Rd - Suite 2, 3, 4 Greensburg, PA Laboratory QA Officer The Laboratory QA Officer ensures conformance with authorized policies, procedures, and sound laboratory practices as necessary. The Laboratory QA Officer will inform the Laboratory Project Manager of any non-conformances, introduce control samples into the sample train, and establish testing lots. In addition, the Laboratory QA Officer approves laboratory data before reporting or transmitting to permanent storage and is responsible for retention of supporting information such as control charts and other performance indicators to demonstrate that the systems that produced the data were in control. The Laboratory QA Officer also reviews results of internal QA audits and recommends corrective actions and schedules for their implementation. The responsibilities of the Laboratory QA Officer include, but are not limited to: Administering the laboratory QA Program. Implementing QC procedures for each test parameter. Reviewing analytical results, including raw data, calculations, and laboratory log books. Monitoring proper documentation and maintenance of the records. Identifying and implementing training requirements for the laboratory analytical personnel. Overseeing QA implementation at the laboratory on a daily basis. Identifying QA problems and recommending appropriate corrective action. Preparing status reports (progress, problems, and recommended solutions). Preparing reports documenting completion of corrective actions. 9

98 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September Laboratory Project Manager The Laboratory Project Manager is the primary contact for the Project Team at the analytical laboratory. A primary responsibility of the Laboratory Project Manager is to schedule analytical work within the laboratory, ensure that project-specific analytical requirements are communicated to staff, monitor analytical status/deadlines, approve laboratory reports, coordinate data revisions/corrections and re-submittal of data packages as necessary, and communicate sample preparation and analysis issues to the QA Oversight Manager and TVA Technical Lead on a real-time basis. The Laboratory Project Manager provides direction and support for laboratory administrative and technical project staff, interfaces with laboratory project staff on technical issues, and performs QA oversight of analytical data. The Laboratory Project Manager contacts the QA Oversight Manager and TVA Technical Lead if, at any point, there is a need to deviate from the ALF RI QAPP or other cited published materials. Any problems or inconsistencies identified at any time after laboratory sample receipt will be documented on a nonconformance report initiated by the Laboratory Project Manager and forwarded to the TVA Technical Lead and the Laboratory Coordinator. The Laboratory Project Manager will provide sample receipt confirmations to the Laboratory Coordinator and Investigation Consultant Project Manager within one business day of sample login Laboratory Sample Custodian The Laboratory Sample Custodian receives samples from TVA or its contractors, signs and dates COC Records, records the date and time of receipt, and records the condition of shipping containers and sample containers. The Sample Custodian will verify and record agreement or non-agreement of information on sample custody documents. If there is non-agreement, the Sample Custodian will record the problems/inconsistencies for the case file and will inform the Laboratory Project Manager. The Sample Custodian will also label sample containers with laboratory sample numbers, place sample containers and spent sample containers into the appropriate storage and/or secure areas, and monitor storage conditions Laboratory Analyst The Laboratory Analyst is responsible for preparing and/or analyzing samples in accordance with this document and/or the applicable analytical methods. If there are problems encountered during sample preparation or analysis, the Laboratory Analyst will inform the Laboratory QA Officer and Laboratory Project Manager QA Functions QA Oversight activities will be performed by a third-party, independent contractor. The QA Oversight Consultant is an independent third-party QA organization and reports directly to the TVA Technical Lead. 10

99 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September QA Oversight Manager The QA Oversight Manager develops, implements, and administers the overall QA Program for the ALF RI. The QA Oversight Manager holds overall authority for the project QA and maintains that authority independently from the operational/production aspects of the project. The QA Oversight Manager also holds the authority to communicate at any level of the project organization in order to be effective. The QA Oversight Manager s responsibilities and duties include: Establish a documented quality system for the project. Identify QA problems through periodic auditing and validation procedures. Initiate, recommend, or provide solutions to QA problems through designated channels. Ensure that project activities, including processing of information, delivery of products, and installation or use of equipment, are reviewed in accordance with QA objectives. Ensure that deficiencies or non-conformances are corrected. Ensure that further processing, delivery, or use of deficient or non-conforming data is controlled until correction of the non-conformance, deficiency, or unsatisfactory condition has occurred. Review and analyze overall task performance with respect to planned requirements. Perform general oversight of corrective action processes. Initiate and direct internal audits, inspections, surveillances, and observation of quality-related activities. Serve as point of contact for audits, inspections, surveillances, data management, and observation activities. Ensure deficiencies and non-conformances are corrected. Maintain QA documentation and records, including this ALF RI QAPP Laboratory Coordinator The Laboratory Coordinator serves as a liaison between field samplers and the analytical laboratories for all work conducted under the ALF RI. The Laboratory Coordinator s responsibilities include: Review analytical requests to verify consistency with project SAPs. Submit analytical requests to the Laboratory Project Manager. Schedule sample submission and transportation (as needed). Review and approve laboratory bottleware orders. Review COC Records submitted to the laboratories and sample receipt documentation provided by the laboratories. Serve as the point of contact for questions and issues arising during laboratory analysis. 11

100 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September Data Validators Data Validators are responsible for performing review and validation of project data generated by the laboratories in accordance with the ALF RI QAPP and data specifications, producing data validation reports, and notifying the QA Oversight Manager of any specific issues or concerns Field Oversight Coordinators Field Oversight Coordinators are independent from field sampling activities and work with the Field Team Leaders to ensure compliance with the ALF RI QAPP, RI Work Plan, RI SAP, and the associated project TIs. The Field Oversight Coordinators are responsible for training personnel involved in field sampling activities (if training is required), sample handling procedures, and sample custody as detailed in project TIs and the RI SAP, and for periodically overseeing their performance of these functions. The Field Oversight Coordinators perform quality oversight of the Field Teams during sample collection and assess the procedures and performance of the Field Teams relative to the requirements in the ALF RI QAPP, TIs, and RI SAP. As part of the quality oversight, the Field Oversight Coordinators will review COCs prior to submission of samples to the analytical laboratories Data Manager The Data Manager is responsible for managing the project EQuIS TM database, which includes analytical data from the project laboratories, field data from the Investigation Consultant, and historical data of known quality used as part of the ALF RI. The Data Manager is the main point-of-contact for data-related issues. The Data Manager is responsible for ensuring compliance with the ALF RI QAPP and the ALF RI DMP. The Data Manager or designee receives EDDs directly from the project laboratories after sample analysis and formats the deliverables such that they can be used during the validation/verification process. Field data is collected and submitted to the Data Manager from the Investigation Consultant utilizing field EDDs and is loaded and managed in the project database. A complete description of the Data Manager s responsibilities and responsibilities of Data Management support staff is provided in the ALF RI DMP. 3.0 PROJECT DESCRIPTION AND APPLICABILITY In response to the Tennessee Department of Environment and Conservation (TDEC) letter dated July 18, 2017, TVA developed an RI Work Plan to characterize groundwater quality near the East Ash Disposal Area at ALF. This QAPP governs the work to be conducted under the ALF RI. The objectives of the ALF RI described in the RI Work Plan include the following: 1) Source area identification and delineation of Coal Combustion Residual (CCR) constituents as listed in Attachments III & IV in the U.S. EPA CCR Regulations, including arsenic, lead, and fluoride, in the subsurface soils which are thought to be impacting shallow groundwater in the vicinity of the East Ash Disposal Area at the Site; 2) Complete horizontal and vertical delineation of the groundwater contaminant plume(s) for CCR constituents, including arsenic, lead, and fluoride, in the Fluvial Aquifer beneath the Site, through the installation and sampling of permanent monitoring wells; 12

101 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September ) Characterization of the Fluvial Aquifer with a network of shallow, intermediate, and deep permanent monitoring wells that will provide monitoring points for the future observation of potential contaminant migration in the shallow aquifer, as well as from the shallow aquifer to the deeper portions of the Fluvial Aquifer; and 4) Completion of a three-dimensional groundwater flow and transport model for the Site to evaluate groundwater flow and contaminant migration in the Fluvial Aquifer under current conditions, as well as future conditions that may develop as a result of pumping from the Memphis Sand Aquifer. To support the ALF RI objectives, a QA program has been implemented to ensure the environmental data generated for use in decision making is of high-quality and is legally defensible. The QA program is described in this ALF RI QAPP and in the ALF RI DMP. On behalf of TVA, the QA Oversight Consultant, an independent QA firm, has prepared this ALF RI QAPP. The requirements of the ALF RI QAPP are applicable to project environmental personnel, support staff, consultants, and subcontractors. 3.1 Purpose and Scope The ALF RI QAPP is intended to establish an overall environmental QA framework for the ALF RI and to provide quantitative quality objectives for analytical data generated under the ALF RI. Requirements associated with various analyses; data generation, reduction, and management; and results reporting are stipulated herein. Additional specific requirements are described in the RI Work Plan and RI SAP. The scope of this document is to describe the QA requirements developed for the ALF RI and provide the appropriate QA procedures and QC measures to be applied to the associated sampling and monitoring activities. The ALF RI QAPP addresses the following items: Project organizational structure, roles, and responsibilities. QA objectives. Training requirements. Field and laboratory documentation requirements. Sample collection, handling, and preservation. COC procedures. Field and laboratory instrumentation and equipment calibration and maintenance. Preventive maintenance procedures and schedules. Laboratory procedures. Analytical methods requirements. Sample analysis, data reduction, validation, and reporting. QC sample types and frequency. QA performance and system audits. Data assessment procedures, including processing, interpretation, and presentation. Corrective actions. QA reports to management. 13

102 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 The RI SAP has been developed to address program-specific sampling requirements to provide data sufficient to address the objectives of the particular investigation. QC requirements and quantitative objectives for analytical data are presented in Attachments E and F of this QAPP. 3.2 Schedule The sampling schedule for anticipated RI activities is presented in the RI Work Plan and the RI SAP. In general, the anticipated schedule of activities related to analytical data generated from chemical analyses is presented below. Activity schedules may be accelerated where required to meet project objectives. The laboratory will provide analytical results and EDDs to TVA within its standard turn-around time (TAT; approximately 10 business days for chemical analyses and approximately 40 days for radiological analyses) from sample receipt (or sooner when expedited TAT is requested). The QA Oversight Consultant will screen the EDD for acceptability to the database and complete the initial verification within 2 business days of EDD receipt and successful EDD loading. Verified data with appropriate qualifiers will be available to TVA and Investigation Consultant personnel for internal use and reporting following verification. The laboratory will provide full data deliverable packages to TVA and the QA Oversight Consultant within its standard TAT (approximately 20 business days for chemical analyses and approximately 45 days for radiological analyses) from sample receipt. The QA Oversight Consultant will complete data validation as requested by TVA, generate reports following receipt of the complete data package, and add data validation qualifiers to the database as appropriate. The overall schedule for the ALF RI is presented in the ALF RI. Schedules for the various sampling activities associated with each EI are addressed in the RI SAP. 3.3 QAPP Distribution and Revision The QAPP will be distributed to each contractor responsible for the collection, generation, and interpretation of field and analytical data. The TVA Technical Lead, QA Oversight Manager, or designee will be responsible for ensuring that necessary revisions are made so that the ALF RI QAPP is up-to-date with actual practices and will ensure that revisions and updates are distributed to necessary users. The document control format used in the ALF RI QAPP will identify the ALF RI QAPP revision number and revision date. A revision history that identifies each revision and a summary of the revision will be maintained. 4.0 DATA QUALITY OBJECTIVES PROCESS The data quality objectives (DQO) process is a series of planning steps based on a scientific method to ensure that the type, quantity, and quality of environmental data used in decisionmaking are appropriate for the intended application. In general, DQOs provide a qualitative and quantitative framework around which data collection programs can be designed. The qualitative 14

103 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 aspect of DQOs seeks to encourage good planning for field investigations. The quantitative aspect of DQOs involves designing an efficient field investigation that reduces the possibility of incorrect decision-making. The DQO process is a tool employed during the project planning stage to ensure that data generated from an investigation are appropriate and of sufficient quality to address the investigation objectives. TVA and the Investigation Consultant informally considered key components of the DQO process in developing RI SAP to guide the data collection efforts at the ALF RI. 5.0 SPECIAL TRAINING/CERTIFICATIONS Field personnel performing sample collection activities will be properly trained in equipment use and procedures necessary for each task prior to entering the field. Training will be conducted by TVA, the QA Oversight Consultant, the Investigation Consultant, and/or other subcontractors. Any proposed training not provided by the QA Oversight Consultant will be reviewed and approved by the Field Oversight Coordinator before training is conducted. Field Personnel training will be fully documented and the documentation will be maintained as part of the Project Record. Individuals who plan to participate in field activities must have current health and safety training prior to commencement of sample collection activities. The Investigation Consultant Field Team Leader will verify that participants who arrive on site have provided evidence of health and safety training. It will be the responsibility of the Investigation Consultant Field Team Leader to ensure that field personnel understand and comply with the applicable requirements for their individual tasks. Field Personnel will be trained on applicable field QC measures associated with a particular sampling program during program-specific training. Training received by Field Personnel will be documented. In addition, Field Personnel will receive training based on field oversight activities and additional training sessions on applicable project TIs. Personnel who are responsible for performing laboratory analyses will be properly trained by the Laboratory Director or her/his designee to conduct the various laboratory analyses described in the ALF RI QAPP. Each laboratory shall assure sufficient personnel with the necessary education, training, technical knowledge, and experience for their assigned functions. Data verification and validation will be conducted under the direction of the QA Oversight Manager, who will be experienced with the production, reporting, verification, and validation of analytical data. Additional QA training will be conducted at the discretion of the TVA Technical Lead and the QA Oversight Manager. Generally, the need for QA training for project personnel will be identified through systems and performance audits and training will be conducted as part of the corrective action process. Any QA training provided to project personnel will be documented. 6.0 DOCUMENTATION AND RECORDS Appropriate records will be maintained in a secure project file to provide adequate documentation of the entire data generation process, including field sampling and laboratory 15

104 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 analysis. Field records will include maintaining field logs, field data sheets, and sample COC documentation. Field QC samples will be documented in both the field logbook and sample COC Records. The Project File will be the central repository for documents relevant to sampling and analysis activities as described in the ALF RI QAPP and in the program-specific Work Plans and/or SAPs. The TVA Technical Lead will hold overall responsibility for maintenance of documentation associated with the project, including relevant records, correspondence, reports, logs, data, field records, pictures, subcontractor reports, analytical data, and data reviews. The file will include the following information, if generated: Field records. Field data and data deliverables. Photographs. Drawings. Sample logs. Laboratory data deliverables. Data validation reports. Field and laboratory audit reports. Reports (e.g., progress reports, QA reports). Custody documentation. Electronic and hardcopy data will be archived for a minimum of 10 years from the date of report. TVA will maintain a complete project file and will archive hardcopy and electronic data in accordance with TVA records retention rules as delineated by TVA s records management documents. Electronic or hardcopy data associated with the ALF RI will not be discarded, deleted, or destroyed by any party without the written consent of TVA Legal Counsel. 6.1 Field Data Documentation Field data collected during the EI will be evaluated for usability by conducting a QA review, which will consist of checking the procedures used by field staff and comparing the data to previous measurements. Field QC samples will be used to verify that field measurements and sampling protocols have been observed and followed. The field data will be reviewed by the Field QA Oversight Coordinator or designee for the following: Compliance with TIs. Compliance with SAPs. Field equipment calibration method and frequency. Field calibration standard lot numbers and expiration dates. Date and time sampled. Preservation. Sampler collection procedures. COC Records. Date sample shipped. 16

105 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Any deviations from applicable TIs or the RI SAP will be approved and documented in the field logbook during sampling and data collection operations. The Field Team leader or designee will be notified of deviations. The original COC Records will accompany samples to the analytical laboratories. Upon receipt and login of the samples at the laboratory, the remaining sections of the COC Record (such as description of the sample condition at the time of receipt, assigned laboratory identification number, and any special conditions) will be completed. The original COC Record will be archived at the analytical laboratory in accordance with the laboratory s document retention requirements and the requirements herein. 6.2 Laboratory Data Documentation Analytical laboratories performing work on this project will retain records of the analytical data for a minimum of 10 years after project completion. Analytical data will not be disposed of without TVA s consent. In addition, laboratory data will be provided to TVA in hardcopy or approved electronic form. TVA will retain data in accordance with TVA records management requirements. Laboratory data will not be disposed without specific approval from the TVA Legal Counsel and the TVA Technical Lead Laboratory Data Reporting/Deliverable Package Analytical laboratories will report data at their standard TAT; generally, 10 business days from sample receipt at the laboratory for all chemical parameters. In some cases, expedited TATs are required. Results of sample chemical analyses are completed and results reported to TVA and the QA Oversight Consultant as a Level II report and EDD within 10 business days for a standard TAT (refer to Attachment A for data deliverables requirements). Level IV data packages (refer to Attachment A for data deliverables requirements), in a hardcopy and/or electronic Adobe Acrobat portable document format (.pdf), will be submitted to TVA and the QA Oversight Consultant within approximately 20 business days from sample receipt at the laboratory. Radiological analysis results are completed and reported to TVA and the QA Oversight Consultant as a Level IV report and EDD within 40 business days. Data deliverables may be requested on an expedited basis where needed to meet project objectives. Laboratories performing chemical analyses will be responsible for providing an EDD consistent with the ALF RI DMP, as well as a Level II report and/or Level IV data package (see Attachment A). The deliverable package will contain final results (uncorrected for blanks and recoveries except where required by the referenced method), analytical method reference, sample results and detection limits, and results of field and laboratory QC samples. In addition, special analytical problems and/or any modifications of referenced methods will be noted in the Case Narrative of the laboratory report/data package. The number of significant figures reported will be consistent with the limits of uncertainty inherent in the analytical method. 17

106 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 As a general statement: Concentrations for aqueous samples are expressed in terms of weight per unit volume (such as milligrams per liter [mg/l]). Concentrations for chemical analyses of solid samples are expressed in terms of weight per unit weight of sample (such as milligrams per kilogram [mg/kg]). Unless specifically directed otherwise, solid sample chemical analysis results will be reported on a dry-weight basis. The reporting basis for solid samples will be clearly indicated in the laboratory data package. Radiological activities are expressed in terms of picocuries per unit volume or weight (such as pci/l or pci/g). For solid samples, radiological activities are not corrected for sample moisture content. Data will be reported in the units specified in the Method Analyte Groups (MAGs) to ensure consistent reporting among the contracted laboratories. The format for the Level II report and Level IV data package is presented in Attachment A. In general, the Level IV data package will include summary forms and raw data for calibrations, QC, and sample analyses. QC results reported will include a method blank, matrix spike/matrix spike duplicate (MS/MSD) samples, field QC samples, and laboratory control samples (LCSs). Sample chemical analyses data (both field and laboratory QC sample results) will also be provided in EDDs. The laboratory is responsible for reviewing the electronic data to ensure that these data are consistent with those presented in the laboratory report/data package. Data discrepancies between the EDD submission and laboratory report/data package, if any, will be reconciled at validation; the data validators will notify the contract laboratory and TVA so that the laboratory deliverables may be revised by the contract laboratory. In the event that revisions to Level II or Level IV data packages are required based on data validation, complete revised deliverables clearly stamped with revision number and date will be provided by the contract laboratory so that a final complete data package is archived for each sample submittal. 6.3 Record Keeping Written and/or electronic records generated under the ALF RI, including but not limited to notes, logbooks, reports, draft and final documents, and forms, are maintained by the originator for inclusion in the project file as appropriate. In addition, electronic files, including but not limited to draft and final documents, and laboratory analytical reports are maintained as part of the electronic project file. Chemical analytical data for this project will be reported in both an EDD and an analytical data package. An EarthSoft EQuIS database will be used for processing, storage, and reporting of all data (historical and investigatory) to be used as part of the ALF RI. To maintain uniformity and consistency among analytical laboratories, the EDD format for the transfer of data associated with the ALF RI will be a complex EDD specification compatible with EQuIS. A simple EDD specification may be substituted for laboratories that do not possess the capabilities to generate a complex EDD or for analyses for which automated data review is not applicable (e.g., percent ash analyses by polarized light microscopy). The EQuIS data transfer parameters are discussed further in the ALF RI DMP. The EDD will be generated by the laboratories and will be used to facilitate loading the analytical data into the EQuIS Project Database. 18

107 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Field data generated during the ALF RI will also be stored in the EQuIS Project Database. A simple EDD specification will be utilized by the Investigation Consultant Field Team Leader (or designee) to submit field data to the EQuIS Project Database. Analytical data packages will be prepared by the laboratory for sample analyses performed. A Limited data deliverable (Attachment A) in Adobe Acrobat.pdf and EQuIS EDD will be provided by the contract laboratory within the laboratory s standard TAT for limited deliverables (approximately 10 business days from sample receipt for chemical analyses and approximately 40 business days from sample receipt for radiological analyses). Full deliverables (Attachment A) will be provided by the laboratory in an Adobe Acrobat.pdf electronic format for all analyses within the laboratory s standard TAT for Full data deliverables (approximately 20 business days from sample receipt for chemical analyses and approximately 45 business days from sample receipt for radiological analyses). 6.4 Data Archival Applicable electronic field and laboratory data collected during sampling will be archived electronically. Backup tapes containing databases and programs or software utilities will be maintained in a secure location. Hardcopy data, including but not limited to field logbooks, laboratory data deliverables, and data validation reports, will be archived in accordance with TVA s Document Control protocols. Formal records custody procedures will be maintained in accordance with TVA s Records Custody procedures. 7.0 SAMPLING PROCESS DESIGN This section briefly outlines field investigation procedures for the ALF RI. Detailed discussions of field protocol are provided in the various TIs developed for the project. In addition, detailed descriptions of field activities are provided in the RI SAP. Aqueous and solid samples may be collected in association with the ALF RI. These samples will be subjected to a variety of chemical, radiological, and physical analyses to support the objectives outlined in the ALF RI and RI SAP. Field investigation and sampling procedures will be conducted such that samples are representative of the media sampled and the resultant data can be compared to other data sets. Sampling schemes (as described in the RI SAP) are designed to provide a statistically meaningful number of field sampling points and the rationale for the collection of these samples. A sufficient number of samples will be collected for each sampling program to adequately characterize the area and provide a sufficiently large data set such that statistical analyses can be performed. Field investigation and sampling methods will be conducted in accordance with the RI SAP and associated TVA TIs, which include equipment requirements and decontamination procedures to meet the objectives of the project. The investigative rationale for the RI sampling and analytical program is addressed in the RI SAP. Sampling and monitoring activities are subject to the requirements set forth in the TVA TIs and this QAPP. The RI SAP will address any specific sampling and monitoring activities when QA requirements more stringent than those presented herein are required to support the sampling and monitoring projects. 19

108 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 The sampling design and execution for monitoring activities associated with the ALF RI are described in the RI SAP. For some investigations it is anticipated that the sampling and monitoring activities will evolve in a phased approach as data are gathered under the planned investigations. As the sampling and monitoring programs are developed, additional SAPs and program-specific TIs may be prepared. As the project progresses, the data generated will be used to evaluate sampling and analytical needs. Subject to regulatory approval, adjustments may be made to sampling schedules, analyte lists, and requested methods when supported by the results of field investigations. The RI SAP presents Site maps, including sampling locations (when applicable), for the sampling and monitoring programs performed at the Site. Detailed descriptions of sampling process design and field sampling activities are provided in the RI SAP. Field investigations will be addressed in RI SAP. 8.0 SAMPLING METHODS REQUIREMENTS Descriptions of the procedures for the sampling, identification, packaging, and handling of project samples; the decontamination of sampling equipment; and the calibration and maintenance of sampling equipment are presented in the associated TIs and the RI SAP. An overview of sample identification, documentation, and custody as related to data collection activities is presented in Section Sample Containers, Preservation, and Holding Times Sample container/media, preservation, and holding time requirements are presented in Attachments E and F of this ALF RI QAPP. Samples will be stored in accordance with the requirements set forth in the referenced analytical methods and/or laboratory TIs. Field samples will be contained and preserved in accordance with appropriate United States Environmental Protection Agency (US EPA) analytical method specifications which are cited in the RI SAP and/or associated TVA TIs. Sampling containers and preservatives will be provided by the laboratory. In most cases, the supplied sampling containers will be pre-preserved by the laboratory prior to shipment. On an investigation-specific basis, samples may be filtered and/or preserved at the analytical laboratory. For chemical analyses, sample containers provided will be new precleaned I-Chem Series 300 (or equivalent). Samples will be placed in individual pre-cleaned containers for shipment to the laboratory. Sample container orders, when shipped by the laboratory, will include a packing list that details the number and type of bottles shipped, the bottle lot numbers, chemical preservatives, and the packer s signature. The COC Records will be completed by Field Personnel and returned to the laboratory with the samples. Sample containers will be individually custody-sealed and placed inside the sample cooler. After the cooler is sealed, sampling personnel will attach signed/dated custody seals to the outside of the cooler as described in TVA Sample Labeling and Custody TI (ENV-TI ). Samples will be stored according to the applicable storage criteria from the time of collection until the time of analysis by the laboratory. Field personnel will keep samples cold by placing ice in the coolers in which samples will be stored until delivery to the analytical laboratory personnel. After receipt of the samples, it is the laboratory s responsibility to store the 20

109 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 applicable samples according to the applicable preservation conditions until preparation and analysis has been initiated. Samples have a finite holding time (the time between sample collection, sample digestion, and sample analysis) to limit the potential for degradation of the analytes. The holding times for required analyses are measured from the verified time of sample collection. When possible, samples will be shipped by overnight carrier or delivered by same-day courier to minimize the time between collection and laboratory receipt. 8.2 Decontamination Tools and equipment decontamination procedures are implemented to prevent cross-contamination of samples and to control potential inadvertent transport of hazardous constituents. Disposable and dedicated sampling equipment will be utilized to the extent possible in an effort to limit the potential for cross-contamination and to reduce labor costs. The non-disposable equipment will be decontaminated using the procedures described in the TVA Field Sampling Equipment Cleaning and Decontamination TI (ENV-TI ) and/or the RI SAP. 9.0 SAMPLE HANDLING AND CUSTODY REQUIREMENTS Field Personnel are responsible for the collection, description, documentation, labeling, packaging, storage, handling, and shipping of samples obtained in the field. These practices are necessary to ensure sample integrity from collection through laboratory analysis and data reporting. To demonstrate and document sample integrity aspects, information relative to the collected project samples will be described and thoroughly documented. Samples will be labeled, packaged, preserved, and shipped to the laboratories for analysis in appropriate sample containers, under the recommended temperature conditions with a COC Record documenting the time and day of sample collection. Laboratory-supplied sample kits with custody seals, packing materials, sample containers and preservatives will be used for project samples during sample collection and transport to the TVA-contracted laboratories. The sample containers and preservation requirements for samples collected under each investigation will be presented in Attachments E and F to this QAPP. COC Records will be assigned standardized identification numbers and task codes describing the intended purpose of the sampling event. Attachment D provides specific requirements for sample nomenclature for the ALF RI. Samples will be assigned identifications using the sample nomenclature scheme identified in Attachment D of this document. As additional site sampling and monitoring plans are developed, nomenclature will be developed in accordance with the sample locations and naming codes (when necessary) will be generated. 21

110 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September Sample Documentation Field activity evidentiary files will be maintained by the Investigation Consultant personnel and will include information that defines the Project in its entirety, including but not limited to, the information below. Field logbooks. Field data sheets. Raw data. QC information. COC Records. Airbills (when used) for sample shipments. Photographs. Field documentation procedures are described in the Field Record Keeping TI (ENV-TI ) and in the RI SAP Chain-of-Custody Record A primary consideration for environmental data is the ability to demonstrate that samples have been obtained from specific locations and have reached the laboratory without alteration. Evidence of collection, shipment, laboratory receipt, and laboratory custody while samples are in the laboratory s possession will be documented by maintaining a COC that records each sample and the individuals responsible for sample collection, shipment, and receipt at the project laboratory. Samples that are collected will be accompanied by a COC Record. An example COC Record is included in Attachment C. The following information will be recorded on the COC Record: Project name and number. Name of sampler. Sample identifier/name, location, date and time collected, and sample type. Analyses requested. Special instructions and/or sample hazards, if applicable. Signature of sampler in the designated blocks, including date, time, and company. Sample condition (including temperature) upon receipt as reported by the analytical laboratory. Signature of the laboratory receipt personnel in the designated blocks, including date, time, and company affiliation. Original COC Records are transferred to the analytical laboratories such that sample custody is maintained through analysis and reporting. Copies of COC Records are maintained on site by the Investigation Consultant Field Team Leaders. Duplicates of COC Records are retained by the TVA Technical Lead and.pdf versions of COC Records are maintained by the Data Management Team as part of the Project File. COC Records will reference defined MAGs to communicate sample analysis requirements to the analytical laboratories. MAGs identify the required analytical methods, parameter lists, and reporting units to ensure consistent reporting of data among multiple laboratories. In addition, 22

