OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Evaluation Report
EPA's Office of Air and Radiation
Needs to Improve Compliance
with Audit Followup Process
Report No. 08-P-0080
February 12, 2008
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Report Contributors: Rick Beusse
Hilda Canes Gardufio
James Hatfield
Michael Young
Abbreviations
AFC Audit Followup Coordinator
EPA U.S. Environmental Protection Agency
MATS Management Audit Tracking System
OAQPS Office of Air Quality Planning and Standards
OAR Office of Air and Radiation
OCFO Office of the Chief Financial Officer
OIG Office of Inspector General
OMB Office of Management and Budget
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
08-P-0080
February 12, 2008
Why We Did This Review
The Office of Inspector
General (OIG) undertook this
review to determine (1) the
status of corrective actions
responding to OIG
recommendations for selected
OIG air reports, and (2) how
complete and up to date the
Management Audit Tracking
System (MATS) is for
selected OIG air reports.
Background
Audit followup is essential to
good management and
improving the efficiency and
effectiveness of U.S.
Environmental Protection
Agency (EPA) programs and
operations. EPA has audit
followup procedures and
designated officials who
manage this process. EPA
Manual 2750 outlines the audit
followup process. EPA is
required to report to Congress
on audit followup, including
any reasons for delays in
taking corrective actions not
implemented within 1 year of
issuing a report.
For further information,
contact our Office of
Congressional and Public
Liaison at (202) 566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2008/
20080212-08-P-0080.pdf
Catalyst for Improving the Environment
EPA's Office of Air and Radiation Needs to
Improve Compliance with Audit Followup Process
What We Found
EPA's Office of Air and Radiation (OAR) had generally taken corrective actions
to implement the recommendations for the five air-related reports we reviewed.
However, documented evidence of completion of agreed-to corrective actions was
in the files for only 1 of 29 corrective actions. Upon reviewing additional
information not contained in the official files, we determined that corrective
actions had been completed for 26 of the 29 agreed-to recommendations reviewed.
The three incomplete corrective actions had not been implemented within 1 year,
as stipulated in EPA Manual 2750, and OAR had not notified the OIG of these
delays.
Also, OAR did not follow the processes specified in EPA Manual 2750 for
certifying the completion and implementation of corrective actions. In two
instances where OAR reported audits as inactive - meaning corrective actions
were completed - the required certifications were not completed and placed in the
official files.
The Agency's audit tracking system (MATS) was incomplete and contained
mistakes. OAR omitted from MATS 10 agreed-to corrective actions pertaining to
two reports. For another instance, the information in MATS was inaccurate
because the Agency had mistakenly included the recommendations and corrective
actions pertaining to a different OIG report, while omitting the relevant six
agreed-to corrective actions. Thus, the MATS record was incomplete or
inaccurate for 16 of the 29 agreed-to corrective actions reviewed.
Prior to issuance of this report, OAR updated MATS to correct the errors and
omissions noted during our review and obtained certification memorandums for
the two inactive reports.
What We Recommend
We recommend that OAR comply with EPA Manual 2750 by (1) biannually
reviewing audit management information for accuracy and completeness;
(2) completing the certification process for closing out reports; and
(3) maintaining a list of specific corrective actions taken. We also recommend
that OAR ensure that newly appointed Audit Followup Coordinators receive audit
management training before taking over the position's roles and responsibilities.
EPA concurred with our recommendations and submitted a corrective action plan
with milestones that addressed our concerns.
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MEMORANDUM
SUBJECT:
FROM:
TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
February 12, 2008
EPA's Office of Air and Radiation Needs to Improve Compliance with
Audit Followup Process
Report No. 08-P-0080
WadeT. Najjum
Assistant Inspector General for Program Evaluation
Robert J. Meyers
Principal Deputy Assistant Administrator for Air and Radiