Review of Reportable Environmental Events at TVA Facilities

We identified issues related to (1) noncompliance with reporting requirements; (2) different interpretations on how some environmental occurrences should be classified; (3) environmental issues that were not documented and managed through TVA's corrective action program; (4) lack of a corporate reportable environmental events (REE) procedure; (5) inaccurate environmental data in the Electronic Corrective Action Program (eCAP), Environmental Event Reporting (EER) system, and REE registry; and (6) two instances where TVA did not externally report events because they did not feel it was required. We recommended TVA's Environmental Stewardship and Policy (1) clarify the environmental occurrences required to be classified as Environmental Events, (2) develop a corporate REE procedure, (3) clarify the environmental occurrences required to be managed through the corrective action process, and (4) review environmental data in the eCAP, EER system, and REE registry for accuracy, correct identified errors, and identify a method to prevent future environmental database errors. We further recommended TVA's Environmental Executive work with other TVA executives to promote a culture of transparent reporting throughout TVA organizations. This could include a periodic briefing of management or executives on the status of REEs, Environmental Events, Notices of Violation, and Environmental Management System findings. Management agreed with our recommendations. Summary Only