111 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 MAGs enable automated data completeness evaluation and data verification upon receipt of electronic data. An overview of the data management process is provided in Section For samples collected for chemical, optical, or radiological analyses, field COCs are provided to the QA Oversight Consultant s Data Production Team by the Field Sampling Team performing the sample collection. EQuIS field sample EDDs are subsequently created to facilitate completeness review upon laboratory submittal of the associated analytical data Sample Custody in the Field The purpose of sample custody procedures is to document the history of samples (and sample extracts or digestates) from the time of sample collection through shipment and sample receipt, analysis, and disposal. A sample is considered to be in one s custody if one of the following conditions applies: The sample is in an individual s actual possession. The sample is in view after being in an individual s physical possession. It was in the physical possession of an investigator and then they secured it to prevent tampering; and/or It is placed in a designated secure area. Each individual Field Sampler is responsible for the care and custody of the samples he/she collects until the samples are properly transferred to temporary storage or are shipped to the laboratory. The following COC procedures will be followed for samples submitted to the laboratory for analyses: Each individual Field Sampler is responsible for the care and custody of samples he/she collects until the samples are properly transferred (relinquished on the COC by a Field Team member) to another person ( acceptor of the samples) or are shipped to the laboratory. A COC Record will be completed at the time of sample collection by the Sampling Team for each batch of samples submitted to the laboratory in accordance with the Sample Labeling and Custody Technical Instruction (ENV-TI ). Field sampling logs may be used in the place of formal COCs in the field. If multiple coolers are needed, one COC Record will accompany each cooler that contains the samples identified on the COC. Sample coolers will be packed and sealed with custody seals for transport from field and shipment to laboratory in accordance with the Handling and Shipping of Samples Technical Instruction (ENV-TI ). Each time a sample batch is transferred (Field Personnel relinquish custody to the laboratory or other Sampling Team personnel), signatures of the individuals relinquishing and receiving the sample batch, as well as the date and time of transfer, will be documented on the COC or courier documentation form. Note that commercial courier custody is tracked by commercial courier records and not by COC. A copy of the carrier air bill will be retained as part of the permanent COC documentation record. The laboratory will record the condition of the sample containers, and cooler temperature upon receipt, and record this information on a combination of sample 23

112 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 receipt documentation including a sample receipt confirmation checklist and the COC. Documentation of sample preservation checks (where applicable) will be recorded in the sample preparation documentation. Changes or corrections to the information documented by the COC Record (including, but not limited to, field sample ID or requested analyses) must be changed by marking through the incorrect information with a single strike through line and, dating, and initialing the change in accordance with the Field Record Keeping Technical Instruction (ENV-TI ). If the request for a change or correction comes from the Field Team after the COC Records have been relinquished to the laboratory, a copy of the COC Record will be revised, initialed, and forwarded to the laboratory, where the revised version will supersede the original COC Record. This record will be used to document sample custody transfer from the sampler to the laboratory and will become a permanent part of the Project File. Sample coolers with appropriate custody seals will be shipped to the contract laboratory in a timely fashion to ensure proper thermal preservation and meet analytical method holding times. 9.2 Sample Packaging and Shipment Samples will be packed and shipped to the laboratory in accordance with applicable U.S. Department of Transportation (US DOT) regulations, consulting corporate guidelines, and International Air Transport Association (IATA) standards (as detailed in the most current edition of IATA Dangerous Goods Regulations for hazardous materials shipments), as applicable. Samples that are to be stored at a temperature < 6 degrees Celsius ( C) (not frozen) will be placed on wet ice within 15 minutes of sample collection and packaged with additional wet ice for shipment to the analytical laboratory. 9.3 Sample Custody in the Laboratory The following subsections describe the COC procedures associated with sample receipt, storage, tracking, and documentation by the laboratory Sample Receipt A designated Laboratory Sample Custodian will be responsible for samples received at the laboratory. The Laboratory Sample Custodian will be familiar with custody requirements and the potential hazards associated with environmental samples. In addition to receiving samples, the Laboratory Sample Custodian will also be responsible for documenting sample receipt, maintaining samples at < 6 C during the sample log-in process, storage at < 6 C before and after sample analysis, and the proper disposal of samples. Upon sample receipt, the Sample Custodian will: Inspect the sample containers for integrity and ensure that custody seals are intact on the shipping coolers. The temperature of the samples upon receipt and the presence of leaking or broken containers will be noted on the COC Record/sample receipt forms. 24

113 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Sign (with date and time of receipt) the COC/sample analysis request forms, thereby assuming custody of the samples and assign the laboratory sample identification numbers. Compare the information of the COC Record/sample receipt with the sample labels to verify sample identity. Any inconsistencies will be resolved through the Laboratory Coordinator before sample analysis proceeds. Store samples in accordance with Section The QA Oversight Manager and Laboratory Coordinator must be notified immediately via or documented telephone call when samples are received broken or improperly preserved. Samples received in a condition that may potentially impact results will be placed on hold pending direction from the QA Oversight Manager or Laboratory Coordinator. In the event that aqueous samples for metals analyses are received at ph 2, acid preservative will be added in the originally received sample bottleware by the laboratory and the ph of the samples will be allowed to equilibrate in the originally received bottleware for a minimum of 24 hours prior to digestion. Sample preservation and equilibration will be fully documented via laboratory logbooks Sample Storage Analytical samples will be stored in a locked facility and maintained within the appropriate temperature range as specified in US EPA SW-846 Chapter 3, or Table II of 40 CFR sample storage requirements. The temperature will be monitored and recorded daily by laboratory personnel. Required sample storage conditions are presented in Attachments E and F of this QAPP Sample Tracking Each sample will receive a unique laboratory sample identification number at the laboratory when the sample is logged into the laboratory information management system (LIMS). Sample preparation/digestion records will be generated to fully document sample handling prior to analysis. Laboratory data will be entered on the sample digestion form and permanently recorded in a laboratory logbook. The laboratory will maintain a sample tracking system that documents the following: Organization/individual who performed sample analyses. Date of sample receipt, extraction or digestion, and analysis. Names of Analysts. Sample preparation procedures. Analytical methods used to analyze the samples. Calibration and maintenance of instruments. Deviations from established analytical procedures, if applicable. QC procedures used to ensure that analyses were in control during data generation (instrument calibration, precision checks, method standards, method blanks, etc.). 25

114 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Procedures used for the calculation of precision and accuracy for the reported data. Statement of quality of analytical results. 9.4 Sample Archive Upon request, unused portions of samples may be requested by TVA from the laboratory for archival. Archived samples will be shipped under COC and relinquished to the TVA Technical Lead or designee. The sample archive will be equipped to properly maintain thermal preservation of the samples and will be locked or in an access controlled locations such that sample custody is maintained. Unused portions of samples collected in association with the ALF RI may be returned to TVA for archive or disposal or may be disposed of by the contract laboratories. Archived samples will be cataloged and stored in an organized manner. In the event that project objectives are not met for a sample, any remaining portion with preparation/analytical holding time remaining may be retrieved and submitted to a TVA contracted laboratory for additional analysis ANALYTICAL METHODS REQUIREMENTS Analytical methods will be selected based on the ability to detect constituents of concern at reporting limits sufficient to meet project requirements and quality objectives for precision, accuracy, and sensitivity. Analytical methods cited in this QAPP reference US EPA s Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846); US EPA Clean Water Act Test Methods; and Standard Methods for the Examination of Water and Wastewater. These and potentially other methods, constituents, and reporting limits for samples collected under this EI are presented in Attachments E and F of this QAPP Field Analysis Field analyses will be conducted in accordance with the associated field sampling TIs and/or published field method as applicable. The results from field analysis are reviewed and stored electronically. Detailed descriptions of field monitoring activities, the field analytical equipment, and the sampling equipment utilized to perform the field activities are provided in the program-specific SAPs and/or in the associated TVA TIs Laboratory Analysis To support the objectives of the ALF RI, the collected samples will be tested for the methods, constituents, and reporting limits presented in Attachments E and F of this QAPP. Individual sample reporting limits may vary from the laboratory s routinely reported limits; this variance may be a result of dilution requirements, sample weight or volume used to perform the analysis, dry-weight adjustment for solid samples, the presence of analytical background contaminants, or other sample-related or analysis-related conditions. Additional analytical needs may be identified based on future project needs, and as such, the ALF RI QAPP and SAPs will be modified to document the QC requirements associated with these additional analyses. 26

115 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Dissolved metals analysis of aqueous samples shall be performed on field-filtered (0.45-m filter) select water samples. Alternatively, dissolved metals analysis of aqueous samples may be performed on a sample that has been filtered in the laboratory. In the event that laboratory filtration is required, sample aliquots collected for dissolved metals analyses will be preserved after filtration and these preserved aqueous samples will be allowed to equilibrate a minimum of 24 hours between sample preservation and digestion. For some investigations, a filtered and nonfiltered sample aliquot may be submitted for all requested analytical parameters. In the event that the filtered and nonfiltered aliquots are not assigned distinct sample identifications (IDs), each parameter will be identified as either total (i.e., nonfiltered) or dissolved (i.e., filtered) in the project database. The reporting limits indicated in Attachments E and F of this QAPP shall represent the maximum reporting limits (not adjusted for sample weight/volume, dilution factors, and percent moisture for non-aqueous samples). All analytical methods performed by the TVA-contracted laboratory must have valid method detection limit (MDL) studies and MDL verifications by matrix type, by preparation method, and by analytical method. MDL studies must include all preparatory and analytical processes used for the preparation and analysis of investigative samples. Formal MDL evaluations must be performed at the frequency dictated by the current US EPA-promulgated procedures or the current The NELAC Institute (TNI) laboratory accreditation standard or the frequency dictated below, whichever is more frequent. TVA s contracted laboratories will conduct MDL studies in accordance with the current TNI laboratory accreditation standard as described below. The initial MDL study will include a minimum of seven spiked replicates prepared and analyzed in a minimum of three separate batches, spaced over the course of three separate calendar days. If an MDL is to be determined over more than one instrument, each instrument must have at least two analyses on two different calendar days. For an analyte to be considered detected during an MDL study it must meet the analytical method s qualitative identification criteria without any manual searching routines. Only analyses associated with acceptable initial calibration, continuing calibration, and batch QC can be used. The MDL based on spiked replicates will be calculated as follows: Where: MDL t n 1,1 s ( 0.99 ) MDL = s MDL based on analysis of replicate spikes, t = Students 99 th percentile single-tailed t-value and S = the sample standard deviation of the replicate analyses. S If the calculated MDL s for any analyte is less than 10% the concentration of the spiked concentration, repeat the study for that analyte at a lower spike concentration. If the calculated MDL s is higher than the spiked concentration, the study must be repeated at a higher spike concentration from the original study. In addition to the spiked samples, an MDL will be determined using method blank results (MDL b ). The initial MDL b determined using the method blanks will be a minimum of seven method blanks prepared and analyzed in at least three separate batches, spaced over the 27

116 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 course of three separate calendar days. If an MDL b is to be determined over more than one instrument, each instrument must have at least two analyses on two different calendar days. For an analyte to be considered detected during an MDL study it must meet the analytical method qualitative identification criteria without any manual searching routines. Only analyses associated with acceptable initial calibration, continuing calibration, and batch QC can be used. If the analytical system for which the MDL b is being determined gives numeric results for every analysis, the MDL b will be calculated as follows: MDL b X t( n1,1 0.99) S Where: X = the mean of the method blank results, t = Students 99 th percentile single-tailed t-value and S = the sample standard deviation of the replicate analyses. If the analytical system for which the MDL b is being determined gives censored results or otherwise gives numeric results for some, but not all method blanks: If fewer than 101 numeric method blank results are available, set the MDL b to the highest method blank result. If more than 100 numeric method blank results are available, set the MDL b to the level that is no less than the 99 th percentile of the method blank results. MDL s and MDL b must be compared and the higher value utilized for MDL reporting. The MDL is to be verified annually through the quarterly analysis of standards spiked at the same concentration used to determine MDL s. For verification analyses for a pooled MDL for more than one instrument, each instrument must have at least two analyses, prepared in different batches and analyzed on separate days. MDL verification analyses must meet the analytical method qualitative identification criteria, again without any manual searching routines. Only analyses associated with acceptable initial calibration, continuing calibration, and batch QC can be used. On an annual basis, the MDL calculation is to be repeated using the results from the quarterly spiked samples and method blanks. The resulting MDL is to be compared to the initially derived MDL. If the repeated MDL is within a factor of 0.5 to 2.0 of the existing MDL, and fewer than 3% of the method blank results have numerical results above the existing MDL, then the initially derived MDL may be left unchanged. Otherwise, adjust the MDL to the new repeated MDL. To add a new instrument, the new instrument must have at least two spike analyses and at least two method blanks. The new spike results would be combined with the existing results and a new MDL s would be calculated. If the new MDL s is within a factor of 0.5 to 2.0 of the existing MDL, then the initially derived MDL s may be left unchanged. If all method blank analyses are below the existing MDL and the MDL s meets the criteria described above, the MDL may be left unchanged. Otherwise, adjust the MDL to the new MDL. Once 6-months of blank data have been generated on a new instrument, MDLs should be evaluated to assess the need for adjustment. 28

117 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 The laboratory will perform a percent moisture analysis on solid samples where possible. Chemical analysis results for solid samples will be reported on a dry-weight basis unless specifically requested otherwise. Radiological activities and physical/optical analysis results will not be corrected for sample moisture. The reporting basis (wet-weight, dry-weight, etc.) will be maintained as an attribute of the result in the database QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS This section describes the data objectives and associated data quality indicators used for the project. QA procedures are designed to ensure high quality for all environmental data associated with this project. The subsections below are intended to provide an introduction to site-wide QA objectives and protocols and set forth minimum requirements for the ALF RI. Specific quantitative QA objectives for each investigation are presented in Attachments E and F of this QAPP General There are four levels of data quality that have been developed for this project. The data quality levels defined below provide general indications of measurement defensibility. The data quality level of a particular measurement is used to determine whether that measurement is sufficient to meet the program-specific DQOs. Field Screening This level is characterized by the use of portable analytical instruments (such as temperature probe) which can provide real-time data to assist in the optimization of sampling locations and health and safety support. Data can be generated regarding the presence or absence of certain contaminants at sampling locations. Field Analyses This level is characterized by the use of portable analytical instruments, which can be used on site (such as YSI instrument) or in a mobile laboratory stationed near a site. Depending on the types of contaminants, sample matrix, and personnel skills, qualitative and quantitative data can be obtained. Screening Data with Definitive Confirmation These data are generated by rapid, less precise methods of analysis with less rigorous sample preparation. Sample preparation steps may be restricted to simple procedures such as dilution with a solvent, instead of elaborate extraction/digestion and cleanup. Screening data provides analyte identification and quantitation, although the quantitation may be relatively imprecise. At least 10% of the screening data will be confirmed using appropriate analytical methods and QA/QC procedures and criteria associated with definitive data. Screening data without associated confirmation data is not considered to be data of known quality. Definitive Data These data are generated using rigorous analytical methods, such as approved US EPA reference methods. Data are analyte-specific, with confirmation of analyte identity and concentration. These methods produce tangible raw data (such as chromatograms, spectra, or digital values) in the form of paper printouts or computer-generated electronic files. Data may be 29

118 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 generated by an on-site or off-site laboratory, as long as the QA/QC requirements are satisfied. To be definitive, either the analytical or total measurement error must be determined. Field Screening data will be obtained with portable instruments, such as conductivity meters, temperature probes, and may be used for health and safety and field operational monitoring. In addition, these instruments and field test kits may be used to produce Field Analysis data to determine where to collect a sample to assess impacts and identify which samples are to be designated for laboratory confirmation analyses. Field ph measurements will meet the requirements of TVA TI Field Measurement Using a Multi- Parameter Sonde (ENV-TI ), the U.S. EPA Region 4 Operating Procedure for Field ph Measurement (SESDPROC-100-R3, January 2013), and the associated investigation-specific SAP. Field ph meters used for collecting data will also meet the calibration requirements of these procedures including calibration adjustment to account for buffer temperature during calibration. Field-collected ph measurements will be considered field analysis data and are appropriate for quantitative use. Attainment of qualitative data indicators is assessed by monitoring QA measures, such as accuracy, precision, representativeness, comparability, and completeness, as discussed in Section Specific qualitative criteria for the chemical analyses to be performed in association with the ALF RI are presented in Attachments E and F of this QAPP. The objectives associated with accuracy and precision of laboratory results are assessed through an evaluation of the results of QC samples. The accuracy of field measurements will be assessed by calibration, as described in the associated field TIs Field and Laboratory Quality Control Samples The quality of data collected in the field will be controlled, monitored, and verified by maintaining site logs, by documenting field activities, and by collecting and analyzing of QC samples concurrently with investigative samples. Field and laboratory QC samples will be used to assess accuracy and precision for chemical analyses to gauge both field and laboratory activities. Further discussion and equations for determining precision and accuracy may be found in Section 21 of the ALF RI QAPP. In addition, specific requirements for comparability, completeness and representativeness of field and laboratory QC samples may be found in Section 21 of the ALF RI QAPP. QC samples will be used to assess laboratory performance and gauge the likelihood of cross-contamination associated with both field and laboratory activities. The subsections below apply to chemical analyses performed on aqueous and solid samples associated with the ALF RI. QC samples will be collected and analyzed in conjunction with samples designated for laboratory analysis. The QC checks that may be instituted by field and laboratory personnel may include, but not be limited to, the following: Equipment Rinsate Blanks. Field Blanks Filter Blank Samples 30

119 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Field Duplicate Samples. MS/MSD Samples. Laboratory Method Blanks. LCSs/Laboratory Control Sample Duplicates (LCSDs). Laboratory Duplicate Samples. These types of QC samples are discussed in the following subsections. Field QC samples will be submitted to the laboratory using the same information as the associated investigative samples. Field QC samples will be collected at the frequency specified on Table Laboratory QC samples will be analyzed at the frequency specified in the associated laboratory SOPs and referenced analytical methods. The analysis frequencies specified below are considered the minimum required frequencies; program-specific Work Plans and/or SAPs and/or TIs may require more frequent collection of field QC samples. Table Field Quality Control Sample Minimum Frequency Field QC Sample Equipment Rinsate Blank Field Blank Filter Blank Field Duplicate a MS/MSD or Laboratory Duplicate b Aqueous Sampling Frequency 1 per sampling event 1 per day of sampling activity 1 per sampling event when dissolved parameters are collected for analysis and 1 per lot of filters used 1 per 10 field samples; minimum of 1 per sampling event 1 per 20 field samples; minimum of 1 per sampling event Solids Sampling Frequency 1 per 20 field samples N/A N/A 1 per 10 field samples; minimum of 1 per sampling event 1 per 20 field samples; minimum of 1 per sampling event N/A a b c Not Applicable True field duplicate samples are not feasible for whole ash/sediment cores (depending on volume recovered); consequently, co-located samples will be collected when possible. Laboratory duplicate analyses will be performed in lieu of MS/MSD for parameters not amenable to spiking (e.g., ph, total dissolved solids [TDS]). Filter lot check is to be performed one per lot of filters used and scheduled in a manner to allow for laboratory to report data prior to investigative sample collection. 31

120 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September Equipment Rinsate Blanks Collection and analysis of equipment rinsate blanks are performed to assess the efficiency of field equipment decontamination procedures in preventing cross-contamination between samples. Laboratory-supplied analyte-free reagent water will be poured into/through/over clean (decontaminated) sampling equipment used in the collection of investigative samples and subsequently collected into prepared sample bottles. For soil core sampling, analyte-free reagent water will be poured through core liner. The rinsate blank will be analyzed for the same parameters as the investigative samples Field Blanks Field blanks are used to assess the potential for cross-contamination of aqueous samples during the sampling process due to ambient conditions and to validate the cleanliness of sample containers. The collection of field blanks is recommended if known or suspected sources of contamination are located within close proximity to the sampling activities. Field blank samples will be generated using laboratory-supplied deionized water Filter Blank Samples Filter blanks are samples of laboratory-supplied deionized water passed through in-line filters used in the collection of dissolved metals (or other analytes) Field Duplicate Samples Field duplicate samples are used to check for sampling and analytical error, reproducibility, and homogeneity. For soil samples, the duplicate will be obtained by collecting a sample from an area adjacent to the routine sample (that is, co-located sample), or by collecting a separate aliquot of homogenized soil from within the same core, whichever is more appropriate for the type of sample/sampling technique (surface or subsurface sediment sample). Duplicates will be analyzed for the same parameters as the associated investigative samples Matrix Spike/Matrix Spike Duplicate MS/MSD samples are investigative samples to which known amounts of compounds are added in the laboratory before extraction/digestion and analysis. The recoveries for spiked analytes can be used to assess how well the method used for analysis recovers target analytes in the site-specific sample matrix, a measure of accuracy. Additionally, the relative percent difference (RPD) between the results of the MS and MSD provide a measure of precision. In the event that sufficient sample volume to perform MS/MSD analyses is not provided, the laboratory may substitute LCS/LCSD analyses (see Section ). For parameters that are not amenable to spiking (e.g., ph, total dissolved solids [TDS]), a laboratory duplicate (see Section ) will be used to demonstrate matrix-specific precision Laboratory Method Blanks Method blanks consist of analyte-free materials (such as reagent water) and reagents (such as sodium sulfate) that are prepared in the same manner as the associated samples (digested, extracted, etc.) and that are analyzed and reported in the same manner as the associated 32

121 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 investigative samples. Laboratory method blanks will be performed as indicated in the analytical method and in the associated laboratory SOPs Laboratory Control Samples/Laboratory Control Sample Duplicates An LCS is a sample of laboratory certified material that is fortified (spiked) with the analytes of interest or a certified reference material that is prepared and analyzed in the same manner as investigative samples. The LCS must be from a source that is different from the source of the initial calibration standards (that is, second-source). LCS data are used to monitor analytical accuracy and laboratory performance. LCSs are prepared and analyzed with each preparation batch of 20 (or less) field samples. In the event that insufficient sample volume to perform MS/MSD analyses (Section ) is received, an LCSD will be prepared to assess laboratory precision. LCS will be performed at a minimum frequency of 1 per batch of 20 (or fewer) field samples or as required by the referenced analytical method and as specified in the associated laboratory SOPs Laboratory Duplicate Samples A duplicate sample is obtained by splitting a field sample into two separate aliquots and performing separate preparation and analysis on the respective aliquots. The analysis of laboratory duplicate samples monitors precision; however, precision may be affected by sample homogeneity, particularly in the case of solid samples. Laboratory duplicates will be analyzed and reported with every batch of 20 (or fewer) field samples. MSDs (see Section ) may be substituted for laboratory duplicates for inorganic analyses. The laboratory will utilize a project sample for the laboratory duplicate in every batch that includes project samples INSTRUMENT/EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE REQUIREMENTS 12.1 Field Equipment Equipment failure will be minimized by routinely inspecting field equipment to ensure that it is operational and by performing preventive maintenance procedures. Field sampling equipment will be inspected prior to sample collection activities by the Field Team members and necessary repairs will be made prior to use of the sampling equipment. Routine preventive maintenance procedures, at a minimum, will include removal of foreign debris from exposed surfaces of the sampling equipment, storage of equipment in a cool dry place protected from the elements, inspections of the equipment each day prior to use, and verification of instrument calibrations as described in Section Equipment, instruments, tools, gauges, and other items requiring preventive maintenance will be serviced in accordance with the manufacturer s specified recommendations or written procedure based on the manufacturer s instructions or recommendations. Maintenance will be performed in accordance with the schedule specified by the manufacturer to minimize the downtime of the measurement system. Maintenance work will be performed by qualified personnel. A list of critical spare parts will be developed prior to the initiation of fieldwork. Field personnel will have ready access to critical spare parts to minimize downtime while fieldwork is in progress. A service contract for rapid instrument repair or backup instruments may be 33

122 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 substituted for the spare part inventory. A listing of field equipment and critical spare parts (where applicable) may be found in the site-specific Work Plans and/or SAPs and/or associated field TIs. Non-routine maintenance procedures require field equipment be inspected prior to initiation of fieldwork to determine whether or not the equipment is operational. If not operational, the equipment will be serviced or replaced. Batteries will be fully charged or new, as applicable. The ability to collect valid samples requires that field equipment be appropriately cleaned and maintained. The elements of an effective maintenance program are identified below. Pre-cleaned or certified-clean equipment. Spare parts. Contingency plan. Maintenance and repair of non-dedicated equipment Supplies and Consumables Field supplies and consumable items (including, but not limited to, pre-cleaned containers, preserved containers, tubing, and filters) will be inspected upon receipt. Certificates of cleanliness for consumables provided by the laboratory will be retained on file at the laboratory. Chemical preservatives provided in pre-preserved containers will be certified by the laboratory prior to use. Certificates of cleanliness for supplies and lot numbers of supplies obtained by the Field Team will be retained by Investigation Consultant personnel as part of the project records. All supplies and consumable materials will be certified clean to levels sufficient to meet data objectives for the associated investigation Laboratory Equipment The ability to generate valid analytical data requires that analytical instrumentation be properly maintained. The laboratory will be responsible for appropriate maintenance for major instruments. The elements of an effective maintenance program are identified below and discussed in the following subsection: Instrument maintenance logbooks. Instrument maintenance and repair. Available spare parts. Contingency plans. Periodic preventive maintenance is required for sensitive equipment. Instrument manuals will be kept on file for reference when equipment needs repair. The troubleshooting sections of factory manuals may be used to assist personnel perform maintenance tasks. Major instruments in the laboratory are covered by annual service contracts with manufacturers or other qualified personnel (internal or external). Under these agreements, regular preventive maintenance visits are made by trained service personnel. Maintenance is documented and maintained in permanent records by the individual responsible for each instrument. 34

123 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 The calibration and maintenance sections of the laboratories SOPs will establish the schedule for servicing critical items to minimize the downtime of the measurement system. The laboratory will adhere to the maintenance schedule and will promptly arrange any necessary service. Qualified personnel will perform required service Instrument Maintenance Logbooks In the laboratory, each analytical instrument will be assigned an instrument logbook. Maintenance activities will be recorded in the instrument logbook and the information entered will include: Date of service. Person performing the service. Type of service performed and reason for service. Replacement parts installed (if applicable). Miscellaneous information. If service is performed by the manufacturer or its representative, a copy of the service record will be inserted into the page immediately following the logbook page where the above-cited information has been entered Instrument Calibration and Maintenance An overview of the routine calibration procedures used for analytical instrumentation is presented in Section Preventive maintenance and calibration by manufacturer service representatives will be provided on a routine basis. In addition to maintenance by manufacturer service representatives, procedures for routine maintenance in accordance with manufacturer specifications for each analytical instrument will be followed by the laboratory. These procedures will include maintaining inventories of spare parts used routinely (such as spare torches for inductively coupled plasma/mass spectrometry [ICP/MS] instruments). Instrument operators have the responsibility to ensure that an acceptable inventory of spare parts is maintained. Instrument calibration and maintenance procedures will be conducted in accordance with the laboratory s QA Program and the specific calibrations sections of the laboratory s analytical SOPs INSTRUMENT CALIBRATION AND FREQUENCY This section provides the requirements for calibration of measuring and test equipment/instruments used in field sampling and laboratory analysis. The calibration procedures stipulated in the ALF RI QAPP are designed to ensure that field equipment and instrumentation are calibrated to operate within manufacturer specifications and that the required traceability, sensitivity, and precision of the equipment/instruments are maintained. Measurements that affect the quality of an item or activity will be taken only with instruments, tools, gauges, or other measuring devices that are accurate, controlled, calibrated, adjusted, and maintained at predetermined intervals to ensure the specified level of precision and accuracy. 35

124 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 In general, instrument calibration will be conducted in accordance with manufacturer s recommendations, method requirements, and field TIs or laboratory SOPs Field Equipment Calibration and Procedures Field instruments that may be used include, but are not limited to, the following: Multi-parameter Sonde Water Quality Meter. Oxidation Reduction Potential Meter. Dissolved Oxygen Meter. Water Flow Meter. Depth-to-Water Level Meter. Turbidimeter. All field analytical equipment used to conduct monitoring will be calibrated/standardized daily prior to use. The calibration/standardization procedures for field instrumentation are described in the calibration section of the applicable field TIs. The calibration/standardization acceptance criteria for field instruments are provided in the applicable TVA TIs. Personnel performing instrument calibrations/standardizations shall be trained in its proper operation and calibration. Records of instrument calibration/standardization will be maintained by the Investigation Consultant Field Team Leader and will be subject to audit by the Field Oversight Coordinator or designee. The Investigation Consultant Field Team Leader will maintain copies of the instrument manuals on site. The calibration records will include documentation of the following information: Instrument name and identification number. Name of person performing the calibration. Date of calibration. Calibration points. Results of the calibration. Manufacturer lot number of the calibration standards. Expiration dates for the calibration standards, when applicable. Field equipment will be properly inspected, charged, and in good working condition prior to the beginning of each working day. Prior to the start of each working day, the Investigation Consultant Field Team Leader will inspect equipment to ensure its proper working condition. If equipment is not in the proper working condition, the Investigation Consultant Field Team Leader must repair or replace the equipment prior to the start of field activities. Field equipment and instruments will be properly protected against inclement weather conditions during the field work. At the end of each working day, field equipment and instruments will be properly decontaminated, taken out of the field, and appropriately placed for overnight storage and/or charging. Field-collected ph measurements will be considered field analysis data and are appropriate for quantitative use. Field ph measurements will be conducted using calibrated instrumentation sufficient to meet the requirements of TVA TI Field Measurement Using a Multi-Parameter 36

