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Catalyst for Improving the Environment
Compendium of
Unimplemented Recommendations
as of September 30, 2010
Report No. 11-N-0006
October 26, 2010

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Abbreviations
ARRA
American Recovery and Reinvestment Act of 2009
CIO
Chief Information Officer
CSO
Combined Sewer Overflow
EAS
EPA Acquisition System
EPA
U.S. Environmental Protection Agency
FACT
Financing Alternatives Comparison Tool
ICR
Information Collection Rule
IGCE
Independent Government Cost Estimate
IGEMS
Inspector General Enterprise Management System
MATS
Management Audit Tracking System
NCC
National Computer Center
NETI
National Enforcement Training Institute
OA
Office of the Administrator
OAM
Office of Acquisition Management
OAR
Office of Air and Radiation
OARM
Office of Administration Resources Management
OCFO
Office of the Chief Financial Officer
OECA
Office of Enforcement and Compliance Assurance
OEI
Office of Environmental Information
OIG
Office of Inspector General
OMB
Office of Management and Budget
ORD
Office of Research and Development
OSWER
Office of Solid Waste and Emergency Response
OW
Office of Water
POTW
Publicly Owned Treatment Works
RCT
Research Coordination Team
RSL
Regional Science Liaison
SAB
Science Advisory Board
SNC
Substantial Non-Compliance
SOP
Standard Operating Procedures
TMDL
Total Maximum Daily Load

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51OSJ 3"C© o
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
October 26, 2010
MEMORANDUM
SUBJECT: Compendium of Unimplemented Recommendations as of September 30, 2010
Report No. ll-N-0006
FROM: Arthur A. Elkins, Jr. Mxvih Oiiaieh fox
Inspector General
TO:	Deputy Administrator
Assistant Administrators
Regional Administrators
General Counsel
Chief Financial Officer
Associate Administrators
Attached is the semiannual Compendium of Unimplemented Recommendations as of
September 30, 2010, prepared by the Office of Inspector General (OIG) of the U.S.
Environmental Protection Agency (EPA). This Compendium fulfills the requirement of the
Inspector General Act, as amended, to identify reports containing significant recommendations
described in previous Semiannual Reports to Congress on which corrective actions have not been
completed.
This Compendium, issued in conjunction with the Semiannual Report to Congress and as a
separate document to EPA leadership, is part of the OIG's followup strategy to promote robust
internal controls. Followup is done in collaboration with the EPA Office of the Chief Financial
Officer and EPA Audit Followup Coordinators. The goal is to improve overall audit management
by helping EPA managers gain a greater awareness of outstanding agreed-to commitments for
action on OIG report recommendations. Implementing these recommendations will correct
weaknesses, reduce vulnerabilities to risk, and leverage opportunities for improved performance.
The significance of audit followup, as described by the Office of Management and Budget
(OMB) Circular A-50, is enhanced by the public's expectation for greater transparency and a
heightened interest by Congress in realizing potential opportunities for improvement in the

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Federal Government. The OIG's previous Compendium reports appear to be having the intended
effect of increasing Agency awareness and action on unimplemented OIG recommendations.
We selected the unimplemented recommendations listed in this Compendium based on their
significance and their status in EPA's Management Audit Tracking System. In addition, some
unimplemented recommendations were identified through review by the OIG. Exclusion from
the Compendium does not indicate the OIG determined the corrective action to be complete for a
recommendation. However, it is a goal of the OIG to verify as many significant
recommendations reported as being complete as possible through other reviews.
According to OMB Circular A-50, audit followup is a shared responsibility between the Agency
and the OIG. We will continue to identify unimplemented recommendations for attention and
action, as well as remove the listing of recommendations as unimplemented when appropriate
information of completion is provided. We hope that you find this tool useful in identifying ways
to further improve Agency operations.

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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Table of Contents
Introduction		1
Unimplemented Recommendations		4
OIG Report Number
10-P-0065 		4
10-R-0057 		5
10-P-0002 		6
09-P-0223 		8
09-P-0197 		9
08-P-0213 	;		10
08-P-0141 		11
08-P-0049 			12
2007-P-00036		13
2007-P-00017 		15
2007-P-00008		17
2006-P-00007 		18
2005-P-00010 		19
2004-P-00030 		21
2002-P-00012 		22
Appendix A: OIG Reports with Unimplemented Recommendations by
Program Office as of September 30, 2010 		23
Appendix B: Unimplemented Recommendations:
Current Compendium Compared to 04/28/10 Compendium		25

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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Introduction
Purpose
The purpose of this Compendium of Unimplemented Recommendations is to highlight for
U.S. Environmental Protection Agency (EPA) management significant recommendations that
remained unimplemented past the due date agreed upon by EPA and the Office of Inspector
General (OIG). In addition, the Compendium satisfies part of Section 5(a) of the Inspector
General Act of 1978, as amended, which requires each inspector general to issue semiannual
reports to Congress and include "an identification of each significant recommendation described
in previous semiannual reports on which corrective action has not been completed." This
Compendium is being issued in conjunction with the OIG Semiannual Report to Congress for the
reporting period April 1, 2010 through September 30, 2010. The OIG intends to issue this
Compendium each semiannual reporting period. The Compendium will keep Agency
management informed about EPA's outstanding commitments and its progress in taking agreed-
upon corrective actions on OIG recommendations to improve programs and operations.
Background
Recommendations are issued by EPA's OIG to improve the economy, efficiency, effectiveness,
or integrity of EPA programs and operations. Office of Management and Budget (OMB) Circular
A-50, Audit Followup, affirms that corrective action taken by management on resolved findings
and recommendations is essential to improve the effectiveness and efficiency of government
operations, and that audit followup is a shared responsibility of agency management officials and
auditors.
OMB Circular A-50 requires each agency to establish systems to ensure the prompt and proper
resolution and implementation of audit recommendations. EPA Order 2750, based on OMB
Circular A-50, details EPA's policy and procedures on audit followup. The chief financial officer
is the Agency audit followup official and has responsibility for Agency-wide audit resolution and
ensuring action officials implement corrective actions. EPA uses the Management Audit
Tracking System (MATS) to track information on Agency implementation of OIG
recommendations. The Office of the Chief Financial Officer maintains and operates MATS.
MATS receives report data, such as the report title, issue date, and recommendations from the
Inspector General Enterprise Management System (IGEMS).
The audit management official in the Office of the Administrator, the Office of General Counsel,
and each assistant administrator's or regional administrator's office, designates an audit followup
coordinator for that office. Audit followup coordinators are responsible for quality assurance and
analysis of tracking system data. When corrective actions in response to recommendations in an
audit report are completed and certified, the Agency may inactivate that report in MATS and it is
no longer tracked by the audit followup coordinator. The Agency self-certifies that corrective
actions are completed. The Agency is also responsible under the Inspector General Act for
1

