Office Of The Inspector General TENNESSEE VALLEY

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Office of the Inspector GeneralTENNESSEE VALLEY AUTHORITYSemiannual ReportOctober 1, 2020 - March 31, 20211

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TABLE OF CONTENTSMessage from the Deputy Inspector General. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Executive Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Audits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Evaluations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22Investigations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28Legislation and Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34Appendices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36Appendix 1 – Index of Reporting Requirements Under the Inspector General Act . . . . . . . . . . . . . . . . . . 37Appendix 2 – Audit and Evaluation Reports Issued . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39Appendix 3 – Audit and Evaluation Reports Issued with Questioned andUnsupported Costs and Recommendations for Better Use of Funds . . . . . . . . . . . . . . . . . 42Appendix 4 – Audit and Evaluation Reports with Recommendations Includedin a Previous Semiannual Report and Awaiting Implementation . . . . . . . . . . . . . . . . . . . . 44Appendix 5 – Investigative Referrals and Prosecutive Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47Appendix 6 – Substantiated Investigations Involving Senior Agency Officials . . . . . . . . . . . . . . . . . . . . 48Appendix 7 – Previously Undisclosed Investigations Involving Senior Agency Officials . . . . . . . . . . . . . . 48Appendix 8 – Statistical Highlights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49Appendix 9 – Government Contractor Audit Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50Appendix 10 – Peer Reviews of the TVA OIG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52Abbreviations and Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 553

MESSAGE FROM THEDEPUTY INSPECTOR GENERALI am pleased to present our report for the period October 1, 2020, to March 31,2021. The global pandemic continues to provide challenges to us, theTennessee Valley Authority (TVA), the people of the Tennessee Valley, and ourcountry. Our dedicated professionals continue to meet these challenges head onand find ways to continue to deliver results for the people of the Valley.In this semiannual period, our audit, evaluation, and An evaluation of TVA’s response to the coronavirusinvestigative activities identified more than 7.1 million(COVID-19) found actions taken related to staffing,in questioned costs, funds put to better use, recoveries,employee safety, and telework were reasonable.projected savings and waste, and opportunities for TVA toHowever, we also identified opportunities forimprove its programs and operations. Below are highlightsimprovement related to various COVID-19 issues.of our work this period. Two contract preaward examinations identified nearlySequoyah Nuclear Plant (SQN) Radiation 3.5 million of potential savings opportunities for TVAProtection (RP) group identified certain behavioralto negotiate.attributes and operational factors that had a positive An audit of TVA’s process for onboarding InformationTechnology (IT) contractors identified opportunities toalign policies between business units and improve theconduct of background investigations to comply withTVA policy. An evaluation of the maintenance of coal combustionresidual storage facilities determined, in general,TVA performed required inspections and completedmaintenance to address issues identified during theinspections. However, we also identified improvementopportunities. An evaluation determined TVA’s Generation Projectsorganization was not effectively managing the turnoverof projects to Power Operations because of misalignedprocesses and inconsistent application of processes.4 An organizational effectiveness evaluation of theimpact on SQN RP’s effectiveness. However, we alsoidentified behavioral and operational risks that couldimpact SQN RP’s effectiveness and ability to executeits responsibilities. Results from investigations include more than 3.6 million in restitution to TVA and others, costsavoided by TVA, and waste identified; significantprocess improvements; prosecutive action on twotemporary living allowance cases; and continuedprosecution of an environmental case.On December 31, 2020, and January 5, 2021, Brian Nolandand Beth Harwell, respectively, were sworn in as membersof the TVA Board of Directors (Board). We welcomeDirectors Harwell and Noland to TVA and look forward to aproductive working relationship with both.

Chickamauga DamFinally, I want to thank our Office of the InspectorGeneral (OIG) team for their sustained perseverancein these challenging times. The team’s unwaveringcommitment to our mission has been evident in how theycontinue to adjust so we can deliver meaningful results.We also extend our appreciation to the dedication of theTVA Board, management, and employees who have alsopersevered, adapted, and delivered on TVA’s broad missionduring these difficult times. We share a purpose and acommitment—making TVA better for the people of theJill M. MatthewsDeputy Inspector General Performing theDuties of the Inspector GeneralTennessee Valley.5