125 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Sonde (ENV-TI ), the US EPA Region 4 Operating Procedure for Field ph Measurement (SESDPROC-100-R3, January 2013), and the associated investigation-specific SAP. In addition to the TVA and method requirements, post-calibration checks will be performed on ph 4.0 and ph 10.0 buffer solutions. All post-calibration checks (ph 4.0, 7.0, and 10.0) will be subject to an acceptance criterion of ±0.2 ph units. Sample ph measurements will not be conducted until the ph meter is calibrated within these acceptance criteria. Calibration checks may suggest the need for maintenance or calibration by the manufacturer. Field instruments that do not meet the calibration requirements will be taken out-of-service until acceptable performance can be verified. Maintenance will be performed when the instrument will not adequately calibrate. Maintenance of field equipment will be noted in an instrument logbook or field notebook. Field equipment calibration is addressed in greater detail in the TIs associated with each field investigation or monitoring activity Laboratory Equipment Calibration Instruments and equipment used in the laboratory will be controlled by a formal calibration program as described in the laboratory s Quality Assurance Manual. The program will verify that the equipment has the proper calibration range, accuracy, and precision to generate data comparable with specific requirements. Calibration will be performed by laboratory personnel experienced in the referenced methods for the analysis of project samples for the constituents of concern. Instrument calibration procedures and corrective actions are described in the calibration section of the associated laboratory SOP. At a minimum, laboratory instrument calibration will be performed in accordance with the associated technical and quality control requirements specified in the method applicable to the associated SAPs. The laboratory will provide all data and information to demonstrate that the analytical system was properly calibrated at the time of analysis, including: calibration method, required frequency, source of standards, response factors, linear range, check standards, and applicable control limits, as part of the data deliverables. Before any instrument is used as a measuring device, the instrument s response to reference materials must be determined. The manner in which various instruments are calibrated is dependent on the particular type of instrument and its intended use. Preparation of reference materials used for calibration will be documented in a laboratory notebook. The two types of laboratory instrument calibration are initial calibration and continuing calibration verification. Initial calibration procedures establish the calibration range of the instrument. Typically, multiple analyte concentrations are used to establish the calibration range and calibration data. The laboratory evaluates the resulting calibration data as detailed in the calibration section of the associated SOP. Continuing calibration verification usually measures the instrument s response to fewer calibration standards and requires instrument response to fall within certain limits of the initial measured instrument response. Continuing calibration verification may be used within an 37

126 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 analytical sequence to verify stable calibration throughout the sequence and/or to demonstrate that instrument response did not drift during a period of non-use of the instrument. The QA measures in the calibration section of the associated laboratory SOP will be used for calibration, calibration verification, and subsequent sample analyses. In addition, the following procedures will be used for the calibration of balances and thermometers. Laboratory balances will be calibrated and serviced annually by a certified contractor. Balances will undergo a calibration check prior to use each day using multiple S-Class or equivalent class weights that bracket the usage range. A record of calibrations and daily checks will be documented. Oven and refrigerator thermometers will be calibrated annually against a National Institute of Standards and Technology- (NIST-) certified thermometer in the range of interest. Annual calibrations will be documented. Daily oven and refrigerator readings will be recorded. Thermometers must be tagged with any applicable correction factors. Records will be maintained as evidence of required calibration frequencies, and equipment will be marked suitably to indicate calibration status. If marking on the equipment is not possible, records traceable to the equipment will be readily available for reference DATA ACQUISITION REQUIREMENTS FOR NON-DIRECT MEASUREMENTS Historical and legacy data may be considered when appropriate to achieve the objectives of the ALF RI. Historical and legacy data may be procured from several sources, including TVA and TDEC records. Historical and legacy chemical data of known quality/defensibility may be used quantitatively as supplemental information to design specific investigation or for human health and ecological risk assessments. Chemical data are considered of known quality/defensibility if sample collection information and data deliverables are available to substantiate the reported analytical results. Historical and legacy data of unknown quality may be used for qualitative purposes. Historical and legacy geotechnical data of known quality/defensibility may be used quantitatively as supplemental information to planned investigations under the ALF RI. The quality/defensibility of geotechnical data will be determined by qualified personnel (i.e., Professional Engineer or Professional Geologist) depending on the type of data requiring evaluation. Generally, these data will be compared against changes in site conditions, changes in the state of practice (e.g., revisions/updates to standard methods), and changes in governing standards (e.g., technical standards or professional guidelines) since the data were generated and also will be compared to more recently collected data for consistency of results. Historical and legacy data will be transmitted in its original format whenever possible. In addition, raw data and other supporting documentation is acquired and may be validated if appropriate or feasible. Historical and legacy data that are determined to be intended for quantitative use will be subjected to a formal critical review process. Historical data will minimally be subjected to a reasonability review to identify potentially suspect data, apparent anomalies, or data that are not representative of current site conditions. Additional evaluation and/or validation may be conducted following the reasonability review; the level of review and validation conducted will be 38

127 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 dependent on the data type, availability of supporting documentation, and criticality of the dataset for completing project objectives. In the event that historical or legacy data cited in the ALF RI cannot be substantiated, the data may not be suitable the support certain aspects of the investigation, and new data may be collected to supplement the historical/legacy data. TVA, QA Oversight, and Investigation Consultant and personnel subject-matter experts will cooperatively develop formal criteria for evaluating historical data sets for potential quantitative use to achieve ALF RI objectives DATA MANAGEMENT A comprehensive ALF RI DMP will be developed for all data generated and used under the ALF RI. Consolidated management of data related to the ALF RI will ensure that environmental data associated with the project are appropriately maintained and accessible to data end users. The ALF RI DMP will provide a basis for supporting a full technical data management business cycle from pre-planning of sampling events to reporting and analysis with a particular emphasis on ensuring completeness, data usability, and most importantly defensibility of the data. Historical data and data generated from RI collection events will be consolidated in the single EQuIS database. The EQuIS database will implement QA procedures at each step in the data transfer process to ensure that a complete, correct data set is maintained. A detailed description of the various elements of the data management program is presented in the ALF RI DMP. In addition, the ALF RI DMP describes sample planning and tracking process and details the flow of field and laboratory data into the project database. Finally, the ALF RI DMP describes the process by which errors in data already reported in the project database are rectified and how those changes are managed and documented ASSESSMENTS AND RESPONSE ACTIONS The primary goal of the ALF RI is to ensure that project data objectives are met and that defensible, high-quality, analytical data are generated for use decision-making processes. The ALF RI includes systems and performance audits to ensure that established QA procedures are properly implemented Field Activities Field QA will include (but not be limited to) the following: Instrument calibration. Documentation of sample collection and field conditions. Adherence to COC procedures. Adherence to the ALF RI QAPP, the RI SAP, and the associated field TIs. Collection of field QC samples. The QA review for usability of objective field data will be performed at two levels. For the first level, data will be reviewed at the time of collection by following SAPs and TVA TIs. For the second level, after data reduction to table format or arrays, the data will be reviewed for inconsistent values. 39

128 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Any inconsistencies identified during data review will be investigated by the Field Team Leader. When possible, the Investigation Consultant Field Team Leader will seek clarification from the field personnel responsible for collecting the data. Resolution of discrepancies will be documented using the corrective action process detailed in Section Field data will be reviewed for reasonableness and completeness. In addition, random checks of sampling and field conditions will be made to check recorded data at that time to confirm the recorded observations. Whenever possible, peer review will also be incorporated into the QA review process in order to maximize consistency among field personnel. Any observed discrepancies between the COC Record and the samples received will be documented by the laboratory, and the TVA Technical Lead, QA Oversight Manager, and the Investigation Consultant Field Team Leader will be contacted for resolution. The field COC Record information will be initially keyed into and maintained in the laboratory s database. A copy of the laboratory s COC Record, referred to as sample receipt confirmation, will be sent to the QA Oversight Manager and Data Manager following sample login for verification of properly entered and COC Record requests and information such as sample identification numbers, analyses requested, and the quantity of samples. In case of discrepancies between the COC Record and the sample receipt confirmation, the appropriate revisions will be communicated to the laboratory for the appropriate COC Record corrections. Corrected information on the COC Record will be recorded into the project data management system Laboratory Analysis Internal laboratory QA will consist of the following: Instrument performance checks. Instrument calibration and calibration verification. Retrieval of documentation pertaining to instrument standards, samples, and data. Adherence to the ALF RI QAPP and the associated laboratory SOPs. Documentation of sample preservation, transport, and analytical methodology. Adherence to the analytical methodology (at a minimum). Analysis of QC samples (discussed in Section 11.2). The samples received by the laboratory will be handled in accordance with internal laboratory QC procedures. The laboratory s deliverables, on submission to Data Validators, will be verified and/or validated with guidance from the National Functional Guidelines. Data package completeness will be assessed and missing or incomplete information will be obtained from the laboratory. Any incorrect data will be corrected. Data usability will be evaluated and appropriate qualifiers will be added to the database. Any data deemed unreliable by data validation efforts due to imprecision, holding time exceedances, and failure of relevant QC measures will be qualified appropriate and/or not utilized for the project Data Reduction Data reduction is performed by the individual Analysts and consists of calculating concentrations in samples from the raw data obtained from the measuring instruments. Data 40

129 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 reduction complexity is dependent upon the specific method and the number of discrete operations (extractions/digestion, dilutions, and levels/concentrations) involved in obtaining a sample that can be measured. For analytical methods, sample response will be applied to the average response factor or the regression line to obtain an initial raw result, which will then be factored into equations to obtain the estimate of the concentration in the original sample. Rounding will not be performed until after the final result has been obtained to minimize rounding errors; results will not normally be expressed in more than three significant figures. Copies of raw data and calculations used to generate the final results will be retained on file to allow reconstruction of the data reduction process at a later date. The laboratory data reduction process is described in detail in the associated laboratory SOPs Laboratory Data Review System reviews are performed at all levels. The individual analyst continuously reviews the quality of data through calibration checks, QC sample results, and performance evaluation (PE) samples. These reviews will be performed prior to submission to the Laboratory Project Manager or designee. Criteria for analytical data review/verification include checks for internal consistency, transmittal errors, laboratory protocol, and laboratory QC. QC sample results and information documented in field notes will be used to interpret and evaluate laboratory data. The Laboratory QA Department will independently conduct a complete review of selected reports to confirm analytical results. The laboratory will complete data verification procedures, including: Verifying analyses requested were analyses performed. Preliminary data proofing for inconsistencies; investigation and corrections, where possible. Reviewing laboratory data sheets for reporting/detection limits, holding times, surrogate recovery performance, and spike recovery performance. Double-checking computerized data entry, if applicable. The Laboratory Project Manager or designee will review data for consistency and reasonableness with other generated data and determine whether project requirements have been satisfied. Selected hardcopy output of data will be reviewed to ensure that results have been interpreted correctly. Unusual or unexpected results will be reviewed, and a determination will be made as to whether the analyses should be repeated. In addition, the Laboratory Project Manager or designee may recalculate selected results to verify the calculation procedure. The Laboratory QA Manager will independently conduct a review of the Project data to determine project requirements have been met. Discrepancies will be reported to the Laboratory Project Manager or designee for resolution. 41

130 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Prior to final review/signoff by the Laboratory Project Manager or designee, the laboratory personnel will verify that the report deliverable is complete and in proper format, screen the report for compliance to laboratory and QAPP requirements, and ensure that the Case Narrative addresses any noted deficiencies. The Laboratory Project Manager or designee will perform the final laboratory review prior to reporting the results to the QA Oversight Consultant and TVA. Any discrepancy noted during laboratory review that results in sample reanalysis or data correction must be documented using the corrective action procedure addressed in Section Performance and System Audits Internal audits will be initiated by the QA Oversight Manager at the discretion of the TVA Technical Lead. Internal audits may be conducted based upon issues identified during various other assessment activities. The internal systems and performance audits will be planned and conducted by the QA Oversight Manager or designee or other appropriate QA Program personnel with the experience and competency to perform the audits/assessments. As part of the planning process for conducting internal audits, internal audits or assessments will first be scheduled. Next, the Audit Team will be identified, and the pertinent documentation and procedures relevant to the audit will be obtained and reviewed by the Audit Team. Internal audits may be announced or unannounced. The Audit Team members will hold a minimum of a Bachelor s degree in a scientific discipline and have 5 or more years of QA and on-site laboratory auditing experience. As indicated in Section 2.0, the QA Oversight Manager holds overall authority for the project QA Program and maintains that authority independently from the operational/production aspects of the project. Documentation of systems and performance audits and any resulting corrective actions will be maintained as part of the Project File. Audit documentation will be reported to the TVA Technical Lead Performance Audits Performance audits are quantitative evaluations of data quality produced by a particular activity or function. Performance audits of the participating laboratories performing chemical analyses of project samples may be conducted through the submission and analysis of performance evaluation samples. The QA Oversight Manager or designee will coordinate the manufacture and submission of performance audit samples to the laboratory. A NELAC-approved performance testing sample provider will be used to obtain the performance evaluation samples. PE sample studies will be conducted at the discretion of the TVA Technical Lead for TVA contract laboratories analyzing aqueous and solid samples associated with the ALF RI. The performance evaluation sample matrices and requested analytes will be determined based on the nature of the work performed by that laboratory for the project. Upon receipt of results from the performance evaluation study analyses, the QA Oversight Manager or designee will evaluate the data relative to the certified true values and will prepare a comprehensive report (including a discussion of non-analytical issues, such as data package preparation and presentation). If multiple laboratories are included in the performance evaluation study, a statistical evaluation of the results will be performed and a simple fencepost test will be conducted for each analyte to determine outliers; a set of warning limits and 42

131 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 acceptance limits (based on the set of data excluding outliers) will be generated for the analytes. The performance evaluation study report will contain a detailed account of any results that are outside of the established acceptance limits. Laboratories will be contacted to explain discrepancies between the reported concentrations and the known (true) concentrations of the analytes in the performance evaluation samples and to provide corrective actions in accordance with the corrective action process described in Section Performance evaluation sample documentation, inclusive of corrective action responses, will be maintained as part of the Project File System Audits System audits entail on-site observation and evaluation of participating laboratories and field sampling activities for compliance with the ALF RI QAPP, TIs, and/or program-specific Work Plans and/or SAPs. Prior to conducting an on-site audit, the Auditor will conduct a thorough examination of procedures and records. These on-site audits will also include verification of effectiveness of implemented corrective actions. The system audits will address both field and laboratory activities, including a review of personnel qualifications, equipment, documentation, sampling techniques, analytical methods, and adherence to QA procedures. Each laboratory has its own QA Plan; therefore, the laboratory audit activities under the ALF RI QAPP will entail a general review of laboratory QA practices. Systems audits of laboratories conducting chemical analyses of project samples will be performed by the QA Oversight Manager or designee. Field Audits will be conducted by the Field Oversight Coordinator or designee. On-site audits of laboratories analyzing samples associated with the ALF RI will be conducted at the discretion of the TVA Technical Lead. Each laboratory will be audited on an annual basis or more frequently as directed by the TVA Technical Lead. Field activities will be subjected to assessments and/or surveillances on a regular basis as new Sampling Teams, new procedures, or new sampling activities are performed. In addition, the Investigation Consultant Field Oversight Coordinator may observe sampling events as appropriate given the sensitivity of the samples collected Feedback and Corrective Action In general, feedback and corrective action processes for the ALF RI will be conducted in accordance with TVA s Corrective Action Program. TVA s Corrective Action Program includes various pathways depending on the nature and severity of the issue identified. Issues will be resolved using the lowest-level pathway that adequately identifies and addresses the cause of the non-conformance or deficiency and prevents recurrence Feedback Mechanism There are mechanisms within the project structure that allow for the identification, feedback, and control of any non-conformances or deficiencies. In general, the technical personnel involved with the project are responsible for reporting suspected technical non-conformances through 43

132 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 standard communication channels established by the organizational structure. In the same manner, project personnel are responsible for reporting suspected QA non-conformances. Feedback will be provided to laboratory personnel and the Field Team by the TVA Technical Lead, QA Oversight Manager, and/or Investigation Consultant. Laboratories may receive feedback based on systems and performance audits and ongoing data validation. In addition, laboratories may provide feedback to the QA Oversight Manager. Documentation of feedback will be maintained in the Project File Corrective Action for Field Activities Field personnel have the initial responsibility to monitor the quality of field measurements and observations. The Investigation Consultant Field Team Leader is responsible for verifying that QC procedures are followed. This responsibility requires the Investigation Consultant Field Team Leader to assess the correctness of field methods and the ability to meet QA objectives. If a problem occurs that might jeopardize the integrity of the project or that might cause a specific QA objective not to be met, the Investigation Consultant Field Team Leader will notify the TVA Technical Lead and QA Oversight Manager. An appropriate corrective action will then be determined and implemented. The Investigation Consultant Field Team Leader will document the problem, the corrective action, and the results. A copy of the documentation form will be provided to the TVA Technical Lead. Field auditing is a recognized technique for evaluating the performance of Field Sampling Teams and assessing how team performance may affect data quality. Field audits will be conducted by the Field Oversight Coordinator to ensure that sampling, handling, and transportation to project laboratories provide assurance that such procedures meet QA protocols and that field documentation is sufficient to produce data of satisfactory quality, to provide a defense in the event that field procedures are called into question, and to identify ways to reduce sampling costs. Field audits may be conducted as on-site observations or as desktop audits of field documentation to verify compliance with the RI SAP and/or TVA TIs. Field audits will be conducted at a minimum of once (for one-time field collection activity) or semi-annually (for reoccurring field activities), or as directed by the TVA Technical Lead or designee to verify that corrective actions have been implemented if deficiencies were identified in prior field audits or as requested by the TVA Technical Lead Laboratory Corrective Action Corrective action within the laboratory will be performed in accordance with the laboratory s formal QA Program. The laboratory has the responsibility to monitor the quality of the analytical system and to provide a corrective action process adequate to address problems encountered in laboratory analysis of samples. The laboratory will verify that QC procedures are followed and that the analytical results of QC samples are within the acceptance criteria. The verification requires that the laboratory assess the correctness of the following items, as appropriate: Sample preparation procedure. Initial calibration. Calibration verification. 44

133 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Method blank result. Laboratory control sample. Laboratory duplicate analysis. Fortified sample result. Internal standard performance. If the assessment reveals that the QC acceptance criteria are not met, the laboratory must immediately evaluate the analytical system and correct the problem. The Analyst will notify the Laboratory Project Manager and Laboratory QA Officer of the problem and, if possible, will identify potential causes and suggest correct action. When the appropriate corrective action measures have been implemented and the analytical system is determined to be in control, the Analyst will document the problem, the corrective action taken, and resultant data demonstrating that the analytical system is in control. Copies of the documentation will be provided to the Laboratory Project Manager and the Laboratory QA Officer. Data generated concurrently with an out-of-control system will be evaluated for usability relative to the nature of the deficiency. If the deficiency does not adversely impact the usability of the results, data will be reported and the deficiency will be addressed in the Case Narrative. If sample results are adversely impacted, the Laboratory Project Manager will be notified and appropriate corrective action (such as reanalysis) will be taken. Figure 16-1 presents the pathway for corrective actions. 45

134 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Figure Critical Path for Laboratory Corrective Action Out-of-Control System Alert Laboratory Project Manager and Laboratory QA Coordinator Review Procedures and Assess Problems Define Corrective Action Alternatives Discuss Corrective Action Alternatives with QAM Take Corrective Action System in Control No Redefine Corrective Action Reanalyze Sample Yes Yes Sample Reanalysis Required No Document Corrective Action and Result Release Data for Report 46

135 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September REPORTS TO MANAGEMENT The QA activities performed by laboratories conducting analyses of ALF RI samples will be monitored by the TVA Technical Lead and the QA Oversight Manager. Communication among TVA, QA personnel, the Investigation Consultant, and laboratory personnel is important to ensure that problems are remedied and that solutions are documented in an informed and timely manner. After the completion of a performance and systems audit, the QA Oversight Manager will submit an audit report to the TVA Technical Lead. This audit report will include a list of observed field activities, a list of reviewed documents, and any observed deficiencies. The TVA Technical Lead and QA Oversight Manager or designee will meet with the laboratory Project Managers of any area with observed deficiencies to review the audit findings, confirm the observations, and resolve misunderstandings. In the event that inadequacies are identified, corrective actions will be undertaken as outlined in Section Field QA Reports The Field Team Leader and Investigation Consultant will provide the TVA Technical Lead with routine field progress reports. Compiled field data sets will be provided to the Data Manager for inclusion in the project EQuIS database. The TVA Technical Lead and QA Oversight Manager or designee will be immediately notified about field QA situations that require corrective action. Corrective action will be performed and documented in accordance with the protocol set forth in Section Laboratory QA Reports The Laboratory QA Officer may provide periodic summary reports specific to the project to the QA Oversight Manager. These reports may summarize QA activities for the reporting period, including results of performance audits (external and internal), results of system audits (external and internal), summaries of corrective action to remedy out-of-control situations, and recommendations for revisions of laboratory procedures to improve the analytical systems. The Laboratory Project Manager will notify the QA Oversight Manager and Laboratory Coordinator about laboratory QA situations that appear to systematically impact data quality. The Laboratory QA Officer will immediately notify the QA Oversight Manager and the TVA Laboratory Coordinator of any laboratory QA situations that require corrective action and ascertain if such measures meet the DQOs of the project. Corrective action will be performed and documented in accordance with the protocol set forth in Section 16.4 or internal laboratory corrective action tracking system, as appropriate Internal Performance and System Audit/Assessment Reports Documentation of systems and performance audits and any resulting corrective actions will be maintained as part of the Project File. Audit documentation will be reported to the TVA Technical Lead. 47

136 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September DATA REVIEW, VERIFICATION, AND VALIDATION The Data Validators will verify or validate data generated by the laboratories for chemical analyses of project samples. Any issues observed during data validation will be brought to the attention of the QA Oversight Manager and TVA Technical Lead; the Laboratory Project Manager will be contacted to determine and implement an appropriate corrective action. The purpose of analytical data verification and validation is to ensure data completeness, correctness, and method compliance/conformance, and identify data quality, including unusable data that would not be sufficient to support environmental decisions. In addition to the laboratory QA review, the data presented in Level IV data packages will be verified and validated by the QA Oversight Consultant for the following: Compliance with requested testing requirements. Completeness. Reporting accuracy (including hardcopy to EDD). Confirmation of receipt of requested items. Traceability, sensibility, and usability of the data. In addition to the above criteria, data will be validated with guidance from the following documents: US EPA Contract Laboratory Program (CLP) National Functional Guidelines (NFG) for Superfund Organic Methods Data Review (June 2008); US EPA CLP NFG for Inorganic Data Review (October 2004); US EPA Region 4 Data Validation SOPs for CLP Cyanide Data (September 2011); US EPA Region 4 Data Validation SOPs for CLP Inorganic Data by Inductively Coupled Plasma Atomic Emission Spectroscopy (September 2011); US EPA Region 4 Data Validation SOPs for CLP Mercury Data by Cold Vapor Atomic Absorption (September 2011); US EPA Region 4 Data Validation SOPs for Organic Analysis (June August 2008); US EPA Region 4 Environmental Investigations SOPs and Quality Assurance Manual (November 2001). It should be noted that data validation guidelines specified above were developed for work conducted under the US EPA Contract Laboratory Program; therefore, these guidelines are not completely applicable to the Clean Water Act (CWA), Standard Methods, and SW-846 methods referenced for the EI. Professional judgment will be used as necessary to adapt the guidelines for use in evaluating usability of data generated in accordance with CWA, Standard Methods, and SW-846 methodology. Analytical data from off-site, commercial laboratories will be qualified with guidance from the National Functional Guidelines previously referenced. The data validation qualifiers listed below will be used for project samples: 48

137 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 U* R UR J UJ U* R UR J UJ Organic Data Validation Qualifiers This result should be considered not detected because it was detected in an associated field or laboratory blank at a similar level. Unreliable positive result; compound may or may not be present in sample. Unreliable reporting or detection limit; compound may or may not be present in sample. Quantitation is approximate due to limitations identified during data validation. This compound was not detected, but the reporting or detection limit should be considered estimated due to a bias identified during data validation. Inorganic Data Validation Qualifiers This result should be considered not detected because it was detected in a rinsate blank or laboratory blank at a similar level. Unreliable positive result; analyte may or may not be present in sample. Unreliable reporting or detection limit; analyte may or may not be present in sample. Quantitation is approximate due to limitations identified during data validation. This analyte was not detected, but the reporting or detection limit may or may not be higher due to a bias identified during data validation. The EDD and Full data packages for data generated from the chemical analysis of project samples will summarize the deviations from approved protocols and significant data findings in the Case Narratives. Analytical reports will be submitted to TVA and The QA Oversight Consultant as separate documents and will be transmitted in an electronic (.pdf and EDD) and/or hardcopy formats. The QA Oversight Consultant will maintain a database of TVA data for data validation and/or verification. The QA Oversight Consultant will complete data validation and generate reports for TVA. Data validation and project reports will be submitted to the TVA Technical Lead. Electronic validated data will be submitted upon approval from the TVA Technical Lead. The ALF RI DMP details the process for appending data qualifiers in the EQuIS database and submitting verified and validated data to data users. In addition to the validation qualifiers, qualifier reason codes will be maintained in the database. The reason codes below will be used to describe the usability issue(s) associated with results qualified during data review. Additional reason codes may be added as needed to address recurring usability issues. Reason Code BE BF BL BN C C+ Explanation Equipment blank contamination. The result should be considered not-detected. Field blank contamination. The result should be considered not-detected. Laboratory blank contamination. The result should be considered not-detected. Negative laboratory blank contamination. Initial and/or continuing calibration issue, indeterminate bias. Initial and/or continuing calibration issue. The result may be biased high. 49

138 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Reason Code Explanation C- Initial and/or continuing calibration issue. The result may be biased low. FD Field duplicate imprecision. FG Total versus Dissolved Imprecision. H Holding time exceeded. I Internal standard recovery outside of acceptance limits. L LCS and LCSD recoveries outside of acceptance limits, indeterminate bias. L+ LCS and/or LCSD recoveries outside of acceptance limits. The result may be biased high. L- LCS and/or LCSD recoveries outside of acceptance limits. The result may be biased low. LD Laboratory duplicate imprecision. LP LCS/LCSD imprecision. M MS and MSD recoveries outside of acceptance limits, indeterminate bias. M+ MS and/or MSD recoveries outside of acceptance limits. The result may be biased high. M- MS and/or MSD recoveries outside of acceptance limits. The result may be biased low. MP MS/MSD imprecision. P Post-digestion spike recoveries outside of acceptance limits, indeterminate bias. P+ Post-digestion spike recovery outside of acceptance limits. The result may be biased high. P- Post-digestion spike recovery outside of acceptance limits. The result may be biased low. Q Chemical preservation issue. R RL standards outside of acceptance limits, indeterminate bias. R+ RL standard(s) outside of acceptance limits. The result may be biased high. R- RL standard(s) outside of acceptance limits. The result may be biased low. S Radium flagged due to reporting protocol for combined results. SD Serial dilution imprecision. T Temperature preservation issue. X Percent solids < 50%. Y+ Chemical yield outside of acceptance limits. The result may be biased high. Y- Chemical yield outside of acceptance limits. The result may be biased low. Z ICP/MS interference. ZZ Other. 50

139 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 In addition to data validation qualification, data users may identify results that appear unreasonable or otherwise suspect when compared to the population of data. In these cases, data user qualifiers may be applied in the database VERIFICATION AND VALIDATION METHODS The overall QA objective for field activities, laboratory analyses, and data assessment is to produce data of sufficient and known quality to support the program-specific objectives and to produce high-quality, legally defensible data. This data assessment activity is an ongoing coordinated process with data production and is intended to ensure that data produced during the project are acceptable for use in subsequent evaluations. Both statistical and qualitative evaluations will be used to assess the quality of the data. The primary evaluation of the data will be based upon the control samples. The blank samples will be used to evaluate whether or not the laboratory and/or field sample handling represent a possible source of sample contamination. Duplicate sample results will be used to evaluate data precision. All data submitted to the project EQuIS database will undergo data verification. Analytical data will be available for preliminary internal use after verification. Initially, 100% of the all chemical and physical analysis data will be reported in fully documented (Level IV) data packages for independent data validation. If after the percentage of Full data validation has decreased, a trend in frequency of reporting issues, method non-compliances, or data usability issues is identified, data validation will be conducted for specific data points or the percentage of Full data validation percentage may be increased until the issues have been minimized to their initial frequency. Data verification includes the review of laboratory deliverables for completeness, correctness, and compliance with applicable methods. The validation of data presented in a Level IV data package includes the review of commercially-available raw data and associated QC summary forms for compliance with the applicable methods and for data usability with respect to the appropriate guidance documents. The nature and extent of the data package available for review is dependent on the analytical method used (such as US EPA methods, SW-846, etc.) and the reporting and deliverables requirements defined in QAPP and program-specific SAPs. After completion of either Full or Limited data validation, a QA report will be prepared. The QA report will address QAPP and method non-compliance issues, reporting errors, data usability issues, and include summary tables with qualified sample results. The QA report will also address laboratory calculation errors (i.e., the reported value is more than 10% different than the value calculated from the raw data by the data validator). The summary tables will include reported sample results and the associated data qualifiers. The QA report will be fully supported by photocopied pages of the laboratory data showing deficiencies identified in the review, as an Attachment to the report. The data produced during the sampling tasks included in the field investigation will be compared with the defined QA objectives and criteria for precision, accuracy, representativeness, completeness, and comparability (PARCC) and sensitivity. The primary goal of these procedures is to ensure that the data reported are representative of actual conditions at the Site. Standard procedures are used so that known and acceptable levels of PARCC are maintained for each data set. Descriptions of these criteria are presented in the following subsections. 51