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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11 -N-0006)
reporting on audit reports for which final corrective action has not been taken one year or more
after the Agency's management decision.
This is the fifth edition of the Compendium of Unimplemented Recommendations. It identifies
18 unimplemented recommendations from 15 reports compared to 34 unimplemented
recommendations from 18 reports identified in the fourth edition for the period ending March 31,
2010. Of the 18 unimplemented recommendations currently reported, 8 from 6 reports are
continuing, and 10 from 9 reports are newly identified. Also, we removed 26 unimplemented
recommendations from 14 reports that were included in the previous Compendium. Please note
that removal of an unimplemented recommendation does not imply that it was verified as
implemented, but rather, that it was reported as being completed or that the target completion
date has been revised with OIG approval.
Scope and Methodology
Due to our limited scope and purpose, we did not conduct our work in accordance with all
generally accepted government auditing standards issued by the Comptroller General of the
United States. Specifically, we did not evaluate management controls, determine compliance
with laws and regulations, or develop findings and recommendations. Further, we did not
thoroughly assess the validity and reliability of data obtained from the Agency's MATS, which
is used by EPA to track audit followup information. Although MATS was our primary source for
identifying unimplemented recommendations, we did perform additional steps to search for
unimplemented recommendations that may not have been identified in MATS.
We reviewed selected audit and evaluation reports issued by the EPA OIG from October 1, 1997,
through March 31, 2010, to identify significant unimplemented recommendations for inclusion in
the Compendium. However, we did not identify any significant unimplemented recommendations
for Fiscal Years 1997 through 2001. We did not review recommendations from reports without an
OIG agreement on the Agency's corrective action plan (Management Decision). A list of these
reports can be found in Appendix 2 of the OIG Semiannual Report to Congress.
We excluded recommendations with future milestone dates for action. Some unimplemented
recommendations that were excluded from this Compendium may, upon further review, be
included in the next Compendium. A recommendation's exclusion from the Compendium does
not indicate our determination that the recommendation has been implemented. We limited the
unimplemented recommendations to those we believe are significant because they could have a
material impact on the economy, efficiency, effectiveness, or integrity of EPA programs and
operations. For this purpose, we define significant recommendations in the following terms:
•	Economy: Opportunity to save, prevent loss, or recover at least $500,000 in monetary
costs or value
•	Efficiency: Improvement in the process, capacity, accessibility, or delivery of program
objectives and the elimination of unnecessary or unproductive actions or expenses
•	Effectiveness: Improvement in the quality of, or reduction in the risk to, public health
and the environment
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Compendium of Unimplemented Recommendations as of September 30, 2010
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• Integrity: Improvement in operational accountability, enforcement of and compliance
with laws and regulations, and security of resources for public confidence
The following EPA offices have unimplemented recommendations listed in this Compendium:
Office of Administration and Resources Management (OARM)
Office of Air and Radiation (OAR)
Office of Enforcement and Compliance Assurance (OECA)
Office of Environmental Information (OEI)
Office of Water (OW)
Region 3
Region 8
We anticipate that the Agency will provide updates in MATS on the status of each
unimplemented recommendation, including a description of progress and an explanation of the
delay in completing an agreed-to action.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Unimplemented Recommendations
Action Office: OARM
Report Title: EPA Can Improve Its Preparation and Use of Independent Government Cost
Estimates for Superfund Contracts
Report No.:	10-P-0065
Date Issued: 2/16/2010
Report Summary
EPA can improve its Superfund Independent Government Cost Estimates (IGCEs) and the
corresponding cost estimating process. In 30 of the 42 cases we reviewed, EPA did not
sufficiently document information in its Superfund IGCEs. Additionally, in 9 of the 42 cases,
EPA did not update the IGCEs when significant changes occurred. In 8 of the 42 cases, EPA
program staff accepted the contractor's estimate without evaluating why it differed from the
IGCE. Finally, in some cases EPA did not prepare an IGCE for actions with a potential value in
excess of $100,000, the Federal Acquisition Regulation threshold for simplified acquisitions.
These actions are contrary to the Government Accountability Office Cost Estimating and
Assessment Guide and the EPA Contracts Management Manual. They occurred because there is
an overall lack of emphasis by EPA management on the preparation and use of IGCEs. EPA
limits its ability to negotiate a fair and reasonable price when it does not have a well-supported
IGCE. The report was issued to OARM and the Office of Solid Waste and Emergency Response
(OSWER). OSWER has no past-due corrective actions recorded in MATS.
Unimplemented Recommendations
Recommendation 2-5: We recommend that the assistant administrator for OARM and the
assistant administrator for OSWER instruct the Office of Acquisition Management (OAM)
and the Superfund program office to provide training to Superfund program staff on IGCE
tools and databases, as well as OAM and Superfund IGCE guidance.
Status: OARM agreed that it would work closely with OSWER to provide training to the
Superfund program and OAM staff on the IGCE guidance by September 30, 2010.1
1 Subsequent to the close of field work, OARM updated MATS to reflect a completion date of July 2010 for this
corrective action.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office: OW
Report Title: EPA Needs Definitive Guidance for Recovery Act and Future Green Reserve
Projects
Report No.: 10-R-0057
Date Issued: 02/01/10
Report Summary
EPA has not provided clear and comprehensive guidance to states for how to determine the
eligibility of green reserve projects. EPA was promoting a green approach to wastewater and
drinking water programs for at least a year prior to the enactment of the American Recovery
and Reinvestment Act of 2009 (ARRA). Despite that experience, EPA did not develop and
issue clear and comprehensive guidance in time to meet many of the states' needs. For
example, EPA did not provide guidance on how to solicit and select green projects until after
many states had finished doing so. Some states felt the need to resolicit for green projects while
others did not.
EPA's guidance and subsequent updates have not addressed important aspects of project
selection. At the time of this review, EPA had not established water and energy efficiency
threshold ranges for many types of green projects. Also, the Agency still had not provided
sufficient information to states on how to develop business case justifications for noncategorical
projects. Moreover, changes over time in EPA's guidance for how to determine project eligibility
resulted in EPA regions applying different standards for approving states' green project
proposals.
EPA cannot provide a reasonable assurance that its green reserve projects will meet
Congress's objectives without issuing guidance that sets definitive expectations.
Additionally, future green funding may face similar issues.
Unimplemented Recommendations
Recommendation 1: "We recommend that the assistant administrator for OW develop and revise
guidance, information, and, as appropriate, specific criteria that states can employ to assist them
in identifying projects qualifying for funding from the state's green project reserve.
Status: OW indicated that it completed multiple actions within the 12-month deadline of
ARRA enactment that were successful in achieving approximately 30 percent Green
Project Reserve funding for both Clean Water and Drinking Water State Revolving
Funds, well above the 20 percent requirement contained in the statute. OW also
developed guidance for regions and states to the Green Project Reserve requirements of
EPA's FY 2010 appropriation and issued additional guidance on business cases provided
in the appropriation. OW planned to develop eight example business cases for the
Drinking Water State Revolving Fund and two fact sheets by July 2010.2
2 Subsequent to the close of field work, OW informed us that the business cases are being finalized and will be
released before the Council of Infrastructure Financing Authorities conference in November 2010. OW also
indicated that four fact sheets are being drafted or reviewed.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office: OARM
