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Brought to you by the Council of the Inspectors General on Integrity and Efficiency
The OIG reviewed Coal Operations' (CO) 4th quarter fiscal year (FY) 2012 and 2nd and 4th quarters FY2013 enterprise risk maps for asset performance vulnerability to assess whether risk mitigation plans and actions were established and properly designed to manage risks. We determined the 4th quarter FY2013 mitigation plans and actions were adequately designed to manage the risks. Although the risk rating and trend had increased from 2 years ago, in our opinion, mitigation plans and actions that consider utilization of assessment tools, replacing components during planned outages, development and implementation of projects and programs to avoid consequences, and reclassification of components to capital from operations and maintenance to increase investment in long-term improvements reasonably address the risk of asset performance vulnerability in CO. We also identified an opportunity to improve CO's risk mitigation documentation which was addressed during our audit.
During 2012, we completed an audit of TVA's Financial Trading Program (FTP) audit number 2011-14477. The program, which started in 2003, was designed to hedge or otherwise limit economic risk associated with the price of commodities recovered in TVA's fuel cost adjustment (FCA). Since the hedging of natural gas comprised the majority of the hedging program, we generally limited our scope to the gas hedging program. Although our audit determined the overall design of TVA's FTP control structure was appropriate, we also identified several areas where management oversight needed improvement to validate the usefulness and effectiveness of the program, as well as ensure TVA stakeholders' understanding of the program.As a follow-up to audit 2011-14477, we contracted with Mercatus Energy Advisors (Mercatus) to provide a third-party review of the final actions taken by TVA management with regard to the recommendations from our audit and determine if TVA's Financial Gas Hedging program was designed and functioning in a manner to achieve program objectives in the most efficient and effective manner.In summary, Mercatus agreed the overall design of TVA's FTP control structure was appropriate. However, Mercatus identified several additional areas regarding the design and function of the program that required attention. To address these areas, Mercatus recommended TVA>Determine risk tolerance and proper size of the FTP.Analyze volumetric risk on a regular consistent basis and communicate with stakeholders having a vested interest in this aspect of the FTP.Redesign hedging strategies to better match the characteristics of the exposures being hedged.Improve and consolidate performance reports.Cease using "Value at Risk" as a primary risk metric and replace it with at risk type of metric(s) that includes financial natural gas hedges and the physical exposures being hedged.Conduct stress testing on a routine basis.Ensure actions required by governance documents are adhered to or if language in the documents is inaccurate, revise the documents to reflect actual practices.Conduct a proper cost/benefit analysis of the FTP and compare all-in hedged cost of fuel to the cost of fuel without hedging (market price).Properly analyze and manage all of TVA's energy commodity exposure.TVA management generally agreed with the recommendations and provided a plan of action to address the recommendations.
In completing project number 2009-12883, Survey of TVA's Process for Determining Condition of Assets, with a report dated September 20, 2012, the OIG learned that asset condition assessments performed by the Nuclear Power Group (NPG) had determined some generation assets were in poor condition. As a follow up to our prior work, we performed a review to determine whether TVA was taking action to address NPG systems, components, and programs with poor ratings. Under NPG's health report process, actions were required when ratings were designated red or yellow. Red ratings are defined as requiring excessive monitoring/resources to maintain, and yellow ratings indicate a need for additional attention.We found 333 systems, programs, and components within NPG had been designated red or yellow. We randomly sampled 25 for detailed review. Our analysis showed at least two actions were taken to address 24 of the 25 samples. For 1 component, only one action was completed and other actions were awaiting approval. These actions resulted in an improvement in condition and a change in 14 cases to a white or green rating, while 11 had ratings that remained red or yellow. It is important to note that of the remaining 11 with red and yellow ratings, 2 changed from red to yellow, and 9 remained the same. In addition, 5 of the 9 that remained red or yellow had some asset condition improvement but not sufficient improvement to change the rating.