140 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Specific quantitative QA objectives for chemical analyses associated with the ALF RI are presented in Attachments E and F of this QAPP Precision The degree of agreement between the numerical values of a set of duplicate samples performed in an identical fashion constitutes the precision of the measurement. During the collection of data using field methods and/or instruments, precision is checked by reporting measurements at one location and comparing results. For example, soil measurements are taken in pairs at a certain point and depth and the values compared. The measurements are considered sufficiently precise only if the values are within a specified percentage of each other. Analytical precision is calculated by expressing, as a percentage, the RPD between results of analyses of laboratory duplicate samples for a given analyte. Precision is expressed as an RPD when both results are greater than 5 the reporting limit as calculated by the following formula: AB Where: A = Value of original sample B = Value of duplicate sample When at least one result is less than 5 the reporting limit, the difference between the results is used to evaluate precision. Specific precision and difference objectives for field duplicate samples and laboratory duplicate samples (including MSDs) are presented in Attachments E and F of this QAPP Accuracy Accuracy is the degree of agreement of a measurement, X, with an accepted reference or true value, T. Accuracy is usually expressed as the difference between the two values, X-T, or the difference as a percentage of the reference or true value, 100(X-T)/T; accuracy is also sometimes expressed as a ratio X/T. Accuracy, which is a measure of the bias in a system, is assessed by means of reference samples and percent recoveries. Error may arise due to personal, instrumental, or method factors. The two types of analytical check samples used are LCSs and MSs. Analytical accuracy is expressed as the percent recovery (%R) of an analyte that has been added to the control sample or a standard matrix (such as blank soil) at a known concentration prior to analysis. The formula used to calculate accuracy for the LCS is: Where: % 100 A T = Total concentration of the analyte measured or recovered A F = Concentration of the analyte spiked 52

141 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 When calculating accuracy for the MS analysis, a correction for background concentration found in the unspiked sample must be made. MS recovery is calculated using the following formula: Where: % 100 A T = Concentration of the analyte measured or recovered A 0 = Unspiked concentration of the analyte A F = Concentration of the analyte spiked In general, the accuracy objectives are based on the requirements set forth in the referenced analytical method and in Attachments E and F of this QAPP Completeness Completeness is a measure of the degree to which the amount of sample data collected meets the needs of the sampling program and is quantified as the relative number of analytical data points that meet the acceptance criteria (including accuracy, precision, and any other criteria required by the specific analytical method used). Completeness is defined as a comparison between actual numbers of usable data points expressed as a percentage of expected number of points. Difficulties encountered while handling samples in the laboratory, as well as unforeseen complications regarding analytical methods, may affect completeness during sample analysis. The minimum goal for completeness is 90%; the ability to exceed this goal is dependent on the applicability of the analytical methods to the sample matrix analyzed. If data cannot be reported without qualifications, project completion goals may still be met if the qualified data (data of known quality, even if not perfect) are suitable for specified project goals. Percent completeness will be expressed as the ratio of the total number of usable results relative to the total number of analytical results. The total number of usable analytical results will be total number of results minus any results deemed unusable (or rejected) at validation Representativeness Representativeness expresses the degree to which sample data are accurate and precisely represent a characteristic of a population, parameter variations at a sampling point, or an environmental condition. Representativeness is a qualitative parameter associated with the proper design of the sampling program. The representativeness criterion can, therefore, be met through the proper selection of sampling locations, the collection of a sufficient number of samples and the use of standardized sampling procedures (viz., TVA TIs) to describe sampling techniques and the rationale used to select sampling locations to ensure representativeness of the sample data. Representativeness will also be measured by the collection of field duplicates or co-located samples, as appropriate given the sample matrix. Comparison of the analytical results of field duplicates will provide a direct measure of individual sample representativeness. 53

142 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September Comparability Comparability is a qualitative parameter used to express the confidence with which one data set can be compared with another. The comparability of the data, a relative measure, is influenced by sampling and analytical procedures. By providing specific protocols for obtaining and analyzing samples, data sets should be comparable regardless of who collects the sample or who performs the sample analysis. The laboratory will be responsible providing the following controls to allow assessment of comparability: Adherence to current, standard US EPA-approved methodology for sample preservation. Compliance with holding times and analysis consistent with QAPP. Consistent reporting units for each parameter of similar matrices. US EPA-traceable or NIST-traceable standards, when applicable RECONCILIATION OF DATA TO PROJECT OBJECTIVES The QA Oversight Manager, in conjunction with the TVA Technical Lead, will determine whether field and validated analytical data or data sets meet the requirements necessary for decisionmaking. The results of measurements will be compared to the objectives set forth in the RI SAP. Generally, data assessment begins with verification and validation of project data to ensure that the sampling and analysis protocols specified in the associated TVA TIs and RI SAP were followed, and that the measurement systems were performed in accordance with the criteria specified in these documents and this QAPP. Data limitations identified during data verification and validation are communicated to the project team via reports and qualification in the project database. Following data assessment, statistical analysis is performed to determine if the investigation and project objectives were achieved. As data are evaluated, anomalies in the data or data gaps may become apparent to the data users. Data that do not meet the data users needs will be identified and appropriately noted so that decision-makers are aware of data limitations. Data that are determined not to meet the investigation and project objectives may be used qualitatively or may be rejected depending on the program-specific requirements and the intended use of the data. The TVA Technical Lead, with the support of the QA Oversight Manager or designee and data validators, will assist data end users in evaluating data limitations identified and determining whether data are acceptable for their intended use. 54

143 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September REFERENCES American Public Health Association, American Water Works Association, Water Environmental Federation. Standard Methods for the Examination of Water and Wastewater, 21 st Edition, September ASTM. Various procedures for analytical methods. TVA. Field Sampling Equipment Cleaning and Decontamination, ENV-TI March 2017 TVA. Field Sampling Quality Control, ENV-TI March TVA. Sample Labeling and Custody, ENV-TI , March TVA. Field Record Keeping, ENV-TI March 2017 TVA. Handling and Shipping of Samples, ENV-TI March TVA. Field Measurement Using a Multi-Parameter Sonde, ENV-TI March US EPA. Contract Laboratory Program National Functional Guidelines for Superfund Organic Methods Data Review, EPA-540-R-08-01, June US EPA. Data Quality Objectives Process for Superfund, Interim Final Guidance, EPA540-R , September US EPA Region 4. Environmental Investigations Standard Operating Procedures and Quality Assurance Manual, November US EPA Region 4. Field ph Measurement, SESDRPOC-100-R3, January US EPA. National Functional Guidelines for Inorganic Data Review, October US EPA. QA Guidance for Sampling and Analysis of Sediments, Water, and Tissues for Dredged Material Evaluations Chemical Evaluations, US EPA. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, 3 rd Edition including Final Update IV, November US EPA. 40 CFR Part 136, Final Methods Update Rule, March

144 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 ATTACHMENT A DATA PACKAGE DELIVERABLE REQUIREMENTS A-1

145 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Required Data Deliverables Elements All Sample Data Packages will include data for analyses of all samples in one sample delivery group (SDG), including field samples, reanalyses, secondary dilutions, blanks, laboratory control samples (LCS), laboratory control sample duplicates (LCSD), matrix spikes (MS), matrix spike duplicates (MSD), and/or laboratory duplicates. A fractionspecific unit is not a required deliverable if the analysis of that fraction was not required for samples in the SDG. The Sample Data Package must be complete before submission and must be consecutively paginated. The Sample Data Package will be arranged in the following order: Cover Letter/Letter of Transmittal signed by Technical Project Manager or designee Title Page Table of Contents SDG Narrative The SDG Narrative will be clearly labeled SDG Narrative and will contain laboratory name; SDG number; TVA sample identifications; laboratory sample numbers; and detailed documentation of any QC, sample, shipment, and/or analytical problems encountered in processing (preparing and analyzing) the samples reported in the data package. A glossary of qualifier codes used in the SDG must also be provided. The laboratory must also include reference to preparation and analytical methods performed and applicable project documents (e.g., approved work plans), any problems encountered, both technical and administrative, corrective actions taken and resolution, and an explanation of all flagged edits (i.e., exhibit edits) on quantitation reports (including results flagged due to storage blank contamination). The SDG Narrative must be signed and dated by the Laboratory Manager or designee. The SDG Narrative must include a statement or statements relative to compliance with this document and any applicable project documents and description of any deviations from these documents: Field and Internal (Laboratory) Chain-of-Custody Records Sample Receipt Documentation Log, and all Project Correspondence Copies of both the external and internal Chain-of-Custody Records for all samples within the SDG must be included in the deliverables. The Chain-of-Custody Records will list all temperature and ph measurements for all samples requiring ph adjustment for preservation. A-2

146 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 A.1 Inorganic and General Chemistry Deliverables Requirements The following subsections provide detailed requirements for the information presented on each of the deliverables elements referenced in Table A-1. In the event that certain required information is not included on a particular form, the laboratory will provide additional documentation (e.g., preparation logs or analytical runlogs) to ensure that the minimum required level of documentation is supplied. A.1.1 Target Analyte Results Summaries Target analyte results summaries are required for all MS/MSD samples, laboratory duplicate samples, LCS/LCSDs, and preparation blanks and will be arranged in increasing alphanumeric order by laboratory sample number. The target analyte results summary must include: SDG Number TVA sample number laboratory sample identifier matrix of the TVA sample date of sample collection sample percent solids (if applicable) name and CAS number for each target analyte concentration or project-required detection limit (PRDL) for each target analyte any applicable flags for target analyte results (e.g., U to designate a not-detected result) concentration units A.1.2 Initial and Continuing Calibration Verification Summary The initial and continuing calibration verification summaries will be arranged in chronological order, by instrument and must include: SDG number names for all target analytes instrument identifier A-3

147 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 start and end dates and times of the analytical sequence true concentrations for all target analytes for the ICV and CCV standards observed concentrations for all target analytes for each ICV and CCV analyses calculated percent recoveries for all target analytes for each ICV and CCV analyses control limits for ICV and CCV percent recoveries concentration units A.1.3 PRDL Standard Summary The PRDL standard summaries will be arranged in chronological order, by instrument and must include the following: SDG number names for all target analytes instrument identifier dates and times for the PRDL standard analyses true concentrations for all target analytes observed concentrations for all target analytes for each PRDL standard analysis calculated percent recoveries for all target analytes for each PRDL standard analysis control limits for PRDL standard recoveries concentration units A.1.4 Initial and Continuing Calibration Blank Summary The initial and continuing calibration blank summaries will be arranged in chronological order, by instrument and must include the following: SDG number A-4

148 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 names for all target analytes instrument identifier start and end dates and times of the analytical sequence observed concentration or PRDL for each target analyte for each initial calibration blank (ICB) or continuing calibration blank (CCB) analysis acceptance limits for ICB and CCB analyses concentration units A.1.5 Preparation Blank Analytical Summary The preparation blank analytical summaries will be arranged in chronological order, by instrument and must include: SDG number preparation blank sample identifier names for all target analytes instrument identifier observed concentration or PRDL for each target analyte acceptance limits concentration units A.1.6 ICP and/or ICP/MS Interference Check Sample Summary The ICP and/or ICP/MS interference check sample summaries will be arranged in chronological order, by instrument and must include: SDG number names for all target analytes instrument identifier dates and times for the ICP interference check standard analyses true concentrations for all target analytes observed concentrations for all target analytes observed in each ICP A-5

149 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 interference check standard analysis calculated percent recoveries for all target analytes for each ICP interference check standard analysis control limits for ICP interference check standard recoveries concentration units A.1.7 Matrix Spike /Matrix Spike Duplicate Summary The MS/MSD summaries will be arranged in alphanumeric order by laboratory sample number and must include: SDG number TVA sample number for the spiked sample percent solids for the TVA sample (if applicable) names for all target analytes analyte concentration observed in the non-spiked sample aliquot true concentrations for all target analytes in the spike solutions observed concentrations for all target analytes in the spike sample/spike sample duplicate analyses calculated percent recoveries for all target analytes control limits for spike sample/spike sample duplicate recoveries calculated RPD between spike sample/spike sample duplicate results RPD limit for each analyte concentration units A.1.8 Post-Digestion Spike Sample Recovery Summary (if applicable) The post-digestion spike sample recovery summaries will be arranged in alphanumeric order by laboratory sample number and must include: SDG number A-6

150 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 TVA sample number for the post-digestion spike parent sample percent solids for the TVA sample (if applicable) names for all target analytes analyte concentration observed in the non-spiked sample aliquot true concentrations for all target analytes in the post-spike solution observed concentrations for all target analytes in the post-spike sample analysis calculated percent recoveries for all target analytes control limits for post-spike sample recoveries concentration units A.1.9 Duplicates Precision Summary The duplicate precision summaries will be arranged in alphanumerical order by TVA sample number and must include: SDG number TVA sample number for the duplicate sample percent solids for the TVA sample (if applicable) names for all target analytes analyte concentration observed in the original sample aliquot observed concentrations for all target analytes in the duplicate sample analysis calculated RPD for all target analytes control limits for RPD concentration units A.1.10 LCS/LCSD Recovery Summary The LCS/LCSD recovery summaries will be arranged in chronological order, by instrument and must include: A-7

151 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 SDG number LCS/LCSD identification number names for all target analytes true concentrations for all target analytes in the LCS/LCSD solution observed concentrations for all target analytes in the LCS/LCSD analysis calculated percent recoveries for all target analytes control limits for LCS/LCSD recoveries concentration units RPD between LCS/LCSD results RPD limit for each analyte A.1.11 Standard Addition Results Summary (where applicable) must include: SDG number TVA sample number for the sample that underwent the standard additions procedure names for all target analytes analyte concentration or absorbance observed in the non-spiked sample aliquot true concentrations for all target analytes for each standard addition analysis observed concentration or absorbance for each standard addition analysis calculated concentration for each target analyte calculated correlation coefficient for each target analyte concentration units A.1.12 ICP and/or ICP/MS Serial Dilution Summary A-8

152 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 The ICP and/or ICP/MS serial dilution summaries will be arranged in alphanumeric order by laboratory sample number and must include: SDG number TVA sample number for the ICP serial dilution sample names for all target analytes analyte concentration observed in the original sample aliquot observed concentrations for all target analytes in the ICP serial dilution analysis calculated RPD for all target analytes control limits for RPD concentration units A.1.13 PRDL and MDL Summary The PRDL and MDL summaries will be arranged in chronological order, by instrument and must include: SDG number instrument identifier date the MDL determination was performed names for all target analytes determined MDL for all target analytes PRDL for all target analytes concentration units A.1.14 ICP Interelement Correction Factors Summary The ICP interelement correction factors summaries will be arranged in chronological order, by instrument and must include: SDG number instrument identifier A-9

153 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 date the ICP interelement correction factors determination was performed names for all target analytes determined ICP interelement correction factors concentrations for all target analytes concentration units A.1.15 ICP and/or ICP/MS Linear Range Summary The ICP and/or ICP/MS linear range summaries will be arranged in chronological order, by instrument and must include: SDG number instrument identifier date the ICP linear range determination was performed names for all target analytes determined ICP linear range concentrations for all target analytes concentration units A.1.16 Preparation Logs TCLP or SPLP Preparation Logs (if TCLP or SPLP extraction was performed) TVA sample and QC sample digestion logs A.1.17 Analytical Sequence Form The analytical sequence forms will be arranged in chronological order, by analyte, by instrument and must include: SDG number instrument identifier TVA sample numbers associated with the sequence QC sample identifiers associated with the sequence A-10

154 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 analysis date and time for each TVA sample and QC sample associated with the sequence identification of all target analytes reported from each TVA sample and QC sample analysis dilution factor for each TVA sample and QC sample analysis start and end dates and times for the sequence A.1.18 ICP/MS Additional Forms ICP/MS Data Packages will include the following forms in addition to the requirements listed above. ICP/MS Tune Summary ICP/MS Internal Standards Relative Intensity Summary A.1.19 Raw Data for Metals/Mercury For each reported value, the laboratory will provide all raw data used to obtain that value. This requirement applies to all required QA/QC measurements and instrument standardization as well as all sample analysis results. This statement does not apply to the Quarterly Verifications Parameters submitted as part of each data package. Raw data must contain all instrument readouts used for the sample results. Each exposure or instrumental reading must be provided, including those readouts that may fall below the PRDL. All ICP, ICP/MS, and AA instruments must provide a legible hardcopy of the direct real-time instrument readout (e.g., strip-charts, printer tapes, etc.). A photocopy of the instrument s direct sequential readout must be included. A hardcopy of the instrument s direct instrument readout for cyanide must be included if the instrumentation has the capability. Raw data must include instrument calibration and calibration curves/equations. A.1.20 Raw Data for General Chemistry Parameters For each reported value, the laboratory will provide all raw data (instrument printouts or logbook pages) used to obtain that value. This requirement applies to all required QA/QC measurements and instrument standardization, as well as all sample analysis results. Raw data must contain all instrument readouts/logbooks pages used for the sample results. Each exposure or A-11

155 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 instrumental reading must be provided, including those readouts/logbook pages that may fall below the quantitation limit. A photocopy of the instrument s direct sequential readout must be included if the instrumentation has the capability. Raw data must include instrument calibration and calibration curves/equations as applicable. Wet Chemistry Preparation Logs (by parameter) A-12

156 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Table A-1: Required Deliverables for Inorganic and General Chemistry Analyses General Section ICP/MS Metals Mercury Chemistry Parameters Cover Letter/Letter of Transmittal n/a X X X Case Narrative n/a X X X Field and Internal (Laboratory) COC n/a X X X Records Sample Receipt Documentation Log n/a X X X Project Correspondence n/a X X X Target Analyte Results Summary A.1.1 X X X ICP/MS Tune Summary A.1.18 F Initial Calibration Summary A.1.19 F F F A.1.20 Initial and Continuing Calibration A.1.2 F F F Verification (ICV/CCV) Summary PRDL Standard Summary A.1.3 F F Initial and Continuing Calibration Blank A.1.4 F F F A Summary Preparation Blank Summary A.1.5 X X X Interference Check Sample Summary A.1.6 F MS/MSD Duplicate Summary A.1.7 X X X A Post-Spike Sample Recovery Summary A.1.8 F F Duplicates Precision Summary A.1.9 X X X LCS/LCSD Recovery Summary A.1.10 X X X ICP and/or ICP/MS Serial Dilution A.1.12 F Summary PRDL and MDL Summary A.1.13 F F F A Standard Additions Summary A.1.11 F A F A ICP Interelement Correction Factors Summary ICP and/or ICP/MS Linear Range Summary ICP/MS Internal Standards Relative Intensity Summary A.1.14 A.1.15 A.1.18 TCLP or SPLP Preparation Logs A.1.16 F A F A Digestion Logs A.1.16 F F General Chemistry Preparation Logs A.1.20 F Analytical Sequence Form A.1.17 F F F Raw Data A.1.19 F F F F F F Notes: X F A Required element for all deliverables Levels Required additional element for full deliverables (in addition to elements required for all deliverables levels) Required element for associated deliverable level when applicable to the analyses performed A.2 Radiological Deliverables Requirements A-13

157 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 The following subsections provide detailed requirements for the information presented on each of the deliverables elements referenced in Table A-2. In the event that certain required information is not included on a particular form, the laboratory will provide additional documentation (e.g., preparation logs or analytical runlogs) to ensure that the minimum required level of documentation is supplied. The radiological data will be arranged in the following order by individual parameter requested for the samples in the SDG. A.2.1 Target Analyte Results Summaries: Target analyte results summaries are required for all samples and will be arranged in increasing alphanumeric order by TVA sample number. The target analyte results summary must include the following: SDG Number TVA sample number laboratory sample identifier matrix of the TVA sample date of sample collection date of sample analysis sample activity, uncertainty, and the sample-specific minimum detectable concentration (MDC). The sample-specific MDC will be based on the background of the detector that the sample was counted on. The sample activity (positive or negative), uncertainty, and sample-specific MDC will be reported for positive and not-detected results any applicable flags for target analyte results (e.g., U to designate a notdetected result) concentration units A.2.2 Chemical Yield (Tracer/Carrier) Recovery Summary that must include the following: SDG number TVA sample number Method blank sample number Laboratory Duplicate sample number LCS identification number A-14

158 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 LCSD identification number (if performed) percent recovery for all tracers/carriers applicable recovery limits for each tracer/carrier A.2.3 Method Blank Summary: The method blank summaries will be arranged in chronological order, by instrument and method and must include the following: SDG number names for all target analytes observed activity, uncertainty, and MDC for each target analyte for each method blank analysis concentration units A.2.4 Duplicates Precision Summary: The duplicate precision summaries will be arranged by instrument and method and must include the following: SDG number TVA sample number for the duplicate sample names for all target analytes analyte activity, uncertainty, and MDC observed in the original sample aliquot observed activity, uncertainty, and MDC for all target analytes in the duplicate sample analysis calculated RPD/Replicate Error Ratio (RER) for all target analytes control limits for RPD/RER concentration units A.2.5 LCS Recovery Summary: The LCS recovery summaries will be arranged by instrument and method and must include the following: SDG number LCS identifier names for all target analytes A-15

159 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 true concentrations for all target analytes in the LCS solution observed concentrations for all target analytes in the LCS analysis calculated percent recoveries for all target analytes control limits for LCS recoveries concentration units A.2.6 Calibration Verification Summary: The calibration verification summaries will be arranged by instrument and method and must include the following: SDG number names for all target analytes instrument identifier date the calibration verification was performed. For each method and analyte, the Contracted Laboratories will provide Calibration Verification summaries that include or bracket the analysis dates of the field and QC samples. acceptance limits for the calibration verification the following calibration verification summaries will be provided for Gas Flow Proportional Counter data a. Efficiency Checks b. Background Checks the following calibration verification summaries will be provided for Alpha Spectroscopy data a. Energy Calibration Checks b. Efficiency Checks c. Background Checks d. Resolution (FWHM) Checks the following calibration verification summaries will be provided for Alpha Scintillation data a. Daily Instrument Performance Checks b. Background Checks A.2.7 Raw Data A-16

160 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 For each reported value, the Contracted Laboratories will provide all raw data (instrument printouts) used to obtain that value. This applies to all required QA/QC measurements (including tracer/carrier recoveries) as well as all sample analysis results. Raw data must contain all instrument readouts and worksheets used for the sample results. An exhibit work sheet per method (including example calculations showing how sample activity, total propagated uncertainty [TPU] and minimum detectable activity [MDA] are calculated) will be provided. A.2.8 Preparation Logs (by method) A.2.9 Traceability Documents (by method) A-17

161 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Table A-2: Required Deliverables for Radiological Analyses Radiological Section Parameters Cover Letter/Letter of Transmittal n/a X Case Narrative n/a X Field and Internal (Laboratory) COC n/a X Records Sample Receipt Documentation Log n/a X Project Correspondence n/a X Target Analyte Results Summary A.2.1 X Chemical Yield (Tracer/Carrier) A.2.2 X Recovery Summary Method Blank Summary A.2.3 X Duplicates Precision Summary A.2.4 X LCS Recovery Summary A.2.5 X Notes: X F Calibration Verification Summary A.2.6 X Preparation Logs A.2.8 X Traceability Documents A.2.9 X Raw Data A.2.7 F Required element for all deliverables levels Required additional element for full deliverables (in addition to elements required for all deliverables levels) A-18

162 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 ATTACHMENT B SAMPLING PROCEDURES LIST B-1

163 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 The TVA Technical Instructions (TIs) and/or standard operating procedures (SOPs) associated with the ALF RI are identified on Table B-1. Current versions of these documents are maintained on TVA s Accellion Workspace. Table B-1: Applicable TIs and SOPs Document Number ENV-TI ENV-TI ENV-TI ENV-TI ENV-TI ENV-TI ENV-TI ENV-TI Document Title Sample Labeling and Custody Field Record Keeping Field Sampling Quality Control Field Sampling Equipment Cleaning and Decontamination Handling and Shipping of Samples Groundwater Sampling Groundwater Level and Well Depth Measurement Field Measurements Using a Multi-Parameter Sonde B-2

164 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 ATTACHMENT C EXAMPLE CHAIN OF CUSTODY RECORD C-1

165 C-2 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017

166 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 ATTACHMENT D SAMPLE NOMENCLATURE D-1

167 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Table A: ALF General Nomenclature TVA Allen Fossil Plant TDEC Order Sample Naming Conventions Table A Site (Plant) Name Site Acronym Sample Type (Matrix) Sample Type Acronym Allen Fossil Plant ALF Soil SS Groundwater GW Location Location ID Soil Boring Number Monitoring Well Number Depth Interval (If Applicable) SBXX Feet/Feet MWXX or Existing MW Name (i.e. ALFXXX) Quality Control/Quality Assurance Sample Type Equipment Rinsate Blank Sample Type Acronym EBXX Year/Month/Day NA Field Blank FBXX Year/Month/Day Date of Sample Example ALF SS SBXX 6.0/ ALF SS EBXX ALF SS FBXX ALF SS DUPXX For MS/MSD note applicable sample on COC ALF GW MWXX ALF GW ALFXXX ALF GW EBXX ALF GW FBXX ALF GW DUPXX ALF GW FLBXX For MS/MSD note applicable sample on COC Matrix Spike/Matrix Spike Duplicate MS/MSD D-2

168 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 ATTACHMENT E INVESTIGATION-SPECIFIC QUALITY CONTROL REQUIREMENTS SOIL SAMPLING E-1

169 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Table E-1. Sample Containers, Mass, Preservation, and Holding Time Requirements Matrix Solid Aqueous Blanks Parameter(s) Metals Mercury Radiological Parameters Anions (Chloride, Fluoride, and Sulfate) ph Metals Mercury Anions (Chloride, Fluoride, and Sulfate) Radiological Parameters Container Type Recommended Sample Mass/Volume Preservation Holding Time 4-oz glass 5 g Cool to < 6 C 180 days 28 days 8-oz glass 20 g Cool to < 6 C 180 days 4-oz glass 250-mL HDPE 5 g 250 ml Cool to < 6 C HNO3 to ph < 2 Cool to < 6 C 28 days NA 180 days 28 days 250-mL HDPE 250 ml Cool to < 6 C 28 days 3 1-L HDPE 3000 ml HNO3 to ph < 2 Cool to < 6 C 180 days Notes: oz - ounce g - grams ml - milliliter L - liter HDPE - High Density Polyethylene NA - Not applicable E-2

170 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Table E-2: Analytes, Methods, and Reporting Limits Solid Matrices Reporting Parameter CAS No. Method Limit 1 Units Antimony SW mg/kg Arsenic SW mg/kg Barium SW mg/kg Beryllium SW mg/kg Boron SW mg/kg Cadmium SW mg/kg Calcium SW mg/kg Chromium SW mg/kg Cobalt SW mg/kg Copper SW mg/kg Lead SW mg/kg Lithium SW mg/kg Magnesium SW mg/kg Mercury SW mg/kg Molybdenum SW mg/kg Nickel SW mg/kg Potassium SW mg/kg Selenium SW mg/kg Silver SW mg/kg Sodium SW mg/kg Thallium SW mg/kg Vanadium SW mg/kg Zinc SW mg/kg Radium EPA pci/g Radium EPA pci/g Radium RA226/228 Calculation 1.0 pci/g Chloride SW mg/kg Fluoride SW mg/kg Sulfate SW mg/kg ph PH SW D 0.1 ph units Modified Notes: CAS No. - Chemical Abstracts Service registry number mg/kg - milligrams per kilogram pci/g - picocuries per gram CALC - Parameter determined by calculation. 1 Samples will be reported on a dry-weight basis; sample-specific reporting limits will vary based on sample mass, dilution factors, and percent moisture. E-3

171 Analyte/ Parameter Group Table E-3: Method Quantitative QA Objectives Soil Samples Surrogate Compound Recoveries/ Chemical Yield (%) Equipment Rinsate Blank, Field Blank, Method Blank LCS Accuracy (% R) MS/MSD Accuracy (% R) LCS/LCSD Precision (RPD) Notes: 1 When both field duplicate results are 5 the RL, the RPD must be < 20%. When at least one result is < 5 the RL, the difference must be < the RL TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 MS/MSD Precision (RPD) Laboratory Duplicate Precision (RPD) Field Duplicate Precision 1 Metals SW NA < RL RPD < 35% difference < 2 the RL Mercury SW NA < RL RPD < 35% difference < 2 the RL Radium-226 EPA < RL NA RER < 2 NA RER < 2 RER < 2 Radium-228 EPA < RL NA RER < 2 NA RER < 2 RER < 2 SW A RPD < 35% Anions NA < RL Modified difference < 2 the RL ph SW D Modified NA ph 6-8 for laboratorysupplied deionized water NA NA NA NA ±0.2 ph units ±0.5 ph units LCS - Laboratory Control Sample LCSD - Laboratory Control Sample Duplicate MS/MSD - Matrix Spike/Matrix Spike Duplicate NA - Not Applicable RPD - Relative Percent Difference RER - Relative Error RL - Reporting Limit %R - Percent Recovery E-4

172 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 ATTACHMENT F INVESTIGATION-SPECIFIC QUALITY CONTROL REQUIREMENTS GROUNDWATER INVESTIGATION SAMPLING F-1

173 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Table F-1. Sample Containers, Mass, Preservation, and Holding Time Requirements Matrix Parameter(s) Metals Mercury Anions (Chloride, Fluoride, and Sulfate) Radiological Parameters Container Type 250-mL HDPE Recommended Sample Mass/Volume Preservation 1 Holding Time 250 ml HNO3 to ph < 2 Cool to < 6 C 180 days 28 days 250-mL HDPE 250 ml Cool to < 6 C 28 days 3 1-L HDPE 3000 ml HNO3 to ph < 2 Cool to < 6 C 180 days Groundwater Arsenic Species 250-mL HDPE 250 ml 2 Total Dissolved Solids (TDS) Alkalinity (Total, Carbonate, and Bicarbonate) ph (laboratory measurement) ph (field measurement) EDTA Cool to < 6 C 28 days 250-mL HDPE 100 ml Cool to < 6 C 7 days 250 ml HDPE 50 ml Cool to < 6 C 14 days 250 ml HDPE 5 ml Cool to < 6 C 24 hours NA NA NA 15 minutes Notes: HDPE - High Density Polyethylene ml - milliliters L - liters NA - Not applicable. 1 Filtered samples requiring chemical preservation will be preserved after field filtration. Dissolved metals parameters analyzed only for samples with stabilized turbidity 5 NTU. 2 Volume for arsenic species will be field-filtered. F-2