EXECUTIVE OVERVIEW6

Over these six months, nonessential TVA and TVA OIG employees remained in mandatory telework as the worldhas maintained caution during the COVID-19 pandemic. This dramatic work change has both presented challengesand opportunities as we performed our audits, evaluations, and investigative work. We have reprioritized ourplans, modified our approaches, implemented and learned new technologies, and adjusted our “normal” to maintainmomentum in reporting on opportunities for TVA to improve effectiveness and efficiency and prevent and detect fraud,waste, and abuse. Despite all of these necessary changes, TVA has continued to reap the benefit of independentoversight provided by our office to improve processes and programs, recover funds, and improve cybersecurity.AUDITSaudit of TVA’s Fiscal Year (FY) 2020 financial statements byOur audit organization includes three departments thatrelated to TVA’s 2020 Winning Performance (WP) measures.focus on contract audits, financial and operational audits,The Financial and Operational Audits section begins onand IT audits. During this reporting period, these teamspage 15 of this report.an external auditor, and (3) applied agreed-upon procedurescompleted eight audits and examinations, which identified 22,545 in questioned costs for TVA to recover andnearly 3.5 million in funds the company could put toIT Auditsbetter use. We also identified several opportunities forIT Audits completed audits of TVA’s (1) IT securityTVA to improve the effectiveness and efficiency of itspractices as required by the Federal Information Securityprograms and operations.Modernization Act (FISMA) of 2014 and (2) IT contractoraccess. The IT Audits section begins on page 20 ofContract Auditsthis report.To support TVA management in negotiating procurementactions, we completed two preaward examinations of costproposals submitted by companies proposing to provideengineering, design, and construction support servicesto TVA. Our examinations identified nearly 3.5 millionof potential savings opportunities for TVA to negotiate.We also completed one compliance audit of a contractwith expenditures totaling 212.4 million for nonnuclearmodification, outage and supplemental maintenance, andtechnical support services at TVA generating plants and othersites. This audit identified potential overbillings of 22,545.The Contract Audits section begins on page 15 of this report.Financial and Operational AuditsWith a focus on financial reporting, compliance withapplicable laws and regulations, and TVA operations,we completed audits of travel expenses reimbursedwithin 50 miles of an official station and TVA purchasingcard (P-Card) usage. In addition to our audit work, we(1) assessed TVA’s Compliance with Executive Order 13950,Combating Race and Sex Stereotyping, (2) monitored the7

8

EVALUATIONSOrganizational EffectivenessOur Evaluations organization includes two groups, one ofThis group completed evaluations of four TVA organizationswhich focuses on organizational effectiveness reviews.to assess behavioral and operational factors thatDuring this reporting period, our teams completed threecould impact their organizational effectiveness. Theevaluations and four organizational effectiveness reviews,organizational effectiveness reviews included evaluationsall of which identified opportunities for improvement.of SQN RP and three business units in TVA’s CommercialEnergy Solutions group. The Organizational EffectivenessEvaluationssection begins on page 24 of this report.The Evaluations group completed three evaluationsduring this semiannual period. These includedINVESTIGATIONSevaluations of the maintenance of coal combustionThis reporting period, we opened 75 cases and closed 90.residual storage facilities, the turnover of projectsOur investigative results include more than 3.6 millionto TVA’s Power Operations, and TVA’s response toin restitution to TVA and others, costs avoided by TVA,COVID-19. The Evaluations section begins onand waste identified; significant process improvements;page 22 of this report.prosecutive action on two temporary living allowancecases; and continued prosecution of an environmentalcase. The Investigations section begins on page 28of this report.STATISTICAL HIGHLIGHTSOctober 1, 2020 – March 31, 2021Audit Reports Issued8Evaluations Completed7Questioned Costs 22,545Questioned Costs Agreed to by TVA 22,545Questioned Costs Recovered by TVA 607,312Funds to be Put to Better Use 3,455,000Savings Realized by TVA 5,779,000Investigations Opened75Investigations Closed90Recoveries/Fees 2,056,407Projected Savings to TVA 1,144,089Waste/Other Monetary Loss 429,414Criminal Forfeitures Ordered 0Criminal Actions3Administrative Actions (Number of Subjects)99

ORGANIZATIONJill M. MatthewsDeputy Inspector GeneralPerforming the Duties ofthe Inspector GeneralLEGAL COUNSELINVESTIGATIONSAUDITS & EVALUATIONSADMINISTRATIONW. David WinsteadLegal CounselNancy J. HollowayAssistant Inspector General,InvestigationsDavid P. WheelerAssistant Inspector General, Audits & EvaluationsTerri BeattyDirector,Organizational Effectiveness& IT ServicesJeffrey T. McKenzieDeputy Legal Counsel/Whistleblower ProtectionCoordinatorJames E. HunterSpecial Agent in ChargeCurtis C. HudsonDeputy Assistant InspectorGeneral, AuditsGregory R. StinsonDeputy Assistant InspectorGeneral, EvaluationsKris D. KeenManager,IT ServicesMeagan SandsSpecial Agent in ChargeChad B. BubeDirector,Contract AuditsLisa H. HammerDirector,Organizational EffectivenessBeth D. RitterManager, Human Resources& Resource ManagementL. Suzanne AllinManager,Investigative Analytics andServicesSarah E. HuffmanDirector,IT AuditsE. David WillisDirector,EvaluationsDavid S. ShieldsManager,Audit and Evaluation QualityRick C. UnderwoodDirector, Financial &Operational Audits10

