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Brought to you by the Council of the Inspectors General on Integrity and Efficiency
This review was the result of broad interest surrounding the safety and condition of TVA dams after the ash spill at the Kingston Fossil Plant. The objectives of this review were to determine if TVA's Dam Safety Program identified and adequately addressed significant risks, was in compliance with TVA policies and procedures as well as applicable laws and regulations, and encompassed all the aspects of a comprehensive dam safety program. This review found TVA was taking steps to identify and mitigate its risks; adhering to the federal guidelines for dam safety with a few exceptions; and had a comprehensive dam safety program, but opportunities existed to strengthen the program. Specifically, we found:TVA was moving from being reactive to proactive by mitigating and anticipating risks. However, based on interviews with TVA plant personnel, we identified improvement opportunities that would further enhance the identification and mitigation of dam safety risks.TVA's policy was to follow the federal guidelines for dam safety, although not required under federal law. TVA is adhering to the federal guidelines with the exception of certain aspects of the operations and maintenance (O&M) manuals, training and awareness program, and emergency action plans (EAPs).TVA management agreed with our findings and recommendations and has taken or plans to take corrective actions.
The OIG reviewed TVA's storage and handling of anhydrous ammonia to determine whether (1) TVA's policies and procedures complied with relevant ammonia-related Occupational Safety and Health Administration (OSHA) and other federal regulations, and (2) TVA fossil plants were in compliance with TVA's policies and procedures covering ammonia storage and management. In addition, we assessed the general physical security surrounding TVA's ammonia storage tanks and related appurtenances.In summary, we found TVA has two procedures, TVA Safety Procedures 219 and 901, which are intended to implement the requirements of OSHA 29 CFR 1910.119. However, our audit disclosed (1) TVA does not have a formal policy addressing the requirements of American Natonal Standards Institute (ANSI) Standard K61.1 (CGA Standard G-2.1) - Storage and Handling of Anhydrous Ammonia or OSHA 1910.111, "Storage and Handling of Anhydrous Ammonia;" (2) TVA's Procedure 219, "Process Safety Management," does not address all of the requirements included in OSHA 1910.119, "Process Safety Management of Highly Hazardous Chemicals;" and (3) certain sites did not (a) complete all of the process hazard analysis requirements included in Procedure 219, (b) certify their operating procedures on an annual basis, (c) follow ammonia training requirements for its employees or have a mechanism for ensuring the required training of its employees who handle ammonia or perform maintenance on ammonia systems was timely, and (d) satisfy the nameplate and/or marking requirements for its ammonia storage tanks as required by ANSI Standard K61.1.We also found there was no "trigger" to inform visitors or nonplant TVA personnel that ammonia training may be required prior to entering the plants other than (1) Procedure 901, which requires that "Ammonia Awareness trainin shall be required for all employees or visitors to plants with SCR or any employee who may have exposure to ammonia," or (2) reliance upon the visitor's or nonplant employee's site contact for such information. Summary Only
We are pleased to present our report for the period March 31, 2010, through October 1, 2010. The hard work of our TVA OIG employees resulted in almost $20.5 million in recoveries, fines/penalties, potential savings, questioned costs, or funds which could be put to better use during this reporting period as well as numerous recommendations to improve TVA programs.We continue to monitor the progress TVA is making with both the Kingston coal ash clean-up efforts and TVA's overall record of environmental performance.