174 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Table F-2: Analytes, Methods, and Reporting Limits Groundwater Samples Parameter 1 CAS No. Method Reporting Limit Units Chloride EPA 300.0/ SW Fluoride EPA 300.0/ SW Sulfate EPA 300.0/ SW mg/l 0.10 mg/l 1.00 mg/l Total Dissolved Solids TDS SM2540C 10.0 mg/l ph ph SW ph units ph ph Field Measurement 0.1 ph units Antimony (Total and Dissolved) SW g/l Arsenic (Total and Dissolved) SW g/l Barium (Total and Dissolved) SW g/l Beryllium (Total and Dissolved) SW g/l Boron (Total and Dissolved) SW g/l Cadmium (Total and Dissolved) SW g/l Calcium (Total and Dissolved) SW g/l Chromium (Total and Dissolved) SW g/l Cobalt (Total and Dissolved) SW g/l Copper (Total and Dissolved) SW g/l Lead (Total and Dissolved) SW g/l Lithium (Total and Dissolved) SW g/l Magnesium (Total and Dissolved) SW g/l Mercury (Total and Dissolved) SW g/l Molybdenum (Total and Dissolved) SW g/l Nickel (Total and Dissolved) SW g/l Potassium (Total and Dissolved) SW g/l F-3

175 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Parameter 1 CAS No. Method Reporting Limit Units Selenium (Total and Dissolved) SW g/l Silver (Total and Dissolved) SW g/l Sodium (Total and Dissolved) SW g/l Thallium (Total and Dissolved) SW g/l Vanadium (Total and Dissolved) SW g/l Zinc (Total and Dissolved) SW g/l Radium EPA pci/l Radium EPA pci/l Radium RA226/228 CALC 1 pci/l Alkalinity, Total ALK SM2320B 5.0 mg/l Alkalinity, Carbonate CARB SM2320B 5.0 mg/l Alkalinity, Bicarbonate BICARB SM2320B 5.0 mg/l Arsenic III AS3 Pace SOP S-MN-I-608- rev g/l Arsenic V AS5 Pace SOP S-MN-I-608- rev.01 Dimethylarsinic (DMA) DMA Pace SOP S-MN-I-608- rev.01 Monomethylarsonic (MMA) MMA Pace SOP S-MN-I-608- rev g/l 0.2 g/l 0.2 g/l Notes: CAS No. - Chemical Abstracts Service registry number mg/l - milligrams per liter pci/l - picocuries per liter CALC - Parameter determined by calculation. 1 Dissolved metals parameters analyzed only for samples with stabilized turbidity 5 NTU. F-4

176 TVA Allen Fossil Plant Remedial Investigation Quality Assurance Project Plan Revision 0 September 2017 Table F-3: Quantitative QA Objectives Groundwater Analyte/ Parameter Group Metals (Total and Dissolved) Mercury (Total and Dissolved) Method Surrogate Compound Recoveries/ Chemical Yield (%) Equipment Rinsate Blank, Field Blank, Method Blank LCS Accuracy (% R) MS/MSD Accuracy (% R) LCS/LCSD Precision (RPD) MS/MSD Precision (RPD) Laboratory Duplicate Precision (RPD) SW NA < RL SW NA < RL Total Dissolved Solids SM 2540C NA < RL NA 20 NA 20 Anions (Chloride, Fluoride, Sulfate) ph Alkalinity (Total, Carbonate, and Bicarbonate) EPA 300.0/ SW A Field Measurement or SW NA < RL NA ph 6-8 for laboratorysupplied deionized water NA NA NA NA SM2320B NA < RL ±0.2 ph units Field Duplicate Precision 1 RPD < 20% difference < the RL RPD < 20% difference < the RL RPD < 20% difference < the RL RPD < 20% difference < the RL ph 6-8 for laboratory-supplied deionized water RPD < 20% difference < the RL Radium-226 EPA < RL NA RER < 2 NA RER < 2 RER < 2 Radium-228 EPA < RL NA RER < 2 NA RER < 2 RER < 2 Arsenic Species Pace SOP Pace SOP S-MN-I-608- rev.01 NA < RL RPD < 20% difference < the RL Notes: 1 When both field duplicate results are 5 the RL, the RPD must be < 20%. When at least one result is < 5 the RL, the difference must be < the RL LCS/LCSD - Laboratory Control Sample/Laboratory Control Sample Duplicate MS/MSD - Matrix Spike/Matrix Spike Duplicate RPD - Relative Percent Difference RER - Relative Error RL - Reporting Limit %R - Percent Recovery F-5

177 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Appendix C Site-Specific Health and Safety Plan September 15, 2017 SITE-SPECIFIC HEALTH AND SAFETY PLAN

178 Site-Specific Health and Safety Plan Geotechnical Field Services for Deep Well Installations Allen Fossil Plant Memphis, Shelby County, Tennessee Prepared for: Tennessee Valley Authority Chattanooga, Tennessee Prepared by: Stantec Consulting Services Inc. Nashville, Tennessee July 24, 2017

179 SITE-SPECIFIC HEALTH AND SAFETY PLAN GEOTECHNICAL FIELD SERVICES FOR DEEP WELL INSTALLATION ALLEN FOSSIL PLANT MEMPHIS, SHELBY COUNTY, TENNESSEE Table of Contents 1.0 BACKGROUND/INTRODUCTION PROJECT NAME AND LOCATION PROJECT DESCRIPTION STATEMENT OF STANTEC SAFETY AND HEALTH POLICY STANTEC SAFETY AND HEALTH POLICY REFERENCES RESPONSIBILITIES AND LINES OF AUTHORITY ORGANIZATION STRUCTURE RESPONSIBILITIES OF KEY PERSONNEL SUBCONTRACTORS AND SUPPLIERS COORDINATION WITH ON-SITE TVA PERSONNEL AND/OR SUB- CONTRACTORS TRAINING NEW HIRES MANDATORY AND PERIODIC REFRESHER TRAINING EMERGENCY RESPONSE PLANNING AND TRAINING SAFETY INSPECTIONS ACCIDENT REPORTING EXPOSURE DATA REPORTING INCIDENT REPORTING FORM HOUR NOTIFICATION REQUIREMENT RECORDABLE INJURY REPORTING REQUIRED PLANS/PROGRAMS/PROCEDURES SCOPE OF SERVICES AND SCHEDULE STAFFING PPE REQUIREMENTS MEDICAL AND EMERGENCY PROCEDURES First Aid and Medical Facilities Fire Prevention Severe Weather Medical Treatment Procedures Site Sanitation Procedures Equipment and Material Storage Worksite Delineation Traffic Control Plan Applicable Program Review... 13

180 SITE-SPECIFIC HEALTH AND SAFETY PLAN GEOTECHNICAL FIELD SERVICES FOR DEEP WELL INSTALLATION ALLEN FOSSIL PLANT MEMPHIS, SHELBY COUNTY, TENNESSEE 9.0 ENVIRONMENTAL MANAGEMENT PLAN RISK MANAGEMENT PROCESS LIST OF TABLES TABLE 1 TABLE 2 TABLE 3 LIST OF ATTACHMENTS Project Personnel Emergency Contact List Address of Hospital/Medical Care Facility JHA/AHA Written Plans Field Forms Stantec RMS Forms

181 SITE-SPECIFIC HEALTH AND SAFETY PLAN Background/Introduction July 24, BACKGROUND/INTRODUCTION This Site-Specific Health and Safety Plan (SSHP) contains the health and safety requirements for the drilling and fieldwork portions of the subject project. The SSHP addresses the internal HS&E policies and operating procedures of Stantec Consulting Services Inc. (Stantec). Stantec is performing the work under Contract No PROJECT NAME AND LOCATION The project is titled, Geotechnical Field Services for Deep Well Installations, Allen Fossil Plant. The referenced plant is located near Memphis, Shelby County, Tennessee. 1.2 PROJECT DESCRIPTION The scope of work for this phase will consist of advancing soil borings to facilitate the installation of ten deep monitoring wells at the Allen Fossil Plant. This work will be performed utilizing sonic drilling techniques under the direction of a Stantec geologist / engineer. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 1

182 SITE-SPECIFIC HEALTH AND SAFETY PLAN Statement of Stantec Safety and Health Policy July 24, STATEMENT OF STANTEC SAFETY AND HEALTH POLICY The safety and well-being of our employees and people we come in contact with during the course of our work is paramount to our operations. Stantec is committed to providing and maintaining a healthy and safe workplace and to responsibly manage all of the environmental aspects of its business. Our goal is to complete our work on this site without incidents of all types; no injuries, no work-related illnesses, no impacts to the environment or to property and equipment. In order to achieve this goal, the project team must work together to perform an effective hazard assessment. The team will then establish appropriate precautions and communicate these daily among project staff. Staff will be responsible for communicating changing field conditions to the PM so these conditions and appropriate precautions may be re-evaluated as needed. Staff should implement Stop Work Authority at any time they believe that conditions may be inherently unsafe or might cause damage to property or harm to the environment. Staff may refuse to participate in work they believe will be unsafe. If such conditions exist, staff must communicate immediately with the PM to resolve the situation. We expect all subcontractors and project personnel to share this goal. 2.1 STANTEC SAFETY AND HEALTH POLICY Through Stantec s Health, Safety and Environmental (HSE) program, the Company strives to: Identify, assess and manage the health, safety, and environmental hazards and risks to which its employees are exposed Minimize the environmental aspects and impacts associated with the services and products it provides Help its employees develop an awareness and understanding of the health, safety, and environmental issues related to their work Work collaboratively with employees to achieve health, safety, and environmental objectives Comply with legislation, regulations, and appropriate industry standards Monitor and enhance the health, safety and environmental practices through inspections, audits, reviews, investigations, corrective actions, and behavior-based processes Provide a framework which supports the continuous improvement of the program 2.2 REFERENCES TVA Standard, TVA-SPP , Rev Title 29 CFR 1910 OSHA Safety and Health Regulations for General Industry wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 1

183 SITE-SPECIFIC HEALTH AND SAFETY PLAN Statement of Stantec Safety and Health Policy July 24, 2017 Title 29 CFR 1926 OSHA Safety and Health Regulations for Construction wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 2

184 SITE-SPECIFIC HEALTH AND SAFETY PLAN Responsibilities and Lines of Authority July 24, RESPONSIBILITIES AND LINES OF AUTHORITY 3.1 ORGANIZATION STRUCTURE Designated project personnel as well as their title and contact information are identified in the following table. Table 1. Project Personnel Title Personnel Office No./Cellular No. TVA Points of Contact (POC) Stantec Project Manager (PM) Stantec Regional Safety and Environmental Coordinator (RSEC) Stantec Site Representative & Site Health and Safety Officer; Competent Person Cedric Adams R&QA Manager Danny Stephens Sr. Program Manager Michael Baker TVA Construction Manager Jerry Roepke TVA Health and Safety Kimberly Kesler-Arnold John McInnes Tony Speer Briggs Evans Cassidy Sutherland (o) (c) (o) (c) (o) (c) (o) (c) (o) (c) (o) (c) (c) (c) wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 3

185 SITE-SPECIFIC HEALTH AND SAFETY PLAN Responsibilities and Lines of Authority July 24, RESPONSIBILITIES OF KEY PERSONNEL All employees with respect to the services they provide on behalf of Stantec are responsible and accountable for Stantec s health, safety, and environmental performance. In addition, all employees are expected to understand and comply with the practices in Stantec s Health, Safety and Environment (HSE) program as a condition of employment. No employee will be required to perform any task requiring specialized training and/or fitness testing without having met the corresponding requirements. The PM has the primary responsibility for implementing this SSHP. This includes completion of the initial job hazard analysis/activity hazard analysis (JHA/AHA) (see Attachment A) at the beginning of the project; identifying and obtaining any special environment and safety equipment required to execute a project; ensuring workers are trained to use appropriate equipment; ensuring that competent workers are assigned to each project or task; reviewing and signing worksite inspection reports; ensuring that daily safety meetings are held covering relevant topics for each day s work; allocating adequate funds to implement this SSHP; and providing proper notification to client representatives, Stantec management, and regulatory authorities as required in the event of an injury, property damage or release incident. Kimberly Kesler-Arnold is the PM for this project and John McInnes will serve as alternate project manager in Kimberly s absence. The Site Health and Safety Officer (SHSO) will be responsible for developing and submitting the JHA/AHA addressing all site-specific hazards for the project. The SHSO has overall responsibility of the safety and health issues for this project. Specifically, the SHSO has the authority to stop field activities if the safety and health of personnel are endangered and to allow restart of operations after safety and health concerns have been addressed. This person is an authorized officer/employee to act on behalf of Stantec for this contract and provides technical insight and supervision for the project. The SHSO has overall responsibility to see that all work is performed safely and in accordance with the provisions of this SSHP. The SHSO or an approved designated representative shall be on-site at all times when work is being performed. The SHSOs for this project are Cassidy Sutherland and Briggs Evans. Ms. Sutherland has the 40-hour HAZWOPER and 10-hour OSHA Construction training. Mr. Evans has the OSHA 30-hour Construction Supervisor training and the 40-hour HAZWOPER. Stantec s Regional Safety and Environmental Coordinator (RSEC), Tony Speer, will provide technical oversight and review of special hazards and situations that may arise that are outside of the normal scope of the project. Specific to this Purchase Order all work will be performed in accordance with Stantec s Health, Safety and Environmental (HSE) program and in compliance with TVA s Safety Manual. No work shall be performed unless a designated competent person is present on the job site. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 4

186 SITE-SPECIFIC HEALTH AND SAFETY PLAN Subcontractors and Suppliers July 24, SUBCONTRACTORS AND SUPPLIERS Subcontractor personnel involved in the project will work under the direct supervision of Stantec, will follow this SSHP requirements, will have appropriate clearances to be on TVA sites, and will receive the necessary training required for the work to be performed on the site. Suppliers who may be making deliveries on-site will coordinate their deliveries with a designated Stantec representative. They will not be exposed to the potential hazards of the jobsite and therefore have not been included in the review and approval process of the SSHP. No subcontractor will be allowed onto the worksite without TVA having been provided with appropriate notification and the subcontractor having received adequate training and orientation. 4.1 COORDINATION WITH ON-SITE TVA PERSONNEL AND/OR SUB- CONTRACTORS The Stantec SHSO Representative will coordinate work activities with on-site TVA personnel and with other on-site contractors/suppliers, when required, to ensure the safety of all employees working on the jobsite. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 5

187 SITE-SPECIFIC HEALTH AND SAFETY PLAN Training July 24, TRAINING All employees have or will have received the required training to comply with applicable OSHA and TVA specialized training requirements for tasks occurring within the scope of this project prior to their performing work on the site. Stantec will submit any required training records to TVA prior to an employee working on the project site. Employees have been briefed on Stantec and TVA Stop Work Authority Policy and the use of the Two-Minute rule card along with the other Human Performance Tools. A copy of the Stop Work Authority is included in Attachment B. A copy of the Two-Minute rule card is included in Attachment C along with the other Human Performance Tools. 5.1 NEW HIRES Each Stantec newly hired employee is given a copy of the Stantec HSE manual for review and completes an orientation questionnaire on the application of the HSE program based on their level of employment with Stantec before going into the field. 5.2 MANDATORY AND PERIODIC REFRESHER TRAINING Existing employees receive the appropriate training mandated by the particular standard that is applicable to the work being performed prior to performing the work and receive the necessary periodic refresher training to maintain those certifications. These certificates are on file and available for review if needed. Stantec field personnel are trained in the use of fire extinguishers, personal protective equipment and in operation of field equipment to be used on this project. Training dates are maintained by each employee s office safety coordinator for easy tracking of due dates for refresher training. Supervisors are also included in refresher training as required. 5.3 EMERGENCY RESPONSE PLANNING AND TRAINING An emergency response plan that identifies phone numbers for key contacts and emergency services is included in Attachment B of this SSHP. This information has been placed in the HASP for quick reference and will be covered during the initial project kickoff meeting with all project participants. Maps to the nearest hospital and to the nearest occupational health clinic with directions are included with the emergency information in Attachment B of this SSHP. The designated SHSO is required to conduct daily pre-job safety meetings prior to beginning work for the day. All employees, subcontractors and visitors will be required to attend and participate in pre-job meetings. A copy of this plan will remain on-site while work is being performed. The Emergency Evacuation Procedures are included in Attachment B of this SSHP. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 6

188 SITE-SPECIFIC HEALTH AND SAFETY PLAN Training July 24, 2017 Table 2. Emergency Contact List Emergency Service Phone Agency Michael Baker (c) ALF Construction Manager Hospital Methodist South Hospital Medical Care Southern Family Medical Clinic Ambulance 911 / Medicone Medical Response Fire 911 / Memphis Fire Department Police 911 / Memphis Police Department Table 3. Address of Hospital/Medical Care Facility Hospital Address Methodist South Hospital 1300 Wesley Drive Memphis, Tennessee (901) Medical Care Address Southern Family Medical Clinic 324 W. Mallory Avenue Memphis, Tennessee (901) wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 7

189 SITE-SPECIFIC HEALTH AND SAFETY PLAN Safety Inspections July 24, SAFETY INSPECTIONS Prior to mobilizing to the site, the PM and SHSO shall complete the Stantec RMS 1 Risk Management Strategy form to identify hazards and risks associated with the project. The completed form is found in Attachment D of this SSHP. All employees performing work on this project will review and sign the RMS 1 form. Prior to commencing work, the equipment operators will perform safety inspections of the equipment to be used for the project. Subsequent equipment inspections will be performed on a daily basis. Inspections will be documented on the Drill Rig Inspection Form included in Attachment C. The SHSO will review the results of inspections and will report deficiencies to the PM. A daily safety meeting will also be conducted by the SHSO every morning with the entire field crew, and the crew will sign-off on the TVA Form Generation Construction (Projects and Civil Construction Coal Combustion Products) Pre-Job Brief form. Copies of the forms and checklists to be used are included in Attachment C. Prior to performing any work, employees shall review the Stantec s JHA/AHA (Attachment A) and review and sign a Two-Minute Rule card (Attachment C). The SHSO and designated representatives shall also perform inspections of operations, and activities on a weekly basis during the project. Inspection deficiencies will be logged on the Stantec RMS 12 form (Attachment D) for tracking of corrective actions to address deficiencies. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 8

190 SITE-SPECIFIC HEALTH AND SAFETY PLAN Accident Reporting July 24, ACCIDENT REPORTING If there is any type of emergency (injury, spill, etc.), work is to be shut down until the situation that caused the emergency is corrected, proper notifications are made and approval received from the TVA Construction Manager or their on-site safety representative, for work to resume without further risk of a similar incident. ALL INCIDENTS regardless of severity and all near misses shall be reported IMMEDIATELY, (after stabilizing the victim(s)/site), to the Stantec PM and the TVA Construction Manager or their on-site representative. The Emergency Response Plan located in Attachment B should be followed to determine the proper course of action. The Stantec Incident Reporting matrix, which contains the contact numbers for the Stantec Regional Safety and Environmental Coordinators, is also included in Attachment B. 7.1 EXPOSURE DATA REPORTING The Stantec PM is responsible for reporting the exposure data (man-hours worked - including subcontractors) and the number of injuries/incidents on a regular basis to TVA. 7.2 INCIDENT REPORTING FORM Stantec utilizes a standard form, RMS 3, for incident reporting that simplifies the process for recording and communicating information about an incident, near miss, or loss. This form is used for recommending and implementing corrective actions that will reduce the chances of recurrence on this site and other sites with similar hazards. The reporting process is not complete until all corrective actions have been implemented and signed off by the PM. The form is located in Attachment D of this SSHP HOUR NOTIFICATION REQUIREMENT All near misses or minor property damage incidents must be reported immediately, after the site and/or personnel have been stabilized, to the PM, TVA Construction Manager, and SHSO to allow proper reporting within 24 hours to the TVA Health and Safety Representative. TVA may need to be completed and submitted to TVA. The referenced form may be found in Attachment D of this SSHP. 7.4 RECORDABLE INJURY REPORTING The Stantec PM will be responsible for notifying Stantec s RSEC and TVA within 24 hours of any injury incident. An Accident Investigation Team (AIT) will be initiated within 24 hours of an injury incident to investigate the incident. Stantec shall thoroughly investigate the accident and submit the findings of the investigation along with appropriate corrective actions to TVA within thirty (30) days of the accident. Corrective actions shall be implemented as soon as reasonably possible wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 9

191 SITE-SPECIFIC HEALTH AND SAFETY PLAN Accident Reporting July 24, 2017 after the accident. The following situations require immediate notification to all parties including OSHA: A fatal injury; A permanent total disability; A permanent partial disability; The hospitalization of three or more people resulting from a single occurrence; or Any TVA Vehicle or Property damage. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 10

192 SITE-SPECIFIC HEALTH AND SAFETY PLAN Required Plans/Programs/Procedures July 24, REQUIRED PLANS/PROGRAMS/PROCEDURES A task specific JHA/AHA has been prepared for this work order and are included as Attachment A. The JHA/AHA may be updated as needed prior to or during fieldwork based on the scope of work and site conditions. Safety Data Sheets (SDS) for various chemicals and products to be used on-site is kept in a binder with on-site personnel. 8.1 SCOPE OF SERVICES AND SCHEDULE The services required under this Purchase Order will consist of soil boring advancement and well installation activities, including well development, aquifer slug testing and groundwater sampling. The drilling will be performed by Cascade Drilling, with supervision being provided by a Stantec geotechnical engineer or geologist. Field personnel will follow the safety procedures outlined in the SSHP for drilling and sampling. Stantec proposes to work 10 hours per day in 10-day on/4-day off work cycles, beginning Tuesday, July 25. Stantec estimates the fieldwork will take approximately four to five weeks to complete. 8.2 STAFFING Stantec will provide engineers or geologists to log the boreholes, perform sample handling/management during the drilling process, and document the installations. The Stantec inspectors will be appropriately trained to serve as the SHSO designees and will follow the requirements of this SSHP. 8.3 PPE REQUIREMENTS Field employees will be required to wear protective headgear (Class C), steel-toed shoes, and safety glasses with side shields at all times when working on the project site. Clothing shall be longlegged trousers (no shorts) and sleeved shirts (no tank tops). Clothing will be appropriate to weather conditions. Hearing protection will be required during operation of equipment such as drill rigs, pumps and when using powered hand tools. Approved gloves are required when operating equipment, lifting or handling materials and when otherwise specified. 8.4 MEDICAL AND EMERGENCY PROCEDURES First Aid and Medical Facilities Stantec s field personnel will be qualified in First Aid and CPR. Each field crew will be equipped with a first aid kit. The first aid kit will be maintained to replace expended supplies. The first aid kit will be stored in a weatherproof container and be kept in a readily accessible location. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 11

193 SITE-SPECIFIC HEALTH AND SAFETY PLAN Required Plans/Programs/Procedures July 24, 2017 A vehicle will be available at all times to provide emergency transportation to local medical care facilities when an ambulance is not readily available, except for potential back/neck spinal injuries. Only EMT personnel and equipped vehicles should conduct transport for potential back/neck spinal injuries. Emergency telephone numbers and reporting instructions for local ambulance, hospital, rescue, fire and police will be available at the work site. Employees will be made aware of the location of the nearest medical care facility and the nearest ambulance service. A portable cellular telephone will be maintained on-site during the work Fire Prevention Field personnel will have received prior training in the use of fire extinguishers. At least one Class ABC fire extinguisher will be available while on-site. Stantec field vehicles are required to have a fire extinguisher on board Severe Weather Local weather forecasts and advisories will be monitored for severe weather alerts. Operations will be assessed on a site-specific basis. In the event of other adverse weather conditions such as heavy rainfall, extreme heat, electrical storms and limited visibility, the SHSO or designee will determine if work can safely continue. For electrical storms, work will immediately be suspended by the designated representative of the SHSO and will not resume until 30 minutes has elapsed since the last show of lightning Medical Treatment Procedures Site personnel will assist the injured or ill person until medical assistance arrives. First aid will be administered while awaiting an ambulance or paramedics. All injuries and illnesses will be reported immediately to the SHSO or the designated SHSO who will report the injury to Stantec s PM as soon as the situation is stabilized. The SHSO or designated SHSO must accompany any injured employee if transported to a medical facility. If work is to continue in the absence of the SHSO, the SHSO s responsibility must be temporarily delegated to another competent employee Site Sanitation Procedures Site personnel will utilize portable sanitary facilities which exist on the site. If site facilities are not available, Stantec will have portable toilets delivered to the site Equipment and Material Storage Site personnel will coordinate with TVA plant and construction personnel to determine a safe and acceptable area to store additional drilling equipment and consumable materials while Stantec is operating at the facility. Particular attention will be given to: Minimizing interference with daily facility activities; wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 12

194 SITE-SPECIFIC HEALTH AND SAFETY PLAN Required Plans/Programs/Procedures July 24, 2017 Maintaining facility and equipment/material security Worksite Delineation Stantec personnel will use a combination of safety cones, wooden stakes and caution tape to delineate the work zone and reduce public access as necessary Traffic Control Plan If necessary, Site personnel will coordinate with TVA plant and construction personnel to determine a safe and acceptable traffic control plan Applicable Program Review The following programs and procedures are included with this plan where applicable: Emergency response plans (Section 5.3, Attachment B); Posting of emergency numbers (Attachment B); and Medical support (Section 8.4, Attachment B); Emergency Evacuation Procedures (Attachment B) Site sanitation plan (Section 8.4.5, Attachment B); Fire prevention plan (Section 8.4.2); Contingency plan for severe weather (Section 8.4.3); Site-specific fall protection and prevention plan (Not applicable); Others as required. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 13

195 SITE-SPECIFIC HEALTH AND SAFETY PLAN Environmental Management Plan July 24, ENVIRONMENTAL MANAGEMENT PLAN TVA on-site personnel will designate a suitable disposal area of investigative derived waste (IDW). wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 14

196 SITE-SPECIFIC HEALTH AND SAFETY PLAN Risk Management Process July 24, RISK MANAGEMENT PROCESS Detailed project-specific hazards and controls are contained in the JHA/AHA included in Attachment A. Appropriate forms for use with the Stantec risk management process are included in Attachment D of this SSHP. wb v:\1826\administration\admin\jwm\tva\final ri work plan\final\appendices\app_c_hasp\alf_sshp_deep wells.docx 15

197 SITE-SPECIFIC HEALTH AND SAFETY PLAN Attachment A JHA/AHA July 24, 2017 ATTACHMENT A JHA/AHA

198 Drilling Job Hazard Analysis Page 1 TO BE REVIEWED PRIOR TO MOBILIZATION BY PROJECT TEAM MEMBERS. FOR QUESTIONS SEE BRIGGS EVANS OR CASSIDY SUTHERLAND. FINAL COPIES TO WORK FILE, PROJECT MANAGER, DRILL CREW, AND FIELD SUPERVISOR 1. Project Summary: The field work will include the installation of 10 deep wells, including well development, aquifer testing, and sampling. Project Number: TBD Location: Allen Fossil Plant, Memphis, TN Site Conditions Locations are anticipated to be drive-on using a truck-mounted or track-mounted drill rig from existing access drives. Scope of Work : Installation, Development, Testing and Sampling of monitoring wells 2. Point of Contact for Client: Client Contacts Name Title Office No./Cell No. Danny Stephens Primary Contact Michael Baker CCPM Construction Manager (o) / (c) Jerry Roepke TVA Health and Safety (o) / (c) 3. Point of Contact at Stantec (include all Stantec team members' work number, cell number and home phone numbers): Stantec Contacts Name Title Office No. Cell No. Kimberly Kesler-Arnold, CPG Project Manager John McInnes, LPG Project Manager Cassidy Southerland, PG Site Contact - SSHO Briggs Evans, PG Site Contact - SSHO Emergency Management : 4.1. Emergency Telephone Numbers A cell phone will be on-site at all times. Emergency contact numbers are given below: Emergency Telephone Numbers Contact Phone Number Hospital Medical Clinic Ambulance 911 / Fire 911 / Police 911 / \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

199 Drilling Job Hazard Analysis Page Route to Medical Clinic - For Routine Injuries or Health Issues : Southern Family Medical Clinic 324 W Mallory Ave, Memphis, TN 38109, United States TVA Allen Fossil Plant 2574 Plant Road, Memphis, TN 38109, United States Head east on Plant Rd toward Buoy St (0.6 mi) Turn Left onto Paul R Lowry Rd (4.3 mi) Turn left onto W Mallory Ave (112 ft) Destination on Right 324 West Mallory Avenue, Memphis, TN 38109, United States \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

200 Drilling Job Hazard Analysis Page Hospital - For Major/Significant Injuries. Methodist South Hospital 1300 Wesley Dr, Memphis, TN 38116, United States TVA Allen Fossile Plant 2574 Plant Road, Memphis, TN 38109, United States Head east on Plant Rd toward Buoy St. 1 min (0.6 mi) Take W Mitchell Rd and W Rains Rd to Wesley Dr 17 min (8.9 mi) Turn right onto Wesley Dr 20 s (194 ft) Methodist South Hospital 1300 Wesley Drive, Memphis, TN 38116, United States \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

201 Drilling Job Hazard Analysis Page 4 5. Drilling Activity Hazard Analysis Work Activity 1. Travel to Site / Drill Location Potential Hazard Action to Eliminate or Minimize Hazard 1a. Narrow Road Possible travel off of roadway leading to immobile vehicle or overturning vehicle 1b. Muddy and/or Slick Road Possible travel off of roadway leading to immobile vehicle or overturning vehicle 1c. Uneven Surface (slope) Ground surface slides out from beneath vehicle, causing overturning of vehicle Assess if roadway is wide enough for safe travel, maintain safe speed and maintain vision of edges of roadway during travel on roadway Assess if roadway is safe to travel and maintain a safe speed while traveling roadway Assess if slope is stable enough for travel and maintain a safe speed while traveling on slope 1d. Driving Traffic Observe speed limit, be observant, eyes on path, look for change in conditions 2. Rig Setup 2a. Inspection Slipping/falling while atop drill rig Only stand/walk on proper and level surfaces 2b. Offloading Tooling Heavy lifting Use two people to lift heavy items and use proper lifting techniques adhere to 50lb. per person lifting limit, and use proper ergonomics lift w/knees Slippery tools 2c. Leveling Drill Rig Crushing point between hydraulic jack(s) and ground Clean tool before handling them, stay out of line of fire Be sure area beneath hydraulic jack(s) is clear before lowering, stay out of line of fire \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

202 Drilling Job Hazard Analysis Page 5 2d. Raising Mast Overhead obstructions Check that space above drill rig is clear of any obstructions to drill mast Unsecured wench cables Hydraulic line breaks Be sure that wench cables do not swing freely or release slack while raising drill mast Helper and driller watch lines and immediately discontinue operation is a leak is noticed. Plastic shall be placed below drill rig setup. Spill kits shall be on-site 2e. Setting Up Rig on Slope Boring Sloping Ground/Uneven Ground Check the slope and ground conditions of the area prior to moving equipment into the area to assess and be prepared for how the equipment will handle in such conditions. Overturning of the equipment while moving to location on slope Drill rigs will be cabled to a wrecker while moving on the embankment slopes and being set in position for drilling. The drill crew, project engineer, and wrecker operator shall meet and discuss the procedures prior to every drill rig movement using the assistance of a wrecker. The operator shall use spotters to assist in equipment moves. The involved parties will be very clear on the use of hand signals during the movement of the drill. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

203 Drilling Job Hazard Analysis Page 6 2e. Setting Up Rig on Slope Boring Overturning of the equipment while advancing boring on slope Drill rigs will be leveled with timber cribbing. Personnel shall check that all cribbing is firm and properly secured before the weight of the drill is transferred to the cribbing. The drill shall be positioned approximately parallel to the slope and oriented where the cab of the drill is on the uphill side and that no personnel are located downhill of the drill. Once the drill is cribbed, the operator should slowly raise the mast watching the cribbing for any shifting or movement. 3. Augering/Sonic Drilling 3a. Lifting augers/casing from rack Heavy lifting Adhere to the 50 lb. per person load limit. Use 2 men to lift auger/casing unless wench cable is used on one end. When wench is used, adhere to proper rigging practices. Lift all heavy loads with knees. Ensure that there is a clear, flat, non-slippery path from the rack to the back of the rig. Pinch points between augers in the rack Wear gloves at all times. Use proper ergonomics and adhere to the 50 lb. per person load limit. Use caution and stay clear of unbalanced augers/casing on the rack. 3b. Connecting New Auger/Casing Heavy lifting Use two people to lift heavy items and use proper lifting ergonomics. Adhere to 50 lb. per person load limit. Pinch point when connecting augers/casing to one another Raking of knuckles while tightening auger bolts Be sure hands/fingers are clear before connecting. Wear gloves at all times. Use proper tool and force to tighten auger bolts. 3c. Advancing Augers/Casing Auger bolt(s) break(s) Use correct size and non-defective auger bolts and use proper drill speed and down pressure. Inspect auger bolts at the beginning of each day. Inspect joints on casing for thread wear. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

204 Drilling Job Hazard Analysis Page 7 3c. Advancing Augers/Casing Auger/Casing shatters Use proper drill speed and down pressure 3d. Pulling, removing, and replacing augers/casing on racks 4. Sampling 4a. Standard Penetration Testing Assembling drilling rods and splitspoon sampler Auger/Casing flight(s) break/crack Hydraulic hose/fitting bursts Auger/casing hoist breaks Disconnecting augers/casing Carrying auger back to rack Heavy lifting Pinch point when connecting drilling rods to one another Pinch point when connecting sub to split-spoon sampler Use proper drill speed and down pressure Use proper drill speed and down pressure. If a leak is detected, immediately stop operation. Inspect chains and hoists before each use. Ensure good pin connection. Use proper rigging practices. Use proper techniques and equipment to disconnect sections. See 3.a. Use two people to lift heavy items and use proper ergonomics. Adhere to 50lb. per person load limit. Be sure hands/fingers are clear before connecting. Wear gloves at all times. Be sure hands/fingers are clear before connecting. Wear gloves at all times. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

205 Drilling Job Hazard Analysis Page 8 4a. Standard Penetration Testing Assembling drilling rods and splitspoon sampler 4b. Standard Penetration Testing Engaging automatic hammer 4c. Standard Penetration Test Disassembling drilling rods 4d. Standard Penetration Test - Removing, disassembling, and re-assembling split spoon 5. Mud Rotary / Roller Bit 5a. Inspect that drill bit teeth and upflow guides are in place and good condition Pinch point when connecting splitspoon sampler and sub to drilling rods. Crushing point when lowering automatic hammer onto drilling rods Crushing point when SPT test is in progress Water/mud in drilling rods spraying drill operator/helper while disconnecting drill rods Cable breaking during hoisting/lowering of drilling rods Threads of drilling rods/sub breaking during hoisting/lowering of rods Heavy Lifting Metal burrs on split spoon Pinch point when splitting spoon If drive shoe is stuck, using ball-peen hammer to break the bite. Potential pinch points when swinging hammer Sharp edges Be sure hands/fingers are clear before connecting. Be sure hands/fingers are clear before lowering automatic hammer Stay clear of hammer drop when SPT test is in progress. Do not approach automatic hammer until driller has fully disengaged it Slowly disconnect rods to allow water/mud to safely release from rods. Wear eye protection at all times. Be sure cable(s) are free from defects and that strength restrictions of cable are not exceeded. Use proper rigging practices. Be sure threads are in good condition on rods before using them. Use proper rigging practices. See 4.a. Wear gloves while handling Keep fingers clear of pinch point areas. Wear gloves at all times. Keep fingers clear of hammer swing. Hammer only on sturdy surface. Wear gloves and handle with caution 5b. Connect drill bit to drilling rods Pinch point between drill bit and drill rods Be sure hands/fingers are clear before connecting 5c. Connect drilling rod with drill bit to hoisting plug secured to wench Pinch point between hoisting plug and drill rods Be sure hands/fingers are clear before connecting \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

206 Drilling Job Hazard Analysis Page 9 cable 5d. Lower drilling rod with drill bit into hole 5e. Use rod catcher to secure rods and prevent rods from slipping down into boring hole 5f. Repeat steps 3-5 with additional sections of drilling rods to desired depth Threads of drilling rods/hoisting plug breaking Wench cable breaking Pinch point between clamp of rod catcher and drilling rods See above Be sure threads are in good condition on rods/hoisting plug before utilizing them for use Be sure cable(s) are free from defects and that strength restrictions of cable are not exceeded Be sure hands/fingers are clear before connecting See above 5g. Connect drilling rods to drill head Pinch point between drill head and drilling rods Be sure hands/fingers are clear before connecting 5h. Turn on pump to begin circulation of drilling fluid 5i. Apply rotation and down force of drill head and rods to desired depth 5j. Turn off pump to cease circulation of drilling fluid, disconnect drill rods from drill head and connect hoisting plug to drill rods and raise drill rods Hose bursting and spraying drill operator/helper Spinning rods Pinch point between hoisting plug and drilling rod Wear safety glasses Keep objects clear of moving parts Be sure hands/fingers are clear before connecting \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

207 Drilling Job Hazard Analysis Page 10 5j. Turn off pump to cease circulation of drilling fluid, disconnect drill rods from drill head and connect hoisting plug to drill rods and raise drill rods 5k. Secure drill rods with rod catcher to remove sections of drill rods Threads of drilling rods/hoisting plug breaking Wench cable breaking Pinch point between clamp of rod catcher and drilling rods Threads of drilling rods/hoisting plug breaking Wench cable breaking Be sure threads are in good condition on rods/hoisting plug before utilizing them Be sure cable(s) are free from defects and that strength restrictions of cable are not exceeded Be sure hands/fingers are clear before connecting Be sure threads are in good condition on rods/hoisting plug before utilizing them Be sure cable(s) are free from defects and that strength restrictions of cable are not exceeded 6. Installing Casing 6a. Installing Casing Lifting casing from trailer or racks on rig 6b. Installing Casing - Assembling casing pieces Drilling fluid in drilling rods spraying drill operator/helper while disconnecting drill rods Heavy lifting Walking with casing. Pinch point when connecting casing pieces to on another Wear safety glasses and slowly disconnect rods to allow drilling fluid to safely release from rods Use two people to lift heavy items and use proper ergonomics. Adhere to 50 lb. per person load limit. Ensure a clear path between casing lay-down location and back of drill rig. Watch for potential slips, trips, and falls. Be sure hands/fingers are clear before connecting \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

208 Drilling Job Hazard Analysis Page 11 6c. Installing Casing Lowering casing into place using wench cables Cable breaking during hoisting/lowering of casing Be sure cable(s) are free from defects and that strength restrictions of cable are not exceeded. Use proper rigging practices. 6d. Installing Casing Hoisting casing back out of boring when complete Threads of casing/sub breaking during hoisting/lowering of casing Heavy lifting Walking with casing Cable breaking during hoisting/lowering of casing Be sure threads are in good condition on casing/sub before utilizing them for use See 6.a. See 6.a. Be sure cable(s) are free from defects and that strength restrictions of cable are not exceeded. Use proper rigging practices. Threads of casing/sub breaking during hoisting/lowering of casing Be sure threads are in good condition on casing/sub before utilizing them for use 7. Well Installation Heavy lifting Use two people to lift heavy items and use proper lifting techniques Pinch point when connecting instrumentation pipe pieces to one another Be sure hands/fingers are clear before connecting 8. Water Hauling Fire Hydrant Pressure Use supplied equipment to turn on fire hydrant, check fitting and values before use Backing up truck and trailer Hauling heavy load Use spotter to help driver Eyes on road, seat belts \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

209 Drilling Job Hazard Analysis Page 12 General Job Hazards 1. Moving the drill rig on uneven or muddy surfaces 1. Overturning of the vehicle or loss of control of the vehicle 1. All drivers shall check the conditions of the area prior to driving the vehicle into the area. The slopes and ground conditions shall be assessed so that the driver can be prepared for how the vehicle will handle in such conditions. 2. Heat stress/cold stress exposure 2. Heat stroke or frost bite, hypothermia 2. Monitor all personnel for signs of fatigue, dizziness or other physical abnormalities. Personnel should wear clothing suited of the weather conditions and breaks shall be given for intake of fluids, etc. 3. Underground Utilities 3. Electrocution, explosion and fire 3. Contact the local utility authorities in advance of drilling activities so that utilities near boring locations can be identified. 4. Overhead Utilities 4. Electrocution, explosion and fire 4. Prior to raising rig mast the area shall be inspected by the supervisor or driller for overhead utilities that may interfere with the drilling operations. The rig mast shall not be set up closer than 50 feet from a voltage source unless the line can be deenergized or isolated from all sources of voltage. The rig shall not be moved with the mast in the up position. 5. Heavy Equipment 5. Physical injury to personnel 5. All heavy equipment operators shall be properly trained in operating the specific piece of equipment. The operator shall be responsible for checking the equipment on a daily basis for any necessary repairs. Support personnel shall also be trained on working around \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

210 Drilling Job Hazard Analysis Page 13 heavy equipment. All personnel shall remain alert while working around heavy equipment. 6. Drill Rig Operation 6. Physical injury to personnel 6. In addition to any training requirements, all personnel shall be required to wear appropriate protective equipment as listed above and in the Health and Safety Plan. 7. Site Maintenance (House Keeping) 7. Slip, trip and fall 7. The drill area shall be maintained in a neat and orderly fashion including clear drill rod paths. The ground surface shall be maintained in order to minimize mud and other slick materials from accumulating. Hoist cables and cathead ropes shall be kept in order and not laid in an area where a tripping hazard is imminent. Wastes generated on site shall be disposed of according to federal, state and local requirements. 8. Augering 8. Pinch points 8. Workers shall check all drilling tools for proper operation prior to use and/or on a daily basis. Workers shall keep hands and fingers from the bottom of drilling tools such as augers and drill rods. Augers shall not be cleaned while in rotation. Workers shall use hoists for lifting drilling tools whenever possible. 9. Noise 9. Damage to hearing 9. Workers shall wear hearing protection when operating or working near heavy equipment. 10. Lifting Equipment 10. Back injury, strained muscles 10. Workers shall use proper lifting techniques which picking up equipment. Proper techniques shall include keeping the back \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

211 Drilling Job Hazard Analysis Page 14 straight while lifting and utilizing the leg muscles. Workers shall use machinery to pick up heavy loads and not attempt to pick up by themselves. 11. Refueling Equipment 11. Explosion, splashing, fire 11. All equipment shall be turned off while refueling. A funnel or approved dispenser in manner to itemize plashing hazards. Absolutely NO SMOKING shall be allowed during a fueling operation. Use of metal safety cans. 12. Grouting 12. Chemical Burns 12. Workers shall use caution to minimize skin contact and breathing of cement dust. In the event that contact cannot be avoided, protective clothing and dust filtering respirator shall be used. 5. Additional Site-Specific Activity Hazards (Include each job step, potential hazard, and action to eliminate or reduce hazard helpful link: Work Activity Potential Hazard 14. Wear PPE 14. Failure to wear proper PPE can result in easily avoidable injury to personnel. Action to Eliminate or Minimize Hazard 14. Wear PPE at all times where required. Inspect PPE at the beginning of each day and at the end of each break. 15. Working around heavy machinery 15. Failure of operator to see employee on the ground 15. Wear proper PPE, including reflective safety vest when working on or around heavy or rotating equipment. 16. Refueling 16. Spill 16. Set-up spill containment at every equipment set-up location. Use metal safety cans. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

212 Drilling Job Hazard Analysis Page Use of on-site porta-toilet facilities 17. Biological hazard, slips, trips, falls 17. Use proper hygiene after using porta-toilet. Ensure that footing is stable on potentially wet, slippery surface. 18. Open Excavation 18. Slip, trip, fall and potential trap for personnel. 18. Open excavation will never be left unattended or overnight. Personnel, materials, and equipment will not be permitted within two (2) feet from the edge of the excavation. All personnel will not be permitted to enter the excavation unless OSHA requirements have been established. 19. Uneven footing, sloped ground 19. Slip, trip, fall Wear appropriate footwear and clothing. Take diligent care while walking, taking photos, taking notes, traversing the sites. 2. Be alert and observe terrain while walking to minimize slips and falls 3. Personnel shall avoid climbing over site debris or equipment. 4. When possible, personnel shall avoid walking through or working in water or mud. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

213 Drilling Job Hazard Analysis Page Walking on/accessing riprap 20. Slip, trip, fall 20. Wear appropriate footwear and clothing to include steel-toed boots (with ankle support) and leather gloves. Take diligent care while walking, taking photos, taking notes and surveying. Directly access the point of interest, achieve objective and return using same path. Do not attempt to traverse riprapped slopes. Access to adjacent benches should be accomplished by using existing walking paths, not across the riprapped slopes. When possible, use a walking staff or survey rod to provide 3 points of contact. Maintain visual contact with a second person, implementing a buddy system. Additional Notes for Mitigating Potential Site Hazards: 1. First aid kits shall be maintained at each work site location. 2. A minimum of 1 each 2-A fire extinguisher shall be located with each vehicle and on each drill rig. 3. Any incidents shall be reported immediately to the Project Manager using Stantec forms. The Project Manager will report to TVA on appropriate TVA forms. 4. All crew members will have first aid and CPR training. 5. The ESHO and designated representatives will have completed a 30-hour OSHA Construction Worker Training. 6. MSDS for on-site materials are provided and kept at the work site. 7. This JHA shall be reviewed and be maintained at the work site as part of the site specific Health and Safety Plan (HASP) 8. A daily tool-box (or pre-job brief) safety meeting shall be completed each morning and before any changes in the work plan. Post-job briefs shall be conducted at the end of each work day and prior to leaving the site. 9. Site inspection forms and daily equipment/drill rig inspections shall be maintained on site for at least one week before transferring to the project file. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix a\appendix a_jha - alf.docx Rev. 09/08

214 SITE-SPECIFIC HEALTH AND SAFETY PLAN Attachment B Written Plans July 24, 2017 ATTACHMENT B WRITTEN PLANS

215 Emergency Response Plan Deep Well Installations Allen Fossil Plant Page 1 TO BE REVIEWED PRIOR TO MOBILIZATION BY PROJECT TEAM MEMBERS. FOR QUESTIONS SEE KIMBERLY KESLER-ARNOLD OR JOHN MCINNES. FINAL COPIES TO WORK FILE, PROJECT MANAGER, DRILL CREW, FIELD SUPERVISOR, JOHN BEAM AND/OR TONY SPEER. 1. Project Summary (brief description of project scope): The field work will include the installation of 10 deep wells, including well development, aquifer testing, and sampling. Project Number: TBD Location: Allen Fossil Plant, Memphis, TN Site Conditions (wooded, grass-covered, steep terrain, etc.): Locations are anticipated to be drive-on using a truck-mounted or track-mounted drill rig from existing access drives. 2. Point of Contact for Client (include name, title, phone number, cell number, , etc.): Client Contacts Name Title Office No./Cell No. Danny Stephens Primary Contact Michael Baker CCPM Construction Manager (o) / (c) Jerry Roepke TVA Health and Safety (o) / (c) 3. Point of Contact at Stantec (include all Stantec team members' work, and cell / home phone numbers): Stantec Contacts (A cell phone will be on-site at all times) Name Title Office No. Cell No. Kimberly Kesler-Arnold, CPG Project Manager John McInnes, LPG Project Manager Cassidy Southerland, PG Site Contact - SSHO Briggs Evans, PG Site Contact - SSHO Emergency Management 4.1. Emergency Telephone Numbers A cell phone will be on-site at all times. For additional information see the HSE Emergency Contact and Critical Care Information in Attachment B of the SSHP. Emergency Telephone Numbers Emer. Service Phone Agency Hospital Methodist South Hospital Medical Care Southern Family Medical Clinic Ambulance 911 / Medicone Medical Response Fire 911 / Memphis Fire Department Police 911 / Memphis Police Department \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix b\attachment b1_emergency response plan - alf.docx

216 Emergency Response Plan Deep Well Installations Allen Fossil Plant Page 2 If there is any type of emergency (injury, spill, etc.), work is to be shut down until the situation that caused the emergency is corrected, proper notifications are made and approval received for work to resume without further risk of a similar incident. ALL INCIDENTS regardless of severity and all near misses shall be reported IMMEDIATELY, (after stabilizing the victim(s)/site), to the Stantec Project Manager. If the Project Manager is unavailable, Keith Kuhlmann, Regional Safety and Environmental Coordinator (RSEC) US South will be contacted. Once the incident has been reported, The Project Manager together with Keith Kuhlmann (or Fred Miller if he is not available) shall then communicate with the client Project Manager in accordance with the client s incident reporting guidelines. Client and Stantec incident reporting guidelines are contained in this document. The Site Safety & Health Officer (SSHO) must be familiar with the directions to the hospital given in Appendix A and B3. (It has become common to take directions off the Internet. In some cases these directions are no longer correct. It is the SSHO's or the designee s responsibility to ensure that the directions stated are absolutely accurate. It may be advisable to ask the client or call a local institution for directions. The SSHO or designee should then verify and validate the route to the hospital by driving it before work begins.) Injury or Illness If an injury or illness occurs, take the following action: Determine if emergency response (fire/ambulance) staff is necessary. If so, dial 911 on cell phone or closest available phone. Provide the location of the injured person and other details as requested. If it makes sense to take an individual to the hospital, follow the directions on the HSE Emergency Contact and Critical Care Information document. Get First Aid for the person immediately. Utilize first aid kit in vehicle. Also utilize the bloodborne pathogens kit. (Make sure you have both kits, or one combined kit). Notify the SSHO immediately. The SSHO is responsible for contacting the Stantec Project Manager immediately after stabilizing the victim(s)/site. The Stantec Project Manager shall then immediately contact Keith Kuhlmann, Regional Safety and Environmental Coordinator (RSEC) US South. The Stantec Project Manager along with the SSHO, and the Office Safety & Environment Coordinator (OSEC) or Lead Safety and Environmental Coordinator (LSEC) (and other witnesses, experts, etc.) are responsible for preparing and submitting the Incident/Near Miss Investigation Report. The client shall be notified in accordance with the client s reporting procedures and timelines by the Stantec Project Manager (or other Stantec representative per client reporting procedures). Use the Incident Investigation / Near Miss Investigation Report included with this document. The SSHO will assume responsibility during a medical emergency until more qualified emergency response personnel arrive at the site. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix b\attachment b1_emergency response plan - alf.docx

217 Emergency Response Plan Deep Well Installations Allen Fossil Plant Page 3 First Aid Procedures for Minor Cuts, Scratches, Bruises, etc. Each occupational illness or injury shall be reported immediately by employees to the SSHO. The SSHO will complete the Incident Investigation / Near Miss Investigation Report included with this document and report the incident to Stantec s Practice Risk Management group. Medical Cases Not Requiring Ambulance Service Medical cases normally not requiring ambulance services are injuries such as minor lacerations, minor sprains, etc. The SSHO will ensure prompt transportation of the injured person to a physician or hospital following the directions listed below. A representative of Stantec /sub-contractor should always drive the injured employee to the medical facility and remain at the facility until the employee is ready to return. If the driver of the vehicle is not familiar with directions to the hospital, a second person shall accompany the driver and the injured employee and navigate the route to the hospital following the directions listed below. If it is necessary for the SSHO to accompany the injured employee, provisions must be made to have another employee, properly trained and certified in first aid, to act as the temporary SSHO. If the injured employee is able to return to the jobsite the same day, he/she should bring with him/her a statement from the doctor containing such information as: Date Employee's name Diagnosis Date he/she is able to return to work, regular or light duty Date he/she is to return to doctor for follow-up appointment, if necessary Signature and address of doctor If the injured employee is unable to return to the jobsite the same day, the employee who transported him should bring this information back to the jobsite and report it to the Regional Safety and Environmental Coordinator (RSEC) US Southeast, Keith Kuhlmann at (740) and to the employee s supervisor. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix b\attachment b1_emergency response plan - alf.docx

218 Emergency Response Plan Deep Well Installations Allen Fossil Plant Page 4 Emergency Cases Requiring Ambulance Services Medical cases requiring ambulance services would be such cases as severe head, back, neck, and spinal injuries, amputations, heart attacks, heat stroke and any other life threatening injuries. Should ambulance service be necessary, the following procedures should be taken immediately: Contact necessary ambulance service and company emergency services by dialing 911 and notify the SSHO for the site. Administer first aid until ambulance service arrives. While the injured employee is being transported, the SSHO should contact the medical facility to be utilized. One designated representative should accompany the injured employee to the medical facility and remain at the facility until final diagnosis and other relevant information is obtained. Death of an Individual or Hospitalization of Three or More Employees The procedure as outlined in "First Aid and Medical Cases", above, should be followed. If the injured person dies, then Human Resources Department, local officials and coroner must be notified immediately. The RSEC will notify the local OSHA office within 8 hours of the incident or fatality in the event of fatality or hospitalization of three or more employees. Response to Spills or Cut Lines Prevent problems by documenting the location of underground lines (e.g., product, sewer, telephone, fiber optic) before starting site work. If a line or tank is drilled through, or another leak occurs, document the event as soon as possible using the Incident Investigation Report attached. Notification of the event must be made to the Stantec Project Manager by the SSHO immediately after stabilizing the site. The Stantec Project Manager shall then immediately contact Health Safety & Environment (HSE) Department. Include dates, times, actions taken, agreements reached, and names of people involved. Use additional pieces of paper to document the event completely. The SSHO and the PM must be notified immediately. The PM will notify the client and the regulatory authorities and/or utility as necessary. In the event of a spill/release, follow this plan: 1. Stay upwind of the spill/release. 2. Wear appropriate PPE. 3. Turn off equipment and other sources of ignition. 4. Turn off pumps and shut valves to stop the flow/leak. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix b\attachment b1_emergency response plan - alf.docx

219 Emergency Response Plan Deep Well Installations Allen Fossil Plant Page 5 5. Plug the leak or collect drippings, when possible. 6. Use sorbent pads to collect product and impede its flow, if possible. 7. Call Fire Department immediately if fire or emergency develops. 8. Inform Stantec Project Manager about the situation. 9. Determine if the client wants Stantec to repair the damage or if the client will use an emergency repair contractor. 10. Advise the client of spill discharge notification requirements and determine who will complete and submit forms. (Do not submit or report to agencies without the client s consent.) Document each interaction with the client and regulators and note, in writing; name, title, authorizations, refusals, decisions, and commitments to any action. 11. Do not transport or approve transportation of contaminated soils or product until proper manifests have been completed and approved. Be aware that soils / product may meet criteria for hazardous waste. 12. Do not sign manifests as generator of wastes; contact PM or Waste Compliance Manager to discuss waste transportation. Notifications A spill/release requires completion of an RMS 3 Incident Report Form. The incident shall be reported immediately after stabilizing the victim(s)/site. The PM must involve the client/generator in the Incident Investigation process. The client/generator is under obligation to report to the proper government agencies. If the spill extends into waterways, the Coast Guard and the National Response Center (800) must be notified immediately by the client or by Stantec PM with the client s permission. All spills/releases must be reported per site/client requirements per procedures listed in the Stantec Incident Reporting Procedure All spills/releases must be reported to TVA. Phone number included in Table above. Emergency Decontamination Procedures Ensure eyewash bottle, water (unless the chemicals of concern are water reactive), and other decontamination aids are available on-site. In the event of emergency decontamination: Secure area or move/evacuate to the emergency gathering location. Immediately remove any contaminated PPE or clothing (gloves, etc.) If possible, wash contaminated area with mild soap and water. Use eyewash station if necessary. Observe the contaminated area. Repeat washing as necessary. Notify SSHO immediately. Exposure to contaminated individuals should be limited to personnel wearing the proper PPE to avoid unnecessary exposure. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix b\attachment b1_emergency response plan - alf.docx

220 Emergency Response Plan Deep Well Installations Allen Fossil Plant Page 6 CONTRACTOR EMERGENCY ACTION PLAN The SSHO will ensure that the Subcontractor/Contractor is capable of efficient evacuation/emergency response in the event of an emergency. Subcontractor/Contractor's employees will be trained by their employer in site-specific evacuation/emergency procedures, including alarm systems and evacuation plans and routes. The Subcontractor/Contractor shall instruct its employees that in the event of an emergency such as a fire, release, or accident involving injuries, they are required to dial 911. The reporting employee is to state the problem clearly and fully and remain on the line until dismissed by the operator. Stantec staff and Subcontractor/Contractors working in an area where an emergency exists shall evacuate to a safe location, preferably upwind, away from the area and take attendance. The gathering location will be determined by the Stantec SSHO upon arrival on-site. It is the responsibility of the SSHO to annotate the Site Plan with the gathering location position and to disseminate that info to all site personnel during the Daily Production Safety Meeting and any other appropriate time after that. (If the emergency causes the route to a gate surrounding the site to be closed, the Stantec staff and Subcontractor/Contractors shall move to an open area upwind of the hazard area, and remain there until instructed by emergency response personnel (i.e., police, fire, ambulance, paramedics, etc.) to do otherwise.) Subcontractor/Contractor has the responsibility to account for its own employees and to provide such information immediately to emergency response personnel upon request. Stantec staff and Subcontractor/Contractor may not reenter the emergency site without specific approval from emergency response personnel. In the event of fire ignition in close proximity to Stantec staff and Subcontractor/Contractor's employees, those persons shall evacuate the area and notify emergency personnel unless the fire is readily extinguished with portable dry chemical equipment on-hand. When in doubt, emergency response personnel shall be notified. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix b\attachment b1_emergency response plan - alf.docx