Since 1985, the OIG has worked to help TVA become better. Through our audits, evaluations, and investigations, weprovide TVA management, the TVA Board, and Congress with an independent look at the economy, efficiency, andeffectiveness of TVA programs and help prevent and detect fraud, waste, and abuse. Over the years, the OIG hashelped TVA save or recover millions of dollars and recommended numerous program improvements. We credit oursuccess to the efforts of our hardworking and talented staff and the professional responsiveness of TVA managementto our recommendations.TVA OIG OFFICE LOCATIONSAUDITS AND EVALUATIONSThe OIG has a work philosophy of being in the right placeThe Audits and Evaluations teams perform a wideat the right time to do the best work possible. We supportvariety of engagements designed to promote positivethat philosophy by encouraging our OIG employees tochange and provide assurance to TVA stakeholders.work where they can be most effective whether that is inBased upon the results of these engagements,one of our physical offices, in the field, or in one of ourthe Audits and Evaluations organizations makevirtual offices that enable our employees to telework fromrecommendations to enhance the effectiveness andhome or while traveling. Our philosophy has served usefficiency of TVA programs and operations.well since the scope of COVID-19 restrictions becameclear early in 2020.The organizations use an impact- and risk-based approachto develop an annual work plan. In developing the plan,The OIG has strategically located its offices near allthe OIG considers TVA’s strategic plans, major managementmajor TVA offices throughout the Tennessee Valley.challenges, TVA’s enterprise risk management process,We are headquartered in TVA’s Knoxville Office Complexand other input from TVA management. This planningoverlooking the downtown area. The OIG has field offices inmodel also evaluates each potential engagement fromChattanooga, Tennessee, where members of the Evaluationsthe standpoint of materiality (i.e., costs or value ofand Financial and Operational Audits departments andassets), potential impact, sensitivity (including public andseveral special agents are located. Special agents are alsocongressional interest), and the likelihood it will result inlocated in Nashville, Tennessee, and Huntsville, Alabama.recommendations for cost savings, recovery of dollars, orAdditionally, we have office locations at Watts Bar Nuclearprocess improvements. The result of the OIG Audits andPlant in Spring City, Tennessee, and Sequoyah Nuclear PlantEvaluations planning process is a focus on the issues ofin Soddy Daisy, Tennessee. Staff work in these locations ashighest impact and risk to TVA.needed. As of March 31, 2021, the OIG had a total staffof 103 employees.These issues vary depending on the objectives ofthe project. The graphic on page 12 shows someADMINISTRATIONrepresentative examples of issues our audit andevaluation projects are commonly designed to identify.The Administration team works closely with the InspectorGeneral (IG), Deputy IG, and Assistant IGs to address theday-to-day operations of the OIG and to develop policiesand procedures designed to drive and enhance productivity,quality, and compliance, and achieve office goals.Responsibilities include personnel administration, internalassessments, budget and financial management, purchasingand contract services, facilities coordination, training-eventplanning, communications facilitation, and IT support.11

TYPES OF AUDIT & EVALUATION ISSUESFinancial and Operational Audits Program Inefficiencies/IneffectivenessLegal/Regulatory NoncompliancePolicy NoncomplianceInternal Control DeficienciesFraudIT Audits Internal Control DeficienciesPolicy NoncomplianceIntegrity of Data and AssetsCybersecurityFraudEvaluations Operational InefficiencyPolicy NoncomplianceLegal/Regulatory NoncomplianceFraudOrganizational Effectiveness Operational IneffectivenessCultural Areas for ImprovementUnmitigated RisksFraudContracts Audits Inflated ProposalsContract OverpaymentsInferior PerformanceFraudThe Audits team conducts performance audits of IT Audits has lead responsibility for audits relatingTVA programs and operations, providing an inclusiveto the security of TVA’s IT infrastructure, applicationpicture of TVA’s overall fiscal and operational health.controls, and general controls associated withThe organization is made up of three departments—TVA systems. This department also performsContract Audits, Financial and Operational Audits, andoperational audits of the effectiveness ofIT Audits. The Audits organization performs its work inIT-related functions.accordance with Government Auditing Standards. Contract Audits has lead responsibility for contractcompliance audits and preaward examinations.In addition, this department performs audits ofTVA contracting processes and provides claimsassistance as well as litigation support. Financial and Operational Audits is responsiblefor performing audit work mandated by legislation,agreed-upon procedures, as well as risk-basedaudits associated with TVA financial andoperational activities. The work stems largely frommandated activities, review of TVA’s business-riskenvironment, consideration of emerging issues, andrequests. This department also provides oversightof the TVA external auditor’s compliance withprofessional standards.12The Evaluations team assesses both operationaland cultural aspects of programs and departmentsthroughout TVA to ensure objectives and operationalfunctions are achieved effectively and efficiently. Thisorganization is made up of two departments—Evaluationsand Organizational Effectiveness. This organizationperforms its work in accordance with Quality Standards forInspection and Evaluation as prescribed by the Council ofthe Inspectors General on Integrity and Efficiency (CIGIE). Evaluations performs both comprehensive reviewsand more limited-scope policy and program reviewsto monitor compliance and assess the efficiency andeffectiveness of operations.

Organizational Effectiveness performs risk-basedprojects and assignments, including interagency lawreviews to assess operational and cultural areas,enforcement task forces on terrorism, the environment,including behavioral and operational factors thathealth care, and public corruption. The graphic showscould impact an organization's ability to achieve itsthe major categories of investigations.mission and goals.INVESTIGATIONSLEGALThe OIG Legal Counsel team monitors existing andThe Investigations team proactively and reactivelyproposed legislation and regulations that relate to theuncovers activity related to fraud, waste, and abusemandate, operations, and programs of the OIG and TVA.in TVA programs and operations. This organizationAdditionally, this team provides legal advice as neededperforms its investigations in accordance with thefor administrative, audit, evaluation, and investigativeQuality Standards for Investigations as prescribed byprojects. OIG attorneys serve as ethics officials,CIGIE, applicable U.S. Attorney General Guidelines,providing OIG employees guidance on governmentand other guiding documents. OIG special agentsethics and standards of conduct. The TVA Whistleblowermaintain liaisons with federal and state prosecutorsProtection Coordinator is also a part of this team andand notify the U.S. Department of Justice whenever theprovides information regarding the statutory protectionsOIG has reason to believe there has been a violation ofagainst retaliation for all TVA employees.againstfederal criminal law. Special agents partner with otherretaliation for all TVA employees.investigative agencies and organizations on special13

SUMMARY OFREPRESENTATIVEAUDITS14

During this semiannual reporting period, the TVA OIG audit organization completed eight audits and examinations.This work identified 22,545 in questioned costs for TVA to recover and nearly 3.5 million in funds the company couldput to better use. We also identified several opportunities for TVA to improve the effectiveness and efficiency of itsprograms and operations.CONTRACT AUDITSTVA’s Compliance with Executive Order 13950, CombatingPreaward Contract ExaminationsTVA’s FY 2020 financial statements by an external auditor,To support TVA management in negotiating procurementactions, we completed two preaward examinations of costproposals submitted by companies proposing to provideengineering, design, and construction support servicesto TVA. Our examinations identified nearly 3.5 millionof potential savings opportunities for TVA to negotiate.The savings opportunities were primarily related tooverstated labor markup rates for the recovery of thecompanies’ indirect costs.Contract Compliance ReviewsDuring this semiannual period, we completed onecompliance audit of a contract for nonnuclear modification,outage and supplemental maintenance, and technicalsupport services at TVA generating plants and other sites.We audited approximately 212.4 million in costs billedto TVA by the contractor for calendar year 2019. Wedetermined the costs billed by the contractor generallycomplied with the contract terms except for 22,545 inpotential duplicated daily craft labor billings. The contractoragreed to provide a credit to TVA for the duplicate billings.Race and Sex Stereotyping, (2) monitored the audit ofand (3) applied agreed-upon procedures related toTVA’s 2020 WP measures.Travel Expenses Reimbursed Within50 Miles of Official StationWe included an audit of TVA’s travel expenses reimbursedwithin 50 miles of an official station in our annual planbecause of issues of noncompliance with TVA policies andprocedures identified during our audit of TVA executivetravel.¹ Our audit objective was to determine if travelexpenses reimbursed within 50 miles of an official stationcomply with Federal Travel Regulation and TVA policiesand procedures. Our audit scope included approximately 500,000 of travel expenses within 50 miles of aTVA employee's official duty station occurring fromOctober 1, 2018, through March 26, 2020. In summary,we found: TVA’s approval process did not ensure expenses fortravel within 50 miles of an official station compliedwith TVA’s Travel policy. Specifically, we foundemployees were reimbursed through TVA’s ExpenseReimbursement System (ERS) without preauthorizationFINANCIAL AND OPERATIONAL AUDITSDuring this semiannual period, Financial and OperationalAudits completed audits of travel expenses reimbursedwithin 50 miles of an official station and TVA P-Cardusage. In addition to our audit work, we (1) assessed1and/or documentation required. In addition, some ofthese reimbursements were not coded as businessmeeting or mission operational expenses and did nothave the required documented approval as requiredby the Travel policy.Audit Report 2018-15573, Executive Travel, September 11, 2019.15

TVA entered into a Memorandum of Understandingwith TVA’s P-Card policies and procedures. Our auditwith the International Brotherhood of Electricalscope included approximately 79.8 million in transactionsWorkers that states TVA will pay a reduced per diemfrom October 1, 2017, through September 30, 2019.for lodging, meals, and incidentals to employees whoare assigned to a board town,² which is 40 miles orOur audit found multiple instances where TVA personnel didmore from their home of record or abode, and whonot comply with requirements in TVA’s P-Card policies andutilize temporary accommodations. TVA does notprocedures. Specifically, we found the following areas ofhave documented procedures to ensure flat-rate-travelnoncompliance with policy requirements:reimbursements are being verified appropriately orreimbursed properly. As a result, six employeesimproperly received flat-rate, per diem reimbursementstotaling over 50,000 for travel within 40 miles of theirofficial station. TVA’s human resources system had incorrect officialstations shown for 25 of 74 employees included in our Some approving officials were not performing theirreview duties properly. Approximately 847,000 of P-Card statementswere not approved. Approximately 48 million, or 60 percent, ofapproved statements were not approved in asamples. We noted the Travel policy provides limitedtimely manner.guidance addressing the assignment and review ofofficial stations.TVA’s Corporate Accounting management agreed with ourrecommendations to update the Travel policy to addressthe issues identified and to reinforce the policy for travelreimbursements within 50 miles of an official station toapproving officials and approval delegates. TVA’s HumanResources management agreed with our recommendationto correct assignment of official stations in the humanresources system and develop specific guidance onassigning and periodically reviewing official stations. Split transactions occurred. Disallowed and questionable (nonbusiness expense)transactions occurred. Only 25 percent of TVA’s cardholders and approvingofficials completed the required annual P-Cardtraining at least once between October 1, 2017, andSeptember 30, 2019. Periodic audits of P-Card transactions by SupplyChain were not performed.Purchasing Card Usage Certain potentially fraudulent transactions byWe included an audit of TVA’s P-Card usage in our annualone cardholder had not been identified due toplan based on (1) findings from several OIG audits³ thatinadequate reviews of the cardholder statements.indicated potential issues and/or misuse of P-Cards andOIG Investigations subsequently found evidence the(2) the findings and recommendations of the CIGIE,cardholder had used the P-Card to make severalReport on the Government Purchase Card Initiative. Ourmonthly rental payments to the apartment complexaudit objective was to determine if TVA personnel compliedwhere the cardholder lived.2According to TVA Labor Relations, board town refers to the closest town that provides lodging and meals for those in travel status in relation to thearea where work is being performed.3Audit Report 2014-15228, TVA Corporate Card, December 10, 2015.Audit Report 2016-15424, Tax Payments Made on TVA Credit Cards, March 30, 2017.Audit Report 2018-15573, Executive Travel, September 11, 2019.16Audit Report 2019-15624, Employee Recognition Expenditures, September 17, 2019.

Lagoon Creek Gas Plant17

Post card, circa 194018

In addition, we found P-Cards were being used withoutdetermining if sources the Supply Chain and FinancialServices policies and procedures rank ahead of theP-Card in its hierarchy were available.TVA’s Corporate Accounting and Supply Chainmanagement agreed with our recommendations tostrengthen controls and help improve compliance with theP-Card policies by (1) implementing additional proceduresand monitoring activities and (2) clarifying and updatingthe policies and related training.Agreed-Upon Procedures for TVAFY 2019 Performance MeasuresTVA’s WP Incentive Plan is a performance managementprogram designed to promote teamwork, focus oncontinued high performance, and motivate and rewardempl

Blue Ridge Dam Hiwassee Dam Apalachia Dam Fontana Dam Tellico Dam Ft. Loudoun Dam & Lock Melton Hill Dam . Tennessee Valley Authority (TVA), the people of the Tennessee Valley, and our . Energy Solutions group. The Organizationa

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