Report Title: Review of Hotline Complaint on Employee Granted Full-Time Work-at-Home
Privilege
Report No.:	10-P-0002
Date Issued: 11/7/09
Report Summary
We found an unauthorized, full-time work-at-home arrangement that existed for 9 years and
allowed a National Enforcement Training Institute (NETI) employee to work from home in Ohio
instead of an office in Washington, DC. The employee and position were originally located in
the Washington area and the employee later moved as the result of a spouse transfer. In our
opinion, NETI's actions are for the benefit of a single employee as opposed to being primarily in
the interest of the government, and this action was not equitably provided within NETI. EPA has
no established or consistent policy, procedure, or criteria for granting full-time work-at-home
privilege. Full-time work-at-home opportunity appears to be preferentially available to only a
few employees. Neither OARM nor NETI has any written documentation showing the
government interest in or appropriateness of making this arrangement, or that senior OARM
officials approved this action.
Office of Human Resources personnel (the associate deputy director of program management
and communications and the Agency telework coordinator) stated that EPA became aware of
similar arrangements due to research it performed for an unrelated court case. OARM raised
concerns about equity in such arrangements and believes this must be brought under control. To
date, OARM has not corrected this situation.
Unimplemented Recommendations
Recommendation 2(a): We recommend that the assistant administrator for OARM establish and
implement Agency policy for all EPA employees that clearly articulates the process and
procedures for changing an employee's duty station to a location geographically separate from
the position of record. This policy should include eligibility criteria for positions and personnel,
records management requirements, periodic review and reauthorization, verification of correct
pay rate (locality and grade), and specific approvals required from initial submission to final
approval to ensure equity. The policy should require the assistant administrator for OARM to be
the final decision authority for all geographically separate duty station locations authorizations
except those duty station location changes initiated within OARM.
Status: OARM has been considering the connections between alternate duty location
policy parameters and the Agency's telework policy. OARM's analysis suggests that
there are compelling advantages to addressing the two policies in an integrated fashion.
The agreed-to date for completing a policy addressing alternate duty location was
March 31, 2010.
Recommendation 2(b^: We recommend that the assistant administrator for OARM identify and
review all existing arrangements of full-time work-at-duty station separate from the position of
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Compendium of Unimpfemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
record, including the situation that was the subject of this review, and bring each of these
arrangements into compliance with implemented EPA policy.
Status: OARM planned to identify and review each situation where employees work at a
duty station separate from the position of record to determine the most appropriate next
steps, working to bring each case into compliance with the policy mentioned in 2(a).
OARM agreed to complete this action within 6 months of the final promulgation of the
new policy. The agreed-to completion date was September 30, 2010.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office: OW
Report Title: EPA Needs to Accelerate Adoption of Numeric Nutrient Water Quality
Standards
Report No.:	09-P-0223
Date Issued: 08/26/2009
Report Summary
EPA's 1998 National Strategy and Plan to promote state adoption of nutrient water quality
standards (which better protect aquatic life and human health) have been ineffective. In 1998,
EPA stated that a critical need existed for improved water quality standards, given the number of
waters that were impaired from nutrients. In the 11 years since EPA issued its strategy, half the
states still had no numeric nutrient standards. States have not been motivated to create these
standards because implementing them is costly and often unpopular with various constituencies.
EPA has not held the states accountable to committed milestones. The current approach does not
assure that states will develop standards that provide adequate protection for downstream waters.
Until recently, EPA has not used its Clean Water Act authority to promulgate water quality
standards for states.
EPA cannot rely on the states alone to ensure that numeric nutrient standards are established.
EPA should prioritize states/waters significantly impacted by excess nutrients and determine
whether it should set the standards. EPA also needs to establish effective monitoring and
measures so that accurate program progress is reported. This will assist EPA management in
program decisionmaking.
Unimplemented Recommendations
Recommendation 2-1: We recommend that the assistant administrator for OW select significant
waters of national value which need numeric nutrient water quality standards to meet the
requirements of the Clean Water Act.
Status: OW developed a list of selection factors to consider when identifying and
prioritizing states and waters that need numeric nutrient water quality standards to meet
the requirements of the Clean Water Act. OW is developing a Nutrient Screening Tool
that includes state-specific data for each factor so that EPA can apply these factors to
compare states on a national basis with regard to the risk and impact of nutrient
impairment and a state's progress towards mitigating nitrogen and phosphorus pollution.
The tool will help EPA to evaluate whether numeric nutrient criteria are necessary for a
given state and to prioritize states for possible Clean Water Act section 303(c)
determinations. OW also agreed to assess availability of resources and determine the
number of evaluations and possible determinations that can be funded. The agreed-to
completion date was May 31, 2010. Additional time was needed to refine the selection
factors and to collect and verify the state data. A meeting with the OW deputy assistant
administrator for approval of the tool and assessment of resources is scheduled for
October 25, 2010.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11 -N-0006)
Action Office: OARM
Report Title: EPA Should Delay Deploying Its New Acquisition System until Testing Is
Completed
Report No.:	09-P-0197
Date Issued: 07/20/09
Report Summary
OAM did not comply with EPA's System Life Cycle Management policy and procedure while
developing the new EPA Acquisition System (EAS). OAM did not fully develop the system's
requirements documents during the requirements phase and requirements were incomplete. Test
scripts were not developed to prove that the system fulfilled all requirements and ensure that the
system would function as required. Although the EAS Project Manager developed a Draft Master
Test Plan that contained testing procedures, OAM management never approved, implemented,
and enforced this plan.
OAM management did not provide the oversight, authority, and support necessary to ensure the
EAS development project complied with EPA's System Life Cycle Management policy and
procedure. Because OAM had not completed the steps needed to reasonably ensure that EAS
would meet EPA's business needs if implemented as planned by June 29, 2009, OAM does not
have a sound basis for deploying EAS as scheduled. More management emphasis is needed to
ensure the system development control environment achieves the desired results and the end
product meets EPA's needs.
Unimplemented Recommendations
Recommendation 1: We recommend that the assistant administrator for OARM identify and
document all system requirements, including functional, technical, security, and EPA-specific
requirements, in the EAS Requirements Document(s).
Status: OARM planned to update the Requirements Baseline with approved new and
detailed requirements and update the Requirements Traceability Matrix with new detailed
requirements from updated Requirements Baseline. The agreed-to completion date was
October 21, 2009.3
3 Subsequent to the close of field work, OARM updated MATS to reflect a completion date of January 15,2010, for
this corrective action.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office: Region 8
Report Title: Oglala Sioux Single Audits—Corrective Actions Taken but Improvements
Needed in Resolving Costs
Report No.:	08-P-0213
Date Issued: 07/28/2008
Report Summary
EPA Region 8 continues to take actions to resolve the internal control findings in the single audit
reports. Region 8 identified the Oglala Sioux Tribe as high risk, requested a corrective action
plan, and reviewed the tribe's accounting documentation. However, Region 8 did not monitor
implementation of the corrective actions in MATS until all actions were completed. As a result,
the Agency was not accurately reporting on its status of implementing corrective actions
resulting from audit reports.
Region 8 did not obtain sufficient documentation to support resolving $2.5 million in questioned
costs. The documentation for resolving the questioned costs was not from the Oglala Sioux
Tribe's official accounting system and did not reconcile to the costs claimed. Region 8 did not
resolve these issues before concluding that the tribe did incur the costs. Without sufficient
documentation to support resolving questioned costs, the region cannot ensure those costs were
allowable under the EPA grants.
Unimplemented Recommendations
Recommendation 1: We recommend that the Region 8 administrator track the remaining
corrective action that the Oglala Sioux Tribe has not implemented in MATS, or submit a revised
corrective action plan to the OIG for evaluation.
Status: Region 8 agreed to arrange for ongoing training and technical assistance for the
accounting staff and to establish a line item in indirect cost budget for internal auditing
services. Region 8 agreed to track progress on these actions in MATS and the agreed-to
completion dates for these two actions were December 31, 2006, and September 30,
2006, respectively.
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Compendium of Unimplemented Recommendations as of September 30, 2010
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Action Office: OECA
Report Title:	EPA Needs to Track Compliance with Superfund Cleanup Requirements
Report No.:	08-P-0141
Date Issued:	04/28/2008
Report Summary
According to EPA's Superfund information system, there were 3,397 active Superfund
enforcement instruments to ensure cleanups at NPL sites as of September 30, 2007. Yet, EPA
does not nationally compile or track data on substantial non-compliance (SNC) with the terms or
requirements of these instruments. Therefore, we were not able to fully determine whether the
regions have resolved Superfund instrument violations consistent with criteria and authorities. In
2000, EPA recognized it needed to improve in this area. It issued an internal report
recommending that the regions improve their data on the compliance status of Superfund
enforcement instruments and responses to non-compliance. However, EPA has not implemented
this recommendation. Consequently, the Agency lacks the internal controls necessary to monitor
compliance with Superfund instruments nationally.
In a limited review of EPA regions' enforcement records, we found that two regions'
enforcement actions, in 12 instances of SNC, were consistent with EPA guidance and authorities.
While the regions took appropriate actions to address these 12 violations, Region 5 had not
established necessary and enforceable requirements to address contamination from the Muskego
Landfill Site, in Waukesha County, Wisconsin. The report was issued to OECA and Region 5.
Region 5 has no past-due corrective actions recorded in MATS.
Unimplemented Recommendations
Recommendation 4: We recommend that the assistant administrator for OECA establish
parameters or metrics that indicate an acceptable range of performance or circumstances
requiring explanation.
Status: OECA will establish a metric for the range of acceptable performance and a
threshold for when regions will be required to substantiate why the SNC threshold was
exceeded. OECA will pull data to evaluate the regions mid-year. The agreed-to
completion date for the mid-year evaluation was April 30,2010. Subsequent to the due
date, OECA recognized that it needed more time and extended the completion date to
October 31, 2010, without the required OIG approval.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office: Region 3
Report Title: Despite Progress, EPA Needs to Improve Oversight of Wastewater Upgrades in
the Chesapeake Bay Watershed
Report No.: 08-P-0049
Date Issued: 01/08/2008
Report Summary
Nutrient overload has been identified as the primary cause of water quality degradation within
the Chesapeake Bay. Wastewater treatment facilities are responsible for approximately
20 percent of nutrient discharges into the Bay. At the request of a United States senator for the
State of Maryland, the OIG sought to determine how well EPA is assisting its Chesapeake Bay
partners in cleaning up the bay. This report evaluates the progress in controlling discharges from
wastewater treatment facilities. We found that Chesapeake Bay wastewater treatment facilities
risk not meeting the 2010 deadline for nutrient reductions if key facilities are not upgraded in
time.
Unimplemented Recommendations
Recommendation 2-4: We recommend that the EPA Region 3 regional administrator promote
awareness of and use of the Financing Alternatives Comparison Tool (FACT) and other financial
analysis tools within the Chesapeake Bay community.
Status: Region 3 planned to continue to develop and implement webcasts on FACT for
states and grantees, streamline the FACT to make it easier to use for local governments,
and expand the existing user guide. Region 3 reports that FACT is complete and the
planned release of the user guide is October 14, 2010. The OIG approved two extensions
to the original completion date of October 1, 2008. The agreed-to completion date for the
user guide was August 31, 2010.4
4 Subsequent to the close of field work, Region 3 informed us that it completed the FACT manual on October 14,
2010.
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Compendium of Unimplemented Recommendations as of September 30, 2010
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Action Office: OW
Report Title: Total Maximum Daily Load Program Needs Better Data and Measures to
Demonstrate Environmental Results
Report No.:	2007-P-00036
Date Issued: 09/19/2007
Report Summary
EPA does not have comprehensive information on the outcomes of the Total Maximum Daily
Load (TMDL) program nationwide, nor national data on TMDL implementation activities. EPA
and states are responsible for implementing point source TMDLs; however, EPA cannot identify
all of the permitted dischargers that should receive or have received wasteload allocations.
Measuring nonpoint source TMDL implementation is difficult because EPA does not have
statutory authority to regulate nonpoint sources and it is highly dependent on state and local
stakeholders. EPA's lack of information prevents the Agency from determining the extent to
which TMDLs are restoring impaired waters and whether TMDL implementation activities are
occurring in a timely manner.
EPA has begun to take steps to measure program results and improve program data, sponsored
several studies of TMDL implementation, and is studying additional TMDL results measures.
Developing meaningful measures is challenging; however, EPA needs to provide more
management direction to improve its ability to assess how well this critical program is
functioning. The TMDL and performance measures we reviewed do not provide clear and
complete metrics of the program's accomplishments.
Unimplemented Recommendations
Recommendation 1-2: We recommend that the assistant administrator for OW demonstrate
that TMDLs are being implemented by annually reporting on the progress of TMDL
implementation activities completed nationwide including the number of TMDLs:
•	that have all wasteload allocations incorporated into NPDES permits
•	that have implemented load allocations through at least one best management
practice, funded through the Section 319 Program
•	for which implementation data are not available to EPA
Status: According to OW, it has:
Reported on TMDL implementation rates, including point source permits and
nonpoint source best management practices, through a statistical study
covering EPA Region 5.
Completed development of a national statistical study design to assess TMDL
implementation rates.
Queried EPA data systems and issued its first annual national report on the
three metrics specified in 1-2.
Produced a synthesis paper covering the findings from multiple
implementation-related studies.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
OW also planned to complete the following corrective actions:
•	Development of an information collection rule (ICR) that covers assessments of
TMDL implementation; initiate national sample-based assessment upon ICR
approval.
•	Complete a national sample-based assessment of TMDL implementation rates.
The agreed-to completion date for these actions was December 31,2009. OW met with
the OIG on September 15, 2010, to discuss waiving or modifying these final two
corrective actions due to a change in circumstances that reduces the value and
appropriateness of these actions. OW believes that the TMDL implementation has
changed markedly due to its completion of several studies that collectively provide an
understanding of TMDL implementation that was nonexistent when they proposed the
corrective action. Also, OW believes the national survey of implementation would now
be of negligible value as well as a major expense approaching $700,000. This national
survey corrective action, and the related ICR corrective action it would require, no longer
would produce findings of unique value and importance commensurate with cost.
Alternative corrective actions are under discussion between the OIG and the TMDL
program, and the TMDL program is awaiting an OIG decision regarding the proposal.
14

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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office: OEI
Report Title: EPA Needs to Strengthen Financial Database Security Oversight and Monitor
Compliance
Report No.:	2007-P-00017
Date Issued: 03/29/2007
Report Summary
The OIG completed this audit to determine whether the EPA (1) implemented and maintained
database hardware and software in accordance with EPA policy requirements; and (2) secured
critical financial information by restricting access to high-level database functions, such as
database administrator authorities.
During the examination, the OIG discovered weaknesses in how EPA offices (1) monitor
databases for known security vulnerabilities, (2) communicate the status of critical system
patches, and (3) monitor the use of and access to database administrator accounts and privileges.
These weaknesses exist because EPA had not implemented security processes to (1) actively
monitor systems that share data with the Integrated Financial Management System, (2) share and
collect information on the implementation of critical system patches, and (3) effectively manage
access controls. Without these processes, the integrity of critical data in key Office of the Chief
Financial Officer (OCFO) systems could be undermined. As a result, OCFO cannot ensure that
the integrity of the data it provides to senior Agency officials is adequately protected. The report
was issued to OEI, OCFO, and Office of Research and Development (ORD). However, OCFO
and ORD have no past-due corrective actions recorded in MATS.
Unimplemented Recommendations
Recommendation 4: OIG recommended that director of the Office of Technology Operations
and Planning within OEI strengthen, formalize, and evaluate the effectiveness of the followup
procedures for obtaining complete responses from program and regional offices regarding high-
level critical system patch alerts.
Status: OEI planned to:
(1)	Update Computer Security Incident Response Capability internal standard operating
procedures (SOP) to document the process that will be used to track and report EPA
regions/program offices' achievement of 90 percent or greater for critical patches
within two weeks of alert notification of system patches by September 30, 2008.
(2)	Communicate via e-mail and Information Security Officer conference call(s) revised
internal SOP process modifications to respective parties and advise on responsibilities
and effective date by November 15,2008.
(3)	Provide Technology Information Security Staff with a summary critical patch status
report reflecting regions/program offices that have not achieved 90 percent or greater
for critical patches within 2 weeks of initial alert by November 15, 2008.
(4)	Escalate summary reports to appropriate EPA management for immediate resolution
or agreed-to course of action and time frame to effectively mitigate identified
vulnerability by January 15, 2009.
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Compendium of UnimplementecJ Recommendations as of September 30, 2010
(Report No. 11-N-0006)
The OIG identified this recommendation as unimplemented in Report No. 10-1-0029,
Audit of EPA's Fiscal 2009 and 2008 (Restated) Consolidated Financial Statements,
dated November 16, 2009.5
5 Subsequent to the close of field work, OEI submitted a revised corrective action plan with new milestone dates for
this recommendation to the OIG for approval.
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Compendium of Unirnplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office:	OEI
Report Title:	EPA Could Improve Controls Over Mainframe System Software
Report No.:	2007-P-00008
Date Issued:	01/29/2007
Report Summary
The OIG engaged KPMG, LLP to conduct an audit of access to and modification of the EPA's
mainframe system software housed at the Agency's National Computer Center (NCC). The NCC
is located at the Research Triangle Park campus in Raleigh, North Carolina. KPMG identified
several weaknesses in EPA's internal controls over its mainframe systems software, including:
•	Roles and responsibilities were not clearly assigned.
•	Change controls were not performed in accordance with Agency policies.
•	Policies, procedures, and guides could be strengthened.
•	Security settings for sensitive datasets and programs were not effectively configured or
implemented.
As a result of these weaknesses, EPA is exposed to greater risk since its mainframe system
software could potentially be compromised.
Unirnplemented Recommendations
Recommendation 9: We recommend that the director of the Office of Technology Operations
and Planning within OEI complete efforts to update the OEI Information Security Manual and
the EPA Information Security Manual. Subsequent to finalizing the changes, ensure the manuals
are (1) reviewed timely by EPA management for adequacy, accuracy, and completeness; and
(2) approved by EPA management in a timely manner.
Status: OEI reported in MATS that resource challenges, including human resource and
acquisition resource alignments, caused the original scheduled Agency Information
Security Procedural Handbook to be delayed. Dedicated EPA staff have been assigned
and a contract has been awarded. The agreed-to completion date for this corrective action
was September 18, 2008.
As an interim stopgap while development of the handbook was being planned, the EPA
Chief Information Officer (CIO) issued CIO Policy Transmittal 08-005, Agency Network
Security Policy, on November 11, 2007. This policy provided the Agency with specific
references to various National Institute of Standards and Technology publications. OEI
plans to provide the Draft Agency Network Security Policy to the Quality and
Information Council for approval and voting on November 30, 2009.6
6
On October 13,2010, OEI submitted a revised corrective action plan with intermediate steps and new milestone
dates to the OIG. The OIG has approved the plan. Corrective action is now scheduled to be completed by March 30,
2012.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office:	OW
Report Title:	More Information Is Needed on Toxaphene Degradation Products
Report No.:	2006-P-00007
Date Issued:	12/15/2005
Report Summary
Toxaphene in the environment changes, or degrades. The resulting degradation products are
different from the original toxaphene in chemical composition and how they appear to testing
instruments, so they could go unreported. The analytical methods EPA uses to identify and
measure toxaphene are not designed to identify toxaphene degradation products. However, a new
testing method used by others specifically tests for toxaphene degradation products. We believe
EPA should validate, approve, and use this method. Certain toxaphene degradation products
accumulate inside people. Although studies indicate that some of these degradation products may
be harmful, more research is needed to determine how much of a risk these products pose to
people. The report recommendations were reported to OA, OW, OSWER, and ORD. OA,
OSWER, and ORD have no past-due corrective actions recorded in MATS.
Unimplemented Recommendations
Recommendation 2; We recommend that the administrator direct the assistant administrators
for ORD, OW, and OSWER to arrange for specific research into the dangers of tumors (i.e.,
cancer) and of harm to embryos posed principally by a mixture of toxaphene congeners and
metabolites found in fish.
Status: OW anticipated completing the third Contaminant Candidate List by August 31,
2009. Corrective action is past due for completion.7
7 OW certified that all agreed-to corrective actions have been completed as of October 8, 2010.
18

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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office: OAR
Report Title: Substantial Changes Needed in Implementation and Oversight of Title V
Permits If Program Goals Are to Be Fully Realized
Report No.:	2005-P-00010
Date Issued: 03/09/2005
Report Summary
Title V of the Clean Air Act, designed to reduce violations and improve enforcing air pollution
laws for the largest sources of air pollution, requires that all major stationary sources of air
pollutants obtain a permit to operate. More than 17,000 sources are subject to Title V permit
requirements. Our analysis identified concerns with five key aspects of Title V permits:
(1) permit clarity, (2) statements of basis, (3) monitoring provisions, (4) annual compliance
certifications, and (5) practical enforceability. One finding in particular relates to compliance
certifications and wording on credible evidence. When EPA amended the rule on continuous or
intermittent compliance, a key clause on credible evidence was inadvertently left out.
Collectively, these problems can hamper the ability of EPA, state and local regulators, and the
public to understand what requirements sources are subject to, how they will be measured, and
ultimately to hold sources accountable for meeting applicable air quality requirements. EPA's
oversight and guidance of Title V activities have resulted in some improvements in Title V
programs; however, areas needing further improvement remain.
Unimplemented Recommendations
Recommendation 2-1: We recommend that the assistant administrator for OAR develop and
issue guidance or rulemaking on annual compliance certification content which requires
responsible officials to certify compliance with all applicable terms and conditions of the permit,
as appropriate.
Status: Based on recommendations from the Clean Air Act Advisory Group Task Force
on Title V Implementation, the Office of Air Quality Planning and Standards has begun
developing a guidance document that will include, among other topics, guidance on
compliance certifications. However, as of September 30, 2010, EPA had not submitted a
formal action plan, stating how it plans to address this recommendation, to the OIG for
approval.8
Recommendation 2-2: We recommend that the assistant administrator for OAR issue the draft
rule regarding intermittent versus continuous monitoring as it relates to annual compliance
certifications and including credible evidence.
Status: EPA did not concur with this recommendation, and it remained unresolved as of
September 30, 2010. The Agency met with the OIG in July 2009 and is providing
additional information. The OIG believes this recommendation is key to knowing the
8 OAR submitted a proposed corrective action plan for Recommendation 2-1 to the OIG on October 14, 2010. The
OIG is in the process of reviewing this plan for approval.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
basis of the permittee's reported compliance with the terms and conditions of its Title V
permit that underlies its annual compliance certification.9
Recommendation 2-3: We recommend that the assistant administrator for OAR develop
nationwide guidance or rulemaking, as appropriate, on the contents of statements of basis which
includes discussions of monitoring, operational requirements, regulatory applicability
determinations, explanations of any conditions from previously issued permits that are not being
transferred to the Title V permit, discussions of streamlining requirements, and other factual
information, where advisable, including a listing of prior Title V permits issued to the same
applicant at the plant, attainment status, and construction, permitting, and compliance history of
the plant.
Status: OAR plans to work with the regions to disseminate information about the
positions EPA has taken on statements of basis in response to citizens programs and
permit petitions. OAR also intends to develop a plan for identifying and sharing with
permitting agencies those statements of basis that represent "best practices." This effort is
planned to be included in guidance documentation addressing recommendation 2-1.
However, as of September 30, 2010, EPA had not submitted a formal action plan, stating
how it plans to address this recommendation, to the OIG for approval.10
9	OAR submitted a proposed corrective action plan for Recommendation 2-2, which concurred with the
recommendation, to the OIG on October 14, 2010. The OIG is in the process of reviewing this plan for approval.
10	OAR submitted a proposed corrective action plan for Recommendation 2-3 to the OIG on October 14, 2010. The
OIG is in the process of reviewing this plan for approval.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office:	OW
Report Title:	EPA Needs to Reinforce Its National Pretreatment Program
Report No:	2004-P-00030
Date Issued:	09/28/2004
Report Summary
The reductions in industrial waste discharges to the nation's sewer systems that characterized the
early years of the pretreatment program have not endured. Since the middle of the 1990s, there
has been little change in the volume of a broad list of toxic pollutants transferred to publicly
owned treatment works (POTWs) or in the index of risk associated with these pollutants. As a
result, the performance of EPA's pretreatment program, which is responsible for controlling
these discharges, is threatened, and progress toward achieving the Clean Water Act goal of
eliminating toxic discharges that can harm water quality has stalled.
The curtailing of the early gains may be explained in part by two factors: (1) dischargers that
developed systems in response to EPA's initial program requirements have not enhanced their
pretreatment systems in recent years, and (2) the rate at which EPA has been issuing effluent
guidelines dramatically declined since 1990. Without more visible leadership from headquarters,
improved programmatic information, and the adoption of results-based performance measures,
EPA's pretreatment program is at risk of losing the gains it made in its early years.
Unimplemented Recommendation
Recommendation 4-1: We recommend that the acting assistant administrator for OW direct
staff to develop a long-term strategy to identify the data it needs for developing pretreatment
results-based measurements; determine the resources necessary to carry out the strategy; and
gain the support of other Agency, state, and POTW staff to carry out the strategy.
Status: OW agreed to request information on databases used by the EPA regions and
states to store information regarding POTW pretreatment program performance.
Through the Permitting for Results process, OW will compile information regarding
current data systems used to store pretreatment data at the EPA regional and state level.
OW intends to use this information to identify inaccurate data and target data correction
in the Permit Compliance System. Both of these activities are crucial to facilitate
migration and retention of data as we transition to the Integrated Compliance Information
System. Once these efforts are complete, OW will be able to determine a long-term
strategy based on data availability and resources, which should ultimately assist it in
developing pretreatment result-based measurements. The agreed-to completion date for
this corrective action was September 30, 2007.11
11 Subsequent to our field work, OW informed us that corrective action should be completed by April 2011 due to
delays in the implementation of the Integrated Compliance Information System.
21

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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Action Office:
Report Title:
OW
Wastewater Management: Controlling and Abating Combined Sewer
Overflows
2002-P-00012
08/26/2002
Report Number:
Date Issued:
Report Summary
Combined sewer overflows (CSOs) are the total discharges into water bodies of untreated
domestic, commercial, industrial waste, wastewater, and storm water runoff. CSOs can adversely
affect the health of humans, animals, and aquatic organisms, as well as cause beach closings and
fishing and recreational restrictions. We found that many communities do not as yet have the
data to determine the effect of CSO controls on water quality. Most communities were only
monitoring the number, volume, and duration of CSO discharges, and did not have data on the
effect CSO controls were having on the quality of receiving waters, as EPA does not require
monitoring until completion of CSO projects. Consequently, it could not be determined until it
was too late whether each CSO project being undertaken was a wise investment of taxpayers'
dollars.
Unimplemented Recommendation
Recommendation 5-1: We recommend that the assistant administrator for OW work with CSO
permitting authorities and communities to assure they negotiate and establish the proper level of
interim monitoring of CSO efforts to determine the impact of the project on water quality.
Status: OW agreed to initiate an effort at EPA headquarters to develop a compilation of
the monitoring approaches that are or may be used in different situations. This
compilation will help permit writers develop appropriate monitoring expectations for
those permittees that have completed construction of their planned CSO controls. OW
has developed guidance for developing and conducting postconstruction water quality
monitoring programs that can be used to verify compliance with water quality standards,
as well as to ascertain the effectiveness of CSO controls. This guidance was reviewed by
OW's regional offices and revised to reflect their comments. The guidance, while still in
draft, is available for use. OW intends to finalize the CSO Monitoring Guidance by
September 30, 2011, as needed based on additional comments received and as funding
becomes available to make any needed changes. The agreed-to completion date was
September 30, 2009.
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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Appendix A
O/G Reports with
Unimplemented Recommendations
by Program Office
as of September 30, 2010
OAR
2005-P-00010
Substantial Changes Needed in Implementation and Oversight of Title V Permits If Program