221 Emergency Evacuation Procedures Deep Well Installations Allen Fossil Plant Page 1 TO BE REVIEWED PRIOR TO MOBILIZATION BY PROJECT TEAM MEMBERS. FOR QUESTIONS SEE BRIGGS EVANS OR CASSIDY SUTHERLAND. FINAL COPIES TO WORK FILE, PROJECT MANAGER, DRILL CREW, AND FIELD SUPERVISOR. 1. Project Summary (brief description of project scope): The field work will include the installation of 10 deep wells, including well development, aquifer testing, and sampling.. Project Number: TBD Location: Allen Fossil Plant, Memphis, TN Site Conditions (wooded, grass-covered, steep terrain, etc.): Locations are anticipated to be drive-on using a truck-mounted drill rig from existing access drives. In the event the job site must be evacuated, it shall be done in such a way as to inform all on-site personnel to evacuate the project in a safe and timely manner. If there is any type of site emergency (site alarm, severe weather, etc.) the SSHO will communicate with TVA Site Manager or Shift Operations Supervisor and/or decide if a site evacuation is necessary. EMERGENCY EVACUATION PLAN In the event of an on-site emergency, incoming inclement weather, bomb threat or fire, or other emergency requiring evacuation, the following will be performed: 1. TVA Safety or TVA Site Manager shall make notification. The evacuation notice will be a verbal notification to key personnel. Key personnel will communicate to all site personnel. 2. Notification and Communication: will be made to TVA by phone or radio, at which point TVA will be responsible for making the necessary 911 call to contact the necessary entities such as Police, Fire, or other Emergency Response units. 3. All equipment will be turned off and visual inspection of the site will occur (providing safe access is available). Verification will be made that all trailers, restrooms, and buildings have been evacuated of all personnel to the pre designated assembly areas. 4. Stantec staff and Subcontractor / Contractors working in an area where an emergency exists shall evacuate to a safe location, away from the area and take attendance. The assembly area will be determined by the Stantec SSHO/designee upon arrival onsite. It is the responsibility of the SSHO/designee to annotate the Site Plan with the assembly area position and to disseminate that info to all site personnel during the Daily Production Safety Meeting and any other appropriate time after that. The visitor guidelines for assembly areas for each site shall be determined upon site arrival. 5. Accountability: Once personnel are assembled, it is the responsibility of each contractor to submit a complete head count to the TVA Site Manager or TVA EHS Coordinator. This count shall be turned over as quickly as possible. 6. Everyone shall remain in the assembly areas until it is determined that the emergency is over. At that time a member of TVA Management shall give the all clear communication. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix b\attachment b2_emergency evacuation procedures - alf.docx

222 Emergency Evacuation Procedures Deep Well Installations Allen Fossil Plant Page 2 The SSHO will ensure that the Subcontractor/Contractor is capable of efficient evacuation / emergency response in the event of an emergency. Subcontractor / Contractor's employees will be trained by their employer in site-specific evacuation/emergency procedures, including alarm systems and evacuation plans and routes. (If the emergency causes the route to a gate surrounding the site to be closed, the Stantec staff and Subcontractor / Contractors shall move to an open area away from the emergency, and remain there until instructed by emergency response personnel (i.e., police, fire, ambulance, paramedics, etc.) to do otherwise.) Subcontractor/Contractor has the responsibility to account for its own employees and to provide such information immediately to emergency response personnel upon request. Stantec staff and Subcontractor/Contractor may not re-enter the emergency site without specific approval from the emergency response personnel in charge. In the event of fire ignition in close proximity to Stantec staff and Subcontractor / Contractor's employees, those persons shall evacuate the area and notify emergency personnel unless the fire is readily extinguished with portable dry chemical equipment on-hand. When in doubt, emergency response personnel shall be notified. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix b\attachment b2_emergency evacuation procedures - alf.docx

223 Police 911 / Hospital/Critical Care Facility Methodist South Hospital 1300 Wesley Dr, Memphis, TN 38116, United States Grassmere Park Road Nashville, Tennessee Phone: (615) Fax: (615) HSE Emergency Contact and Critical Care Information Project Information Project Number / Project Description/Location/Extents: Project Name The field work will include the installation of 10 deep wells, including well development, aquifer testing, and sampling. ALF Deep Well Installation City Memphis County Shelby State Tennessee Stantec Contact Information Role: Personnel: Office Number: Cell Number: Project Manager Kim Kesler-Arnold (248) (248) kimberly.kesler-arnold@stantec.com Asst Project Mgr. John McInnes (317) (317) john.mcinnes@stantec.com RSEC Tony Speer (615) (615) tony.speer@stantec.com SSHO SSHO Briggs Evans Cassidy Sutherland (615) (615) (615) (615) briggs.evans@stantec.com Emergency Contact Information Emer. Service Phone Number Ambulance 911 / In case of emergency, Fire 911 / always attempt to call 911 Agency Medicone Medical Response Memphis Fire Department Memphis Police Department \\us1229-f01\shared_projects\tva_eip_deep_wells\work Plan - SSHP\SSHP\Appendix B\Attachment B3_HSE Contact 1 of and 3Critical Care Information Form - ALF.xlsx 8/17/2017

224 Directions to Hospital/Critical Care Facility TVA Allen Fossil Plant 2574 Plant Road, Memphis, TN 38109, United States Head east on Plant Rd toward Buoy St. 1 min (0.6 mi) Take W Mitchell Rd and W Rains Rd to Wesley Dr 17 min (8.9 mi) Turn right onto Wesley Dr 20 s (194 ft) Methodist South Hospital 1300 Wesley Drive, Memphis, TN 38116, United States \\us1229-f01\shared_projects\tva_eip_deep_wells\work Plan - SSHP\SSHP\Appendix B\Attachment B3_HSE Contact 2 of and 3Critical Care Information Form - ALF.xlsx 8/17/2017

225 Non-Emergency Care Facility Southern Family Medical Clinic 324 W Mallory Ave, Memphis, TN 38109, United States Directions to Non-Emergency Care Facility TVA Allen Fossil Plant 2574 Plant Road, Memphis, TN 38109, United States Head east on Plant Rd toward Buoy St (0.6 mi) Turn Left onto Paul R Lowry Rd (4.3 mi) Turn left onto W Mallory Ave (112 ft) Destination on Right 324 West Mallory Avenue, Memphis, TN 38109, United States \\us1229-f01\shared_projects\tva_eip_deep_wells\work Plan - SSHP\SSHP\Appendix B\Attachment B3_HSE Contact 3 of and 3Critical Care Information Form - ALF.xlsx 8/17/2017

226 JANUARY 2015 ALL INCIDENTS MUST BE REPORTED IMMEDIATELY When an incident occurs, the first priority is to control the situation by caring for people and stabilizing the environment. Only then can communication, assessment, and investigation safely begin. All employees are to report any incident to their SUPERVISOR immediately (ideally within the first hour). This includes injury, near miss, damage, spill, etc. When an injury or serious incident occurs, the supervisor will contact the OSEC, LSEC, and RSEC immediately. Additionally for injury and regardless of severity, inform the workers compensation claims coordinator. Landline Cell RSEC - Canada East (Ontario/Quebec) Jim Elkins RSEC - Canada East (Atlantic Canada) Neil Clements RSEC - Canada Prairies & Mountain Yvonne Beattie RSEC US South & Midwest Keith Kuhlmann RSEC US Northeast & Mid-Atlantic Fred Miller RSEC - US West Clint Reuter RSEC - International Kev Metcalfe HSE Director, HSE Operations (interim) Carol Ferguson- Scott Your OSEC or LSEC Master HSE Representative Listing Employees with general medical questions regarding symptoms and care options may speak to a medical professional at AllOne Health (24-hour service): WC Claims Region Cell Coordinator Landline US (All Regions) Melissa Helton Canada (All Regions) Rebecca Brown When you report an incident, work with your supervisor and your OSEC to complete the incident report. The RMS3 Incident Report is available on StanNet and must be completed by the supervisor and submitted to the OSEC for every incident. Stantec HSE Bulletin 1

227 STOP WORK AUTHORITY Stantec believes that no work performed by its employees is so urgent that it can t be done safely. As a Stantec employee, you are responsible and authorized to STOP work immediately if you become aware of an unsafe act or condition that could place anyone in danger, or if you are not confident in the work plan. Leadership supports the decision of its employees in the diligent execution of this practice: Stop work immediately if: o o you see an unsafe action, behavior, omission or non-action of any party potentially leading to injury or damage; or work to be performed is not in accordance with the approved RMS1, Job Hazards/Safety Analysis (JHA/JSA), and/or Health and Safety Plan. Any person regardless of position or seniority has the right and duty to stop work, if in their opinion an activity is deemed to be unsafe On a multi-contractor job site where Stantec does not have authority over others, the client and/or prime contractor shall be immediately notified of the unsafe condition so that they can take prompt action. Stantec employees are always empowered and obligated to stop our own work on a site whenever it is unsafe to proceed. There shall be no blame or fault on any employee who follows this process and stops work or notifies others to stop work in good faith, even if, upon investigation, the work stoppage was deemed unnecessary. Work that has ceased due to a Stop Work order shall not be resumed until all safety aspects are cleared to the satisfaction of the employee who initiated the Stop Work order or his/her supervisor. Stantec is committed to attaining and maintaining an incident free and safe working environment and will continue to implement programs designed to achieve continued excellence towards the protection of health, safety and the environment. Robert J. Gomes President & CEO, Stantec

228 Site Sanitation Deep Well Installation Allen Fossil Plant Page 1 TO BE REVIEWED PRIOR TO MOBILIZATION BY PROJECT TEAM MEMBERS. FOR QUESTIONS SEE BRIGGS EVANS OR CASSIDY SUTHERLAND. FINAL COPIES TO WORK FILE, PROJECT MANAGER, DRILL CREW, AND FIELD SUPERVISOR 1. Project Summary (brief description of project scope): The field work will include the installation of 10 deep wells, including well development, aquifer testing, and sampling.. Project Number: TBD Location: Allen Fossil Plant, Memphis, TN Site Conditions (wooded, grass-covered, steep terrain, etc.): Locations are anticipated to be drive-on using a truck-mounted drill rig from existing access drives. 2. Sanitation Facilities Site personnel will utilize portable sanitary facilities which exist on-site. If facilities are not available, Stantec will have portable facilities delivered to the site. 3. Potable Water Stantec field crews will have coolers with potable drinking water with each drilling support truck. Stantec will also have access to a potable water source on site. 4. Investigative Derived Waste Disposal of drill cutting and fluids along with other generated waste shall be placed in designated areas as instructed by on-site TVA personnel. \\us1229-f01\shared_projects\tva_eip_deep_wells\work plan - sshp\sshp\appendix b\attachment b5_site sanitation - alf.docx

229 STOP WORK AUTHORITY Stantec believes that no work performed by its employees is so urgent that it can t be done safely. As a Stantec employee, you are responsible and authorized to STOP work immediately if you become aware of an unsafe act or condition that could place anyone in danger, or if you are not confident in the work plan. Leadership supports the decision of its employees in the diligent execution of this practice: Stop work immediately if: o o you see an unsafe action, behavior, omission or non-action of any party potentially leading to injury or damage; or work to be performed is not in accordance with the approved RMS1, Job Hazards/Safety Analysis (JHA/JSA), and/or Health and Safety Plan. Any person regardless of position or seniority has the right and duty to stop work, if in their opinion an activity is deemed to be unsafe On a multi-contractor job site where Stantec does not have authority over others, the client and/or prime contractor shall be immediately notified of the unsafe condition so that they can take prompt action. Stantec employees are always empowered and obligated to stop our own work on a site whenever it is unsafe to proceed. There shall be no blame or fault on any employee who follows this process and stops work or notifies others to stop work in good faith, even if, upon investigation, the work stoppage was deemed unnecessary. Work that has ceased due to a Stop Work order shall not be resumed until all safety aspects are cleared to the satisfaction of the employee who initiated the Stop Work order or his/her supervisor. Stantec is committed to attaining and maintaining an incident free and safe working environment and will continue to implement programs designed to achieve continued excellence towards the protection of health, safety and the environment. Robert J. Gomes President & CEO, Stantec

230 SITE-SPECIFIC HEALTH AND SAFETY PLAN Attachment C Field Forms July 24, 2017 ATTACHMENT C FIELD FORMS

231 Drill Rig Inspection Date Inspector Rig # Rig Type Company Oversight Drill Rig/Support Equipment Yes No N/A Repaired Are there obvious hose/connection leaks on rig? Any 1. Hoses in contact with other parts where wear is evident or could be as they move? 2. Are hydraulic system safety shut offs in proper condition? 3. Are hand tools and power tools maintained in good repair? Is there evidence of wearing or grooving of cathead to a 4. depth greater than 1/8, indicating replacement required? Are casing hammer cables, shackles, and hammer rails in 5. safe condition? Are air and water hoses/connections in good repair; whip 6. checks installed properly? 7. Is pumping equipment properly secured to rig? 8. Are pump pressure regulators set at approved PSI rating? 9. Is welding equipment properly secured to rig? 10. Are oxygen & acetylene bottles properly stored & labeled? Are welding torches (gas) equipped with anti-flashback 11. check valve between bottle regulator & torch manifold? Are compressed air tanks regularly purged of excess 12. moisture accumulation (air brakes)? Are fossil fuels and flammable solvents stored/dispensed 13. from approved safety cans? Properly labeled? MSDS? Are discharge hoses on dual type percussion rig properly 14. restrained/barricaded against striking personnel? 15. Is Haz Mat spill control kit available/well stocked? Are proper number and kinds of outrigger pads, blocking, 16. cribbing on hand? Are kill switches operating? 17a. Initials of person who tested switches: 17b. Indicate how to activate kill switch. Rigging/Material Handling Equipment Is all material handling equipment used and maintained in accordance with 29 CFR and/or manufacturers 18. recommendations? Rigging hardware per TVA Rigging Standard? Has all hoisting equipment been completely inspected for 19. broken wires, crushing, bird-caging, or other damage? Do all wire ropes have sufficient rated capacity for the 20. hoisting equipment used and the lifts being performed? Correctly installed number of wire rope clamps in use & 21. installed? 22. Is a thimble installed in all hoisting eyes? 23. Do hooks have approved safety latch installed?

232 Drill Rig/Support Equipment Yes No N/A Repaired 24. Does hook rating match rated tonnage of winch? 25. List hoisting equipment inspected: Serial Number Description Protective Systems/Equipment 26. Are all guards, etc. in place around pinch points, moving machinery etc. and in good repair? 27. Are mechanical pinch points on drilling rig properly labeled/color coded? 28. Is there adequate fall protection equipment available if climbing the mast is necessary? 29. If derrick platform is more than 4 ft. above grade, is it equipped with safety railing and toe boards as required? 30. Are signs stating caution/danger shock or electrocution hazard in place on the mast? 31. Is there a possibility for exhaust fumes from the drilling rig to accumulate and affect worker s health? 32. Is adequate lighting, in accordance with NFPA , installed for night operations? 33. Are all workers wearing proper hard hats, safety boots, and safety glasses? 34. Are there an adequate number of fire extinguishers, portable eye wash(es), and first aid kit(s) on site? Programs/Plans 35. Are assured grounding procedures for equipment and power tools being followed? 36. Are drillers following a code of safe practices developed by the contractor? 37. Is there a safe procedure in place for guiding drill rods or pipe sections into racks or onto transport vehicle? 38. Is a certified CPR/First Aid trained individual with the rig? 39. Hearing protection levels verified with recent documentation? = = = = Comments:

233 Turn in to Site Manager or Safety Department at end of day or completion of task. The PJB shall be completed daily and for each high hazard task. PJBs shall be completed when the scope of work changes or when a new task has been assigned. Plant/Site: TVA: Plant/Site: Foreman: Contractor: Person conducting the PJB: Date: Location of Task: Task Description: Does this task require special training? Yes No If yes, what type? General Information/Considerations/Reminders 1. Is there a work package for this task? Do you have the necessary drawings, procedures or verbal instruction to proceed? 2. Should a safety professional be involved in the planning of this job? 3. Do you have materials staged or available and the proper tools in good working order to complete the work? 4. Does everyone have the training/qualifications to perform the work? 5. Verify safe working standards for all work. 6. Are you conducting routine or non-routine tasks? Nonroutine tasks require more planning / awareness. Do you have a contingency plan? 7. Take two extra minutes when arriving at the work area/look for changes/items that impact your work. 8. YOU ARE AUTHORIZED AND RESPONSIBLE FOR STOPPING AT-RISK WORK FOR SAFETY, HEALTH, OR ENVIRONMENTAL REASONS. 9. Has a JSA been completed/reviewed for this task? Yes No N/A 10. Observe the Two Minute Rule before starting work. TVA [10-??-2012] Generation Construction [Projects and Civil Construction / Coal Combustion Products] PRE-JOB BRIEF (PJB) A check mark below indicates the item applies to this work activity and precautions were discussed during this PJB or was not applicable to the job. Trucks and Heavy Equipment 11. Equipment inspection check lists on all required equipment. Yes N/A Points of contact used for climbing on/off equipment. Yes N/A 13. All personnel wearing bright colored safety vest. Yes N/A 14 Trucks required to back long distances. Yes N/A 15. Flag/Signal person required for this job. Yes No 16. Control of vehicle and pedestrian traffic patterns. Yes N/A 17. Personnel clear of equipment swing radius; eye contact w/operator before approaching equipment. Yes N/A 18. Crane operations near overhead power lines. Yes N/A Terrain Stability 19. Dikes/dams/embankments evaluated for stability for heavy equipment and analysis complete. Yes N/A 20. Personnel prohibited from walking on ash/gypsum ponds. Yes N/A Trenching & Excavation Work 21. All personnel entering a trench or excavation trained. Yes N/A 22. A trained Competent Person is available to inspect and approve entry. Yes N/A 23. Barricade and safe access maintained. Yes N/A Material Handling lb manual lifting limit; obtain if needed; use equipment instead of heavy manual lifting; eyes on path when carrying; one hand free for handrails on steps/stairs; load swing path clear; softeners used for sharp edges. Yes N/A Environmental 25. Are you working near waters of the U.S.? Yes N/A 26. Have you completed the environmental checklist form TVA for project startup? Yes N/A Personal Protective Equipment (PPE) 27. PPE selected, inspected and available (hand, eye, head, foot, hearing, PFD). Yes N/A Rigging 28. Rigging plan developed. Yes N/A 29. Personnel performing rigging are trained. Yes N/A Person-In-Charge of rigging: Housekeeping 30. Housekeeping maintained safe / acceptable in the work area; all flammable/combustible materials properly stored and proper containment around storage area. Yes N/A Hazardous Materials 31. The work activity has potential to expose employees to the hazards of lead, asbestos, arsenic, cadmium or other hazardous substances or materials. Yes N/A 32. Requirements for training, sampling, monitoring, PPE. Yes N/A Emergency Planning 33. List below the location of the nearest fire extinguisher, spill kits, communications source, emergency phone number(s), and assembly area. Yes N/A Applicable Permits 34. Hot Work Yes No Clearance Yes No Excavation Yes No Signs/Barricades Yes No Confined Space Yes No Crane Lift Yes No Scaffolds Yes No Other: Yes No Additional Comment & Precautions Discussed

234 Signature Pre-job Briefing Participants Printed Name Generation Construction [Projects and Civil Construction / Coal Combustion Products] PRE-JOB BRIEF (PJB) Are there recommended changes to the work that could have improved the safety or efficiency of the work, i.e., PPE, work environment, tools, materials, equipment, etc.? Yes No Were there any unexpected aspects or occurrences including accidents, injuries or near-miss incidents? Yes No Was training for the job appropriate and effective? Yes No Was work area cleanup/housekeeping adequate? Yes No Did all involved with the work understand their individual responsibilities? Yes No Was the task accomplished with expected results? Yes No Is additional follow up required from this Postjob Review? Yes No Is any enhancement to plant documentation warranted, i.e., were procedures/step text complete and accurate, any print or schematic discrepancies, etc? Yes No Was planning and scheduling optimized to reduce the potential for human error? Yes No If YES, then the Foreman/Supervisor/Lead Performer is responsible to provide this feedback to the responsible group for action. Post-job Review Participants Signature Printed Name Was preparation adequate? Yes No Post-Job Review For any issues identified during this review, provide comments below the question, including any actions taken already, PER written (document PER#), etc. Equipment inspection check lists on all required equipment. Yes No Were lessons learned that change the way the job should be performed, recorded, passed on to others, and entered into Maximo as appropriate? Yes No Were Lessons Learned entered into the FGD&C Lessons Learned website? Yes No If a JSA was used in the pre-job briefing, did it adequately cover all of the hazards and control measures? Yes No If a JSA was not used in the pre-job briefing, did the checklist cover all of the hazards and control measures? Yes No Was there any change in work scope requiring re-briefing of workers? Yes No If a JSA was not used in the pre-job briefing should a JSA be developed for this job? Yes No Did supervision provide the needed support and appropriate guidance when necessary? Yes No Did you notice any human factors issues, improper or missing labels, or any significant physical hindrances to the performance of the work? Yes No Was equipment parked in required/designated location after use? Yes No Foreman/Supv/Employee: Date of Review: Note: This form must be retained for 30 days or until work order/package is closed. TVA [10-??-2012]

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237 SITE-SPECIFIC HEALTH AND SAFETY PLAN Attachment D Stantec RMS Forms July 24, 2017 ATTACHMENT D STANTEC RMS FORMS

238 FIELD LEVEL RISK ASSESSMENT (FIT FOR DUTY), 5 DAY RMS 2 Project: Project No: Client: Location: Start Date: Documentation and Procedure Review 1. Risk Management Strategy (RMS1) form and/or Site Specific Health and Safety Plan signed and reviewed? Yes No* 2. Emergency Response Plan reviewed? Yes No* N/A 3. Tested two-way communications (cell phone, satellite phone) and security measures? Yes No* 4. Attended Client Site Health and Safety meeting? Yes No* N/A 5. Conducted Stantec site safety meeting with all workforces? Yes No* N/A 6. Are there any new or unexpected hazards not identified in the RMS1/HASP? If yes, include in the Job Safety Analysis (JSA). 7. Working alone or remote work? If yes, complete call in/out process Safe Work form must be completed. Notifications and Permits 8. Are work permits required for this site? If yes, have they been completed and submitted as required? 9. Are utility locates required for this site? If yes, have they been completed and reviewed? 10. Does the Client require any notification prior to starting the work? If yes, has the notification been provided? Yes No Yes No Yes No Yes No* Yes No Yes No* Yes No Yes No* Work Description *Contact your Project Manager immediately. Provide a general description of the work to be conducted. Personal Protective Equipment List specific PPE as needed. Verify type and inspect condition. Head Protection Type: Hearing Protection: Gloves Type: Foot Protection Type: Respiratory Protection: Water Safety Gear: Eye Protection Type: Fire Retardant Coveralls: High Visibility Vest: Fall Protection: Tools and Equipment List specific equipment to be used. Verify type and inspect condition. Last Updated: March 2014 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 1 of 4

239 Daily Tailgate Discussions/Subcontractor Input Date: Time: Weather: Start FIELD LEVEL RISK ASSESSMENT (FIT FOR DUTY), 5 DAY RMS 2 Mid-Day Post-Day Date: Time: Weather: Start Mid-Day Post-Day Date: Time: Weather: Start Mid-Day Post-Day Date: Time: Weather: Start Mid-Day Post-Day Date: Time: Weather: Start Mid-Day Post-Day Last Updated: March 2014 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 2 of 4

240 I know the hazards: By signing here, you are stating the following: FIELD LEVEL RISK ASSESSMENT (FIT FOR DUTY), 5 DAY RMS 2 1. I have been involved in the Job Safety Analysis (JSA) and understand the hazards and risk control actions associated with each task I am about to perform. 2. I understand the permit to work requirements applicable to the work I am about to perform (if it includes permitted activities). 3. I am aware that work that has not been risk assessed must not be performed. 4. I am aware of my ability and obligation to Stop Work (See below). I arrived and departed fit for duty (see Fit for Duty card for further information): 5. I am physically and mentally fit for duty. 6. I am not under the influence of any type of medication, drugs or alcohol that could affect my ability to work safely. 7. I am aware of my responsibility to bring any illness, injury (regardless of where or when it occurred), symptoms of soreness or discomfort, or fatigue issue I may have to the attention of the Crew Lead or Supervisor. 8. I sign out uninjured unless I have otherwise informed the Crew Lead or Supervisor. Insert fitness level under corresponding time column: Fit for Duty = F Alternate Plan = AP Team Lead to contact Project Manager for any personnel identified as AP Date: Date: Date: Date: Date: Individual Name/Company Name/Signature Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: I will STOP WORK any time anyone is concerned or uncertain about safety. I will STOP WORK if anyone identifies a hazard or additional mitigation not recorded. I will be alert to any changes in personnel or their fitness level (AP), conditions at the work site or hazards. If it is necessary to STOP WORK, I will reassess the task, hazards and mitigations; and then proceed only when safe to do so. Conclusion of day: I certify that the planned work activities are completed for the day and all injuries and first aids have been reported via RMS3. Signature of Crew Lead: Signature of Crew Lead: Signature of Crew Lead: Signature of Crew Lead: Signature of Crew Lead: Date: Date: Date: Date: Date: Last Updated: March 2014 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 3 of 4

241 Job Safety Analysis (JSA) Must be completed for all field activities. Basic Job Steps Potential Hazards FIELD LEVEL RISK ASSESSMENT (FIT FOR DUTY), 5 DAY RMS 2 Controls to Reduce or Eliminate Hazard Person Responsible Review the hazard categories below and check the mitigation measures applicable to the identified scope of work. Environmental Hazards 1. Work area clean 2. Material storage identified 3. Dust/Mist/Fume 4. Noise in area 5. Extreme temperatures 6. Spill potential 7. Waste containers needed 8. Waste properly disposed 9. Waste plan identified 10. Excavation permit required 11. Other workers in area 12. Weather conditions 13. MSDS reviewed Ergonomic Hazards 14. Awkward body position 15. Over extension 16. Prolonged twisting/bending motion 17. Working in a tight area 18. Lift too heavy/awkward to lift 19. Parts of body in line of fire 20. Repetitive motion 21. Hands not in line of sight 22. Working above your head Access/Egress Hazards 23. Aerial life/man basket (inspected & tagged) 24. Scaffold (inspected & tagged) 25. Ladders (tied off) 26. Slips & trips 27. Hoisting (tools, equipment) 28. Evacuation (alarms, routes, ph. #) 29. Confined space entry permit required Overhead Hazards 30. Barricades & signs in place 31. Hole coverings identified 32. Harness/lanyard inspected % Tie-off with harness 34. Tie off points identified 35. Falling items 36. Foreign bodies in eyes 37. Hoisting or moving loads overhead Rigging & Hoisting Hazards 38. Lift study required 39. Proper tools used 40. Tools inspected 41. Equipment inspected 42. Slings inspected 43. Others working overhead/below 44. Critical lift permit Electrical Hazards 45. GFI test 46. Lighting levels too low 47. Working on/near energized equipment 48. Electrical cords condition 49. Electrical tools condition 50. Fire extinguisher 51. Hot work or electrical permit required Personal Limitations/Hazards 52. Procedure not available for task 53. Confusing instructions 54. No training for task or tools to be used 55. First time performing the task 56. Micro break (stretching/flexing) 57. Report all injuries to your supervisor Reviewed by Name and Signature: It is important that all relevant hazards have plans in place to reduce risk. Be sure that all associated permits are closed off at the end of the job. Remember: Stop and Think Last Updated: March 2014 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 4 of 4

242 INCIDENT REPORT RMS 3 Incidents involving injury, potential injury, or report of pain, soreness, or discomfort must be reported immediately (within one hour) to a supervisor. Supervisors will then immediately contact their HSE representative to develop a plan for assessment and care. This form must be completed and submitted within 24 hours of any incident. Do not delay submission waiting for signatures. to hse@stantec.com or fax unsigned report to (780) and file locally in compliance with the corporate records retention policy and practices once all signatures have been obtained. This document contains privileged and confidential information prepared at the request of Stantec s Legal Counsel. The contents of this report are restricted to HR personnel, Risk Management Representatives, Project Manager and BC Leader, and Stantec s Insurer, Adjuster and Legal Counsel. Information collected will be used solely for the purpose of meeting the requirements of Stantec's HSE and insurance programs, complying with applicable legislation, and will be used in accordance with any governing privacy legislation. The information collected will be maintained electronically and may be included in required reports. SECTION 1: GENERAL INFORMATION Office location: Location of incident: Incident date and time: Project name: Client Name: Person in charge: BC number: Date and time reported: Project number: Person in Charge Phone: SECTION 2: STANTEC EMPLOYEE INFORMATION (if more than one identify extras in incident details below) Name: Phone: Job position: Group name: Time employee began work: Job Experience (in years) Type of employment: Full Time ; Visitor ; Contract ; Volunteer ; Seasonal Supervisor: Supervisor Phone: SECTION 3: INCIDENT DETAILS Type of Incident: *incident types marked with an asterisk, please complete pages 1 and signature page only See StanNet for a list of Incident Type Definitions *Report Only First Aid Motor Vehicle Incident 3 rd Party Incident (i.e., Public) *Hazard Identification Medical Aid No Lost Time Property Damage - Vehicle Spill or Release *Near Miss Restricted Work Property Damage - Other Utility Strike *Safety Opportunity Lost Time Theft Fire/Explosion/Flood Fatality Contractor Recordable Incident Stop Work Authority Violence or Harassment Non-compliance Describe incident in detail: (include any issues related to people, equipment, materials, environment, and processes) Immediate corrective actions taken: Canada East (Atlantic) Neil Clements ( ); Canada East (ON/QC) Jim Elkins ( ); Canada East (Quebec) Claudine Tremblay ( ); Canada Prairie & Mountain Yvonne Beattie ( ); International Kev Metcalfe ( ); US Northeast & South) Fred Miller ( ); US Midwest & Mid-Atlantic - Keith Kuhlmann ( ); US West Clint Reuter ( ) Last Updated: May 2015 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 1 of 4

243 INCIDENT REPORT RMS 3 SECTION 4: MEDICAL INFORMATION Name of first aid attendant: Description of first aid or medical treatment administered: Injury recorded in first aid log? Yes No N/A Clinic/hospital sent to: Attending physician/paramedic (if known): Area of Injury Please check all that apply: Head Teeth Upper back Left Right Left Right Left Right Left Right Face Neck Lower back Shoulder Wrist Hip Ankle Eye(s) Chest Abdomen Arm Hand Thigh Foot Ear(s) Pelvis Elbow Finger(s) Knee Toe(s) Other Specify Forearm Lower Leg Has the injured employee had a previous similar injury or disability? Yes No SECTION 5: PROPERTY OR VEHICLE DAMAGE: STANTEC Ownership Details (choose one): Rented (attach rental agreement) Stantec Owned Personal (employee vehicle) Year, Make, and Model of Vehicle: Vehicle ID # (VIN) Nature of damage: Estimated cost of damage: $ Description of damaged property: Attending police officer (if known): Badge #: Copy of police report received Yes No If yes, file number: (attach copy of police report) PROPERTY OR VEHICLE DAMAGE: 3 RD PARTY Name of owner and contact number: Year, Make, and Model of Vehicle: Insurer and Policy Number: Injured parties? Yes No If yes, describe Injuries: Diagram or photographs attached? Yes No License Plate Number: WITNESS INFORMATION - #1 Name: Witness statement provided? Yes (attached) No Phone Number: WITNESS INFORMATION - #2 Name: Witness statement provided? Yes (attached) No Phone Number: SECTION 6: SPILL OR RELEASE Substance: Quantity: Employee(s) exposed via: Inhalation Contact Ingestion n/a Off-site impacts observed or anticipated? Yes No If yes, describe: Name of regulatory agencies contacted: Contact name, number, date and time of call: Canada East (Atlantic) Neil Clements ( ); Canada East (ON/QC) Jim Elkins ( ); Canada East (Quebec) Claudine Tremblay ( ); Canada Prairie & Mountain Yvonne Beattie ( ); International Kev Metcalfe ( ); US Northeast & South) Fred Miller ( ); US Midwest & Mid-Atlantic - Keith Kuhlmann ( ); US West Clint Reuter ( ) Last Updated: May 2015 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 2 of 4

244 INCIDENT REPORT RMS 3 SECTION 7: ANALYSIS IMMEDIATE/DIRECT CAUSES A. UNSAFE ACTIONS (check off as many as necessary) Operating equipment without Failing to use personal protective equipment Failure to identify hazard or risk authority properly Failure to warn Improper loading Inattention Failure to secure Improper placement Failure to communicate Operating at improper speed Improper lifting or handling Other: Specify Making safety devices inoperative Improper position for a task Removing safety devices Servicing equipment in operation Using defective/improper Horseplay equipment Using equipment improperly Failure to follow procedure, policy or practice B. UNSAFE CONDITIONS (check off as many as necessary) Inadequate guards/barriers Radiation exposure Inadequate information/data Improper/inadequate PPE High or low temperature Inadequate preparation/planning exposures Defective tools or equipment Inadequate or excess Inadequate support/assistance illumination Congested work area Inadequate ventilation Road conditions Inadequate warning system Presence of harmful materials Weather conditions Fire and explosion hazards Inadequate instructions/procedures Other: Specify Poor housekeeping; disorder Hazardous environmental conditions; gases, dusts, smokes, fumes, vapours Noise exposure BASIC/ROOT CAUSES C. PERSONAL FACTORS (check off as many as necessary) Inadequate physical capability Mental stress Lack of knowledge Physical stress Lack of skill Other: Specify D. JOB FACTORS (check off as many as necessary) Inadequate leadership or supervision Inadequate maintenance (scheduled or Excessive wear and tear preventative) Inadequate engineering Inadequate tools or equipment Inadequate communications Inadequate purchasing Inadequate work standards Improper motivation Abuse or misuse Other: Specify SECTION 8: FOLLOW-UP Short-term: Corrective Action Assigned To Target Date Completion Date Long-term: Corrective Action Assigned To Target Date Completion Date Canada East (Atlantic) Neil Clements ( ); Canada East (ON/QC) Jim Elkins ( ); Canada East (Quebec) Claudine Tremblay ( ); Canada Prairie & Mountain Yvonne Beattie ( ); International Kev Metcalfe ( ); US Northeast & South) Fred Miller ( ); US Midwest & Mid-Atlantic - Keith Kuhlmann ( ); US West Clint Reuter ( ) Last Updated: May 2015 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 3 of 4

245 INCIDENT REPORT RMS 3 Involved Employee Comments: REVIEW COMMENTS Signature: Print Name: Date: Job Title: Lead Investigator Comments: Signature: Print Name: Date: Job Title: Supervisor/Project Manager: Signature: Print Name: Date: Job Title: HSE Representative (OSEC/JH&S Committee/RSEC/HSE Manager): Signature: Print Name: Date: Job Title: Management Review: Signature: Print Name: Date: Job Title: Client Review (if required): Signature: Print Name: Date: Job Title: Additional Comments: Canada East (Atlantic) Neil Clements ( ); Canada East (ON/QC) Jim Elkins ( ); Canada East (Quebec) Claudine Tremblay ( ); Canada Prairie & Mountain Yvonne Beattie ( ); International Kev Metcalfe ( ); US Northeast & South) Fred Miller ( ); US Midwest & Mid-Atlantic - Keith Kuhlmann ( ); US West Clint Reuter ( ) Last Updated: May 2015 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 4 of 4

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248 WORKSITE INSPECTION: FIELD (RMS5) Group/Business Line: Location: Purpose: Responsibility: Business Center: Date: To identify hazards in the field where Stantec personnel are working. The Project Manager will determine how often work site inspections are required. OSEC may assist. NOTE: for pre-use vehicle inspection, record inspection on SWP 124a Vehicle Pre-Use Checklist. Okay Status Needs Work Severity Ranking N/A A B C Repeat Item (Y or blank) Action Required (incl. champion s name) Date Done HSE Documentation RMS1 hazard assessment Health and Safety Plan (HASP) Toolbox meeting/rms2 Permits (e.g. work, confined space, hot work, etc.) Clearances Training requirements met Safe Work Practices Inspection forms (e.g. ladder, chainsaw, client-specific excavation, etc.) Other: Specify: Emergency Preparedness Emergency Response Plan current & available Muster point First aid kit stocked/available Emergency eyewash available First aid providers on-site Fire extinguisher Communication available Spill response kit Other: Specify: Protective Equipment Hard hats Safety glasses Hearing protection High visibility vests Proper work gloves Safety boots 18 PVC orange traffic cones Road signs as required A Major Includes potential for serious incident or illness, hospitalization, permanent disability, fatality or extensive property damage B Moderate Includes potential for lost-time injury or illness, temporary disability or considerable property damage C Minor Includes potential for first aid injury, minor illness, no lost time or limited property damage Last Updated: May 2015 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 1 of 3

249 WORKSITE INSPECTION: FIELD (RMS5) Okay Status Needs Work Severity Ranking N/A A B C Repeat Item (Y or blank) Action Required (incl. champion s name) Date Done Fall arrest/restraint Personal floatation device Other: Specify: Tools and Equipment Maintenance tools in good condition Used properly Appropriate for job Stored and/or secured safely Lockout system established Clearance from panels/overhead wires Guards in place Other: Specify: Chemicals Site Controlled products labeled properly Stored properly MSDS available TDG compliance Other: Specify: Parking Accessibility Work area demarcated Visibility Slipping and tripping hazards Drainage Overhead hazards identified Buried utilities located/marked and exposed by hand Pits/excavations barricaded Excavation/Trench supports/slope Traffic hazards controlled (including pedestrian walkways) Other: Specify: Environment Sensitive areas identified Noise levels (</= 84dBA 8hr shift; 82dBA 12hr shift) A Major Includes potential for serious incident or illness, hospitalization, permanent disability, fatality or extensive property damage B Moderate Includes potential for lost-time injury or illness, temporary disability or considerable property damage C Minor Includes potential for first aid injury, minor illness, no lost time or limited property damage Last Updated: May 2015 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 2 of 3

250 WORKSITE INSPECTION: FIELD (RMS5) Okay Status Needs Work Severity Ranking N/A A B C Repeat Item (Y or blank) Action Required (incl. champion s name) Date Done Chemical hazards identified Working near water Heat/Cold Gas, fumes, dusts, vapors, asbestos Ventilation Confined space (including monitor and attendant(s)) Other: Specify: General (including Buildings/Trailers) Exits marked and accessible Stairs and walkways clean and dry Handrails sturdy Emergency lighting General housekeeping Body positioning, ergonomics (resources available on StanNet) Other: Specify: Prepared by: Approved by: Print Name Signature Date Print Name Signature (Project Manager) Date Original Copy: Project Files Copies: OSEC & Field Files A Major Includes potential for serious incident or illness, hospitalization, permanent disability, fatality or extensive property damage B Moderate Includes potential for lost-time injury or illness, temporary disability or considerable property damage C Minor Includes potential for first aid injury, minor illness, no lost time or limited property damage Last Updated: May 2015 Document Owner: Corporate HSE Printed copy uncontrolled current version on StanNet Page 3 of 3

251 RMS12 - HEALTH SAFETY ACTION PLAN Action Responsibility Target Date Completion Date Comments/ Sign Off Last Updated: March 12, 2014 Printed copy uncontrolled - current version on StanNet Document Owner: HSE Page 1 of 1

252 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Appendix D Data Management Plan DATA MANAGEMENT PLAN

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309 TVA ALLEN FOSSIL PLANT REMEDIAL INVESTIGATION WORK PLAN Appendix E UM-USGS Groundwater Investigation Proposal UM-USGS GROUNDWATER INVESTIGATION PROPOSAL

310 Investigation of Groundwater Conditions at the Tennessee Valley Authority Allen Combined Cycle Plant, Memphis, Tennessee A Collaborative Investigation by the U.S. Geological Survey and University of Memphis Center for Applied Earth Science and Engineering Research Submitted to the Tennessee Valley Authority August 2017

311 Background and Problem The Tennessee Valley Authority (TVA) is constructing a natural gas power plant near the site of the Allen Fossil Fuel Plant at Memphis, Shelby County, Tennessee. The new plant will be a two on one natural gas plant that can run in either simple or combined-cycle (CC) mode. The simple-cycle mode uses little if any water. The CC mode is projected to use an annual average of 2,500 gallons per minute (gpm), or approximately 3.6 million gallons per day (MGD). The maximum instantaneous flow needed is 5,000 gpm for a few hours on the hottest days and based on historical maximum 24 hour weather data and power usage, would equal an average of approximately 3,800 gpm (5.5 MGD) on these extreme days. The effect of groundwater withdrawal at the new Allen CC Plant on the aquifers and on groundwater levels recently has come into question by local and state agencies, including the Tennessee Department of Environment and Conservation (TDEC). TDEC has requested that TVA take steps to evaluate the effects of pumping the five new Memphis aquifer production wells installed at the CC Plant to assess (1) the potential for hydraulic connection between the Mississippi River Alluvial aquifer (MRVA) and the Memphis aquifer and (2) potential for water-quality degradation in the Memphis aquifer resulting from leakage of water from the MRVA aquifer and (or) McKellar Lake/Mississippi River. Included in the TDEC request is that groundwater-flow and solutetransport modeling will be conducted for: evaluating source contamination to the Fluvial Aquifer, potential contaminant migration pathways from the source area, potential water quality impacts to the Memphis Sand aquifer, and ultimately the possibility of contaminant migration to potential receptors, via shallow migration or MLGW wellfield impacts. 1

312 The U.S. Geological Survey (USGS) and The University of Memphis Center for Applied Earth Science and Engineering Research (CAESER) personnel have determined that an adequate groundwater model cannot be developed before beginning the final phase of startup of the new CC Plant in December 2017 for the following reasons: Recently collected geologic data are available and additional hydrologic and geologic data are needed to update the current conceptual model to address the potential interaction between the MRVA aquifer and the Memphis aquifer in the Allen CC Plant area. The USGS Mississippi Embayment Regional Aquifer Study (MERAS) model (Clark and Hart, 2009) does not address localized effects of pumping from the Memphis aquifer in enough detail to address potential for interaction with shallow (water-table) aquifers (MRVA aquifer and fluvial deposits aquifer) or to conduct solute-transport simulations at scale of interest. Refinement of the MERAS flow model or development of a new model will be required. Limited temporal and spatial water-level data are available in the Allen CC Plant area. Additional data are needed for calibration of a groundwater-flow and solutetransport model. Potential pathways for contaminant transport are not well defined. In order to address questions about groundwater withdrawals at the new CC Plant, USGS and CAESER personnel propose to conduct an initial set of action items to better define hydrologic conditions at the site. These items, defined as Action No. 1, assess the potential for interaction between the MRVA and Memphis aquifers in the study area by testing whether hydraulic communication exists in the short-term locally between the two hydrogeologic units 2

313 prior to planned startup of and groundwater withdrawals at the new CC Plant, and to provide baseline and on-going data after the Plant is operational. Action No. 1 will refine the current conceptual model needed for use in simulations of groundwater flow and solute transport. Based on the expected needs for groundwater modeling, an area of interest (study area) will be defined to include both the Allen Fossil and CC Plants and surrounding areas to the extent needed for application of appropriate boundary conditions for a groundwater model. Objective The objective of this investigation is to evaluate the potential short-term effects of groundwater withdrawals associated with the Allen CC Plant on the Memphis and MRVA aquifers, and to establish a preliminary network of wells for long-term monitoring following Plant start-up and production well operation. Specific questions to be answered by the study include: What are the hydrogeologic characteristics of the MRVA aquifer, the upper Claiborne confining unit, and the Memphis aquifer in the study area? Does pumping from the Memphis aquifer locally induce any hydraulic response from the MRVA aquifer? Is there evidence for modern water in the Memphis aquifer, and (or) does water in the Memphis aquifer indicate a contribution of from the MRVA aquifer locally? Is there any evidence for hydrogeologic connection between the MRVA and Memphis aquifer at the Allen Fossil and CC Plants based on available data for the study area? 3

314 The answers to these questions will provide the information needed to refine the conceptual model of the hydrogeology in the area surrounding the CC Plant and an improved framework for simulation of groundwater flow in the Memphis and MRVA aquifers in the study area. Relevance and Benefits The proposed study fits within the Water Use and Availability section of the USGS, Lower Mississippi Gulf Water Science Center Science Plan. The information and understanding gained through this study will benefit many users, including the TVA, TDEC; the City of Memphis, Memphis Light, Gas and Water Division; and Shelby County. The USGS and CAESER have collaborated on several hydrogeologic studies in the Memphis area. A regional groundwater-flow model of the Mississippi embayment aquifers has been constructed and calibrated using MODFLOW (Harbaugh, 2005) for the period from predevelopment to 2007 as part of the USGS MERAS study (Clark and Hart, 2009). This groundwater-flow model incorporates information on the hydrogeology and water use in the northern Mississippi embayment area, including the Memphis area. Water-use data incorporated in the model for the Memphis area currently is being updated through The model is the best tool available to evaluate the effects of withdrawals associated with combined-cycle combustion plants in conjunction with other withdrawals from the aquifer system. The MERAS model was used previously to simulate the effects various scenarios of pumping from the Memphis aquifer at the new Allen CC Plant (Haugh, 2016). 4

315 Scope and Approach Tasks to be conducted under Action No. 1 and are designed to address questions in the short-term about the effects of pumping from the Memphis aquifer at the Allen CC Plant on the shallow aquifer, and to refine the conceptual model of hydrogeologic conditions in the study area. The scope of the study will require that the production wells at the CC Plant be pumped for short periods in order to collect representative water-quality samples from the Memphis aquifer and to evaluate the effects of short-term withdrawals from the Memphis aquifer on the MRVA aquifer. The results of this study will be used for developing proposed tasks to be conducted for Action No. 2, which will consist of continued long-term water-level and water-quality monitoring in the area, possible surface geophysical surveys, and update of the MERAS model or development of a new model to evaluate the effects of withdrawals in the study area, should the results of Action No. 1 indicate the need for simulations of groundwater flow and solute transport. Action No. 1: Well Reconnaissance and Hydrogeologic Information Compilation - A reconnaissance of existing wells in the study area will be conducted. Wells permitted by the Shelby County Health Department will be inventoried. Emphasis will be placed on wells screened in the Memphis aquifer within the study area and on wells screened in the MRVA aquifer proximal to the CC Plant. Well records and driller s/geophysical logs will be compiled for use in the development of updated maps of the top and thickness of the confining unit and cross-sections for use in refining the conceptual hydrogeologic model and framework for the study area. Depending on accessibility and pumping schedules of inventoried 5

316 wells, selected non-tva production wells also may be used for periodic water-level measurements and possible sampling for water-quality analyses during this study. Additional Drilling and Well Installation - Additional wells screened in MRVA aquifer are proposed for installation to aid in monitoring water-level conditions in the shallow aquifer and to serve as additional control points for determining potential for hydraulic communication between the shallow aquifer and the Memphis aquifer. Plans are underway for TVA to add a series wells at the Allen CC Plant to the drilling program that is currently underway at the Allen Fossil Plant. USGS and CAESER personnel will be onsite for geologic logging of the boreholes and collecting lithologic samples to determine screened settings for the new wells at the CC Plant. Four, 4-inch PVC casing and screen monitoring wells are proposed for installation: 1. Two monitoring wells to be installed adjacent to production well #5 at the CC Plant. One well to be installed with a 10-foot screen in the upper part of the MRVA aquifer and one with a 10-foot screen near the base of the MRVA aquifer. These wells will serve to assess vertical hydraulic gradient in the shallow aquifer adjacent to one of the new production wells and monitor hydrologic response of water levels in the MRVA aquifer to pumping from the Memphis aquifer at the Plant. 2. One monitoring well to be installed in the southeastern corner of the CC Plant property, near production well #1, or in the northeastern corner of the Plant, with a 10-foot screen in either the middle or lower part of the MRVA aquifer. This well will serve to assess hydrologic response of water levels in the MRVA aquifer 6

317 at the southeastern or northeastern corner of the Plant to pumping from the Memphis aquifer at the facility. 3. One monitoring well to be installed in the southwestern corner of the property adjacent to production well #3 with a 10-foot screen in either the middle or lower part of the MRVA aquifer. This well will serve to assess hydrologic response of water levels in the MRVA aquifer at the southwestern corner of the CC Plant to pumping from the Memphis aquifer at the facility. Geophysical Logging - Geophysical logging of planned new MRVA wells at the CC Plant and potentially other available monitoring wells at the Allen Fossil Plant will be conducted. The USGS geophysical logging unit will be used to run single-point resistance, natural gamma-ray, and electromagnetic conductivity logs in the completed wells to obtain stratigraphic information on the MRVA aquifer. Water-Quality Sampling - Water-quality samples will be collected from all production and monitoring wells at the CC plant, and the Harsco well screened in the MRVA aquifer at the Allen Fossil Plant. Additional samples may be collected in coordination with Stantec, Inc. personnel from selected monitoring wells at the Allen Fossil Plant, and possibly from a few industrial wells on Presidents Island and the Pigeon Industrial Park. The samples will be analyzed for field parameters on site (temperature, dissolved oxygen, ph, redox potential, and specific conductance) and submitted to the USGS National Water Quality Laboratory in Denver, Colorado for analysis of major dissolved constituents, trace metals, and stable oxygen, hydrogen, carbon, and sulfur isotopes. Tritium age-dating samples also will be collected and sent to the University of Miami lab for analysis. These data will be used to characterize the water-quality characteristics of 7

318 groundwater in the Allen Fossil and CC Plant area and potential for modern water (in contact with the atmosphere during the past 60 years) or water derived from the Mississippi River in the Memphis aquifer. Water-Level Data Collection - Water-level data will be collected as part of this study to evaluate the short-term potential for interaction between the MRVA aquifer and the Memphis aquifer during planned short-duration test pumping of the five new CC Plant production wells. Following these tests, water-level measuring equipment will remain in selected MRVA aquifer wells for continued data collection as part of Action No. 2 to evaluate the long-term response of the groundwater system to pumping once the CC Plant goes online. Descriptions of the two water-level data collection components in terms of their relation to this study are given below. o Short-term data: Water-level data will be collected from selected monitoring wells at the Allen CC Plant and Allen Fossil Plant prior to and during planned individual and combined test pumping of the five new Memphis aquifer production wells. Continuous water-level data will be collected during the tests from the four proposed MRVA monitoring wells to be installed at the CC plant, from selected wells at the Fossil Plant (Stantec will coordinate data collection from wells at the Fossil Plant and stage of McKellar Lake), and from selected offsite observation wells. Transducers will be installed in the monitoring and observation wells as soon as a notice to proceed is given by TVA in order to obtain as much antecedent data as possible prior to test pumping of the new production wells. USGS and CAESER personnel will jointly deploy and manage 8

319 collection of short-term data. The resulting data will allow ambient and testpumping water-level conditions to be monitored pre-plant startup. o Long-term data: Water-level data are planned for collection beyond the current study as part of Action No. 2 to monitor the effects pumping once the new CC Plant and wells become operational. These data will be managed by the USGS and stored in the USGS National Water Information System (NWIS) database. One of the new MRVA aquifer wells at the CC Plant and a local Memphis aquifer observation well will be selected and equipped with real-time recording equipment so that the data are displayed on the USGS NWISWeb site. The resulting data will allow for water-level conditions to be monitored pre- and postplant startup, including evaluation of hydraulic gradients within the MRVA/Memphis aquifers under static and pumping stress conditions. Test Pumping At the earliest scheduled time and following the new well installations and deployment of water-level transducers described above, USGS and CAESER personnel will conduct tests of the five new production wells at the CC Plant individually and in combination while continuously monitoring water levels in the four MRVA wells at the facility and selected MRVA wells at the Allen Fossil Plant (in coordination with Stantec personnel). TVA has agreed not to make the new production wells operable at Plant start-up, but they will need to be run for short periods as part of this study to evaluate the effects of pumping within the Memphis aquifer and for water-quality sampling. Water levels in the five production wells will be monitored for the tests by making periodic airline measurements in each well under static and pumping conditions. The duration of each individual and combination well test will be determined based on 9

320 consultation with TVA and study personnel, but will be of sufficient length to evaluate hydraulic interaction between the shallow and Memphis aquifer local to the CC Plant. Deliverables The deliverable for the proposed study will be a report to TVA describing the results of the items included as Action No. 1, including construction of a detailed conceptual model of hydrologic and geologic conditions beneath the Allen Fossil and CC Plant area. Water-level and water-quality data collected by the USGS will be available through the USGS NWISWeb page. A proposal for future work to be defined as Action No. 2 also may be prepared based on findings of this study. Timeline The proposed project is expected to take approximately four months to complete. If started by September 1, all field work for the project should be completed by the end of October Results of water-quality sample analyses will be available within approximately 60 days from sample submission to the labs. A final report containing the results of the study will be completed by December 31, A general task-timeline for the study is shown below. Task August September October November December Well Recon & HG Info Compilation X X Additional Drilling X Geophysical Logging X QW Sample Collection X Water Level Data Collection X X X X 10

321 Test Pumping X X Develop Conceptual X X X X X Model Prepare Report X X X X 11

322 12

323 References Clark, B.R., and Hart, R.M., 2009, The Mississippi Embayment Regional Aquifer Study (MERAS): Documentation of a groundwater-flow model constructed to assess water availability in the Mississippi Embayment: U.S. Geological Survey Scientific Investigations Report , 61 p., Harbaugh, A.W., 2005, MODFLOW-2005, the U.S. Geological Survey modular ground-water model The ground-water flow process: U.S. Geological Survey Techniques and Methods 6-A16 [variously paged]. Haugh, C.J., 2016, Evaluation of effects of groundwater withdrawals at the proposed Allen combined-cycle combustion turbine plant, Shelby County, Tennessee: U.S. Geological Survey Scientific Investigations Report , 8 p., 13

324 Proposal Addendum Work Plan for Test Pumping of New Production Wells at Tennessee Valley Authority Allen Combined Cycle Power Plant, Memphis, Tennessee The U.S. Geological Survey (USGS) and the University of Memphis, Center for Applied Earth Science and Engineering Research (CAESER), in cooperation with the Tennessee Valley Authority (TVA), are conducting a study of the effects of groundwater withdrawals from the Memphis aquifer at the new Allen Combined Cycle (ACC) Power Plant. As part of the study, test pumping and water-level monitoring were proposed to determine whether withdrawals from the new Memphis aquifer production wells at the ACC Plant produce drawdown in the overlying Mississippi River Valley Alluvial (MRVA) aquifer, which would indicate hydraulic connection between the two aquifers. The USGS/CAESER proposal was provided to TDEC as an addendum to the Remedial Investigation (RI) work plan for the TVA Allen Fossil Plant (ALF). TDEC has requested that additional details be provided on the proposed well testing. This document provides additional descriptions of the procedures, schedule, wells, pumping rates, duration, storage/disposal of water, and water-level monitoring during a planned test of selected production wells at the ACC Plant. Test Pumping General A test of selected Memphis aquifer production wells at the ACC Plant will be conducted in late September-early October 2017, before the wells and Plant are put into service. Plans for the test are continuing, with the schedule, duration, and other logistics of the test dependent on several factors primarily including how water withdrawn during the test will be stored and released. 1

325 All five production wells are permanently piped to the cooling tower basin, and once it enters the closed-loop cooling system, water in the system can be discharged to the Memphis wastewater treatment facility at rates up to approximately 700 gallons per minute (gpm) as currently designed and constructed. For this test, TVA will reroute the majority of the flow from the wells to discharge via site Construction General Permit (CGP) with an option to discharge some of the flow via the site Pretreatment permit to the City of Memphis Maxson Waste Water Treatment Plant (WWTP) next door. Because the City does not currently have sewer line capacity to transport all of this water to the Maxson Waste Water Treatment Plant (WWTP), the site will also have the option utilize the storage capacity of the Storm Water Pond and the Cooling Tower Basin.. Uncontaminated groundwater is an authorized non-stormwater discharge allowed by the site Construction General Permit. Once the ACC Plant is operational, water withdrawn by the production wells primarily will be used for make-up of water lost to evaporation during steam condensate cooling. The five new production wells at the Plant are each rated for continuous operation at yields of about 1,250 gallons per minute (gpm). The estimated annual daily average rate of cooling system make-up water to be supplied by the wells is estimated to be 2,500 gpm, or approximately 3.6 MGD, which includes a maximum instantaneous pumping rate of 5,000 gpm that is estimated to be needed for only a few hours on the hottest days [based on historical maximum 24-hour weather data and power usage, TVA estimates that the highest average daily pumping rate would equal approximately 3,800 gpm (5.5 MGD) on these extreme days]. On the basis of the projected annual average daily pumping rate of 2,500 gpm, a test of about one day duration at this maximum anticipated rate should be sufficient for evaluating hydraulic 2

326 communication between the two aquifers in the short-term, with continued water-level monitoring in the two aquifers that is proposed to be conducted as part of the overall study providing for a longer-term evaluation of potential effects once the Plant becomes operational. Test Pumping Wells, Rates, and Duration The proposed test will simulate TVA s anticipated maximum withdrawal scenario on an extremely hot summer day. This would correspond to running four wells for 8 hours, three wells for 8 hours, and two wells for 8 hours over a continuous 24 hour period (total withdrawn = 5.4 MGD). Managing and handling this amount of water over this period on a non-operating plant will be challenging. In essence, the ACC will be discharging the amount of water that would normally be lost to evaporation, and the plant is not designed to do this without temporary modifications to piping systems and close coordination with the City of Memphis and operating staffs at the Maxson WWTP A 24-hour duration test also will allow for comparison to projected drawdown estimates from the results of aquifer-test and lithologicsample data collected from a test well drilled at the location of and prior to completion of Production Well #1 in the southeastern corner of the ACC site (Trinity, 2016), and from drawdown measured in the production wells during the performance tests conducted by Layne Christensen. Test Pumping Water-Level Monitoring Water-level monitoring will be conducted during the test to determine drawdowns in the pumping and idle Memphis aquifer production wells at the ACC Plant, and to evaluate the 3

327 potential effects on water levels in the MRVA aquifer local to both TVA plants and in a few available Memphis aquifer observation wells located within a 4-mile radius of the ACC Plant. Pressure transducers will be installed in the MRVA and Memphis aquifer observation wells to collect water-level data at one-hour intervals prior to, during, and following the tests. Stantec, contracted by TVA, plans to install transducers in all of the existing MRVA wells around the ALF East Ash Pond to collect continuous (hourly) water-level data through the pre- and post-test period. Stantec also will provide personnel to be onsite to make periodic measurements in the MRVA aquifer wells during prior to, during, and following the test. Pressure transducers will be installed by USGS/CAESER personnel prior to the test in the four new MRVA aquifer wells installed at the ACC Plant and in the three available Memphis aquifer observation wells within a 4-mile radius of the Plant. Static water levels will be measured in each production well before the test begins with a dedicated and cleaned steel tape and chalk, and by airline methods to verify airline and steel-tape readings. Periodic water-level measurements then will be made in the pumping and idle production wells by airline methods during the test and for a few hours following the test during the period of water-level recovery. Water levels will be measured in the MRVA and Memphis aquifer observation wells (by electric tape methods) ahead of, during, and after the test during the period of water-level recovery. All electric tapes used to make water-level measurements in wells will be cleaned ahead of the test and deconned between wells. USGS and CAESER personnel will make water-level measurements prior to and through the test period in the onsite Memphis aquifer production and MRVA aquifer monitoring wells and the offsite Memphis aquifer observation wells. Figure 1 shows the locations of the TVA 4

328 ACC Plant, ALF, Memphis aquifer production wells and observation wells, and the extent of area where water-level data will be collected from the MRVA aquifer. Following test completion, a summary of the test and data will be prepared and provided to TVA by the USGS and CAESER. USGS/CAESER will coordinate with Stantec to obtain water-level data collected from their network for use in evaluating results of the test and for inclusion in the summary report. Figure 1. Locations of TVA Allen Combined Cycle and Allen Fossil Plants, new production wells (in red), and approximate area of Allen Fossil Plant monitoring wells (light white polygon) and potential Memphis aquifer observation well to be monitored during test (in green). 5