Goals Are to Be Fully Realized
OARM

10-P-0065
EPA Can Improve Its Preparation and Use of Independent Government Cost Estimates for

Superfund Contracts
10-P-0002
Review of Hotline Complaint on Employee Granted Full-Time Work-at-Home Privileges
09-P-0197
EPA Should Delay Deploying Its New Acquisition System until Testing Is Completed
OECA

08-P-0141
EPA Needs to Track Compliance with Superfund Cleanup Requirements
OEI

2007-P-00017
EPA Needs to Strengthen Financial Database Security Oversight and Monitor Compliance
2007-P-00008
EPA Could Improve Controls Over Mainframe System Software
ow

10-R-0057
EPA Needs Definitive Guidance for Recovery Act Future Green Reserve Projects
09-P-0223
EPA Needs to Accelerate Adoption of Numeric Nutrient Water Quality
2007-P-00036
Total Maximum Daily Load Program Needs Better Data and Measures to Demonstrate

Environmental Results
2006-P-00007
More Information Is Needed on Toxaphene Degradation Products
2004-P-00030
EPA Needs to Reinforce Its National Pretreatment Program
2002-P-00012
Wastewater Management: Controlling and Abating Combined Sewer Overflows
23

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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Resion 3	
08-P-0049 Despite Progress, EPA Needs to Improve Oversight of Wastewater Upgrades in the Chesapeake
Bay Watershed
Region 8	
08-P-0213 Oglala Sioux Single Audits—Corrective Actions Taken but Improvements Needed in Resolving
Costs
24

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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Appendix B
Unimplemented Recommendations:
Current Compendium Compared to 04/28/10 Compendium
Continuing Unimplemented Recommendations
09-P-0197	EPA Should Delay Deploying Its New Acquisition System until Testing Is Completed
(Recommendation 1)
2007-P-00036 Total Maximum Daily Load Program Needs Better Data and Measures to Demonstrate
Environmental Results (Recommendation 1-2)
2006-P-00007	More Information Is Needed on Toxaphene Degradation Products (Recommendation 2)
2005-P-00010 Substantial Changes Needed in Implementation and Oversight of Title V Permits If Program
Goals Are to Be Fully Realized (Recommendations 2-1,2-2,2-3)
2004-P-00030 EPA Needs to Reinforce Its National Pretreatment Program (Recommendation 4-1)
2002-P-00012 Wastewater Management: Controlling and Abating Combined Sewer Overflows
(Recommendation 5-1)
New Unimplemented Recommendations
10-P-0065	EPA Can Improve Its Preparation and Use of Independent Government Cost Estimates for
Superfund Contracts (Recommendation 2-5)
10-R-0057 EPA Needs Definitive Guidance for Recovery Act and Future Green Reserve Projects
(Recommendation 1)
10-P-0002 Review of Hotline Complaint on Employee Granted Full-Time Work-at-Home Privileges
(Recommendations 2a, 2b)
09-P-0223 EPA Needs to Accelerate Adoption of Numeric Nutrient Water Quality (Recommendations 2-1)
08-P-0213 Oglala Sioux Single Audits—Corrective Actions Taken but Improvements Needed in Resolving
Costs (Recommendation 1)
08-P-0141 EPA Needs to Track Compliance with Superfund Cleanup Requirements (Recommendation 4)
08-P-0049 Despite Progress, EPA Needs to Improve Oversight of Wastewater Upgrades in the Chesapeake
Bay Watershed (Recommendation 2-4)
2007-P-00017	EPA Needs to Strengthen Financial Database Security Oversight and Monitor Compliance
(Recommendation 4)
2007-P-00008 EPA Could Improve Controls Over Mainframe System Software (Recommendation 9)
25

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Compendium of Unimplemented Recommendations as of September 30, 2010
(Report No. 11-N-0006)
Removed Unimplemented Recommendations
Note: Removal of an unimplemented recommendation does not imply that it was verified as implemented, but rather,
that it was reported as being completed or that the target completion date has been revised with OIG approval.
09-P-0242 Contractor Invoice Internal Controls Need Improvement (Recommendations 2-1,2-2,2-4,3-1,
3-2)
09-P-0232 EPA's Office of Research and Development Could Better Use the Federal Managers' Financial
Integrity Act to Improve Operations (Recommendation 2-3)
09-P-0229 EPA Should Stop Providing Estimates of Total Labor Hours to Contractors (Recommendations
1,2)
09-P-0223 EPA Needs to Accelerate Adoption of Numeric Nutrient Water Quality Standards Results of
Technical Network Vulnerability Assessment: EPA's Research Triangle Park Campus
(Recommendations 2-3,2-4, 2-5)
09-P-0203 EPA Should Use FMFIA to Improve Programmatic Operations (Recommendation 3)
09-P-0197 EPA Should Delay Deploying Its New Acquisition System until Testing is Completed
(Recommendations 2,3, 4)
09-P-0089 EPA Needs a Comprehensive Research Plan and Policies to Fulfill its Emerging Climate Change
Role (Recommendations 3-1,3-3,3-4,3-5)
08-P-0266 EPA Assisting Tribal Water Systems but Needs to Improve Oversight (Recommendation 2-3)
08-P-0141 EPA Needs to Track Compliance with Superfund Cleanup Requirements (Recommendation 3)
08-1-0032 Audit of EPA's Fiscal 2007 and 2006 (Restated) Consolidated Financial Statements
(Recommendation 18)
2007-P-00027 Overcoming Obstacles to Measuring Compliance: Practices in Selected Federal Agencies
(Recommendation 2-1)
2006-P-00013 EPA Can Better Manage Superfund Resources (Recommendation 2-3)
2006-P-00009 Opportunities to Improve Data Quality and Children's Health through the Food Quality Protection
Act (Recommendation 4-1)
2005-P-00010 Substantial Changes Needed in Implementation and Oversight of Title V Permits If Program
Goals Are to be Fully Realized (Recommendations 3-1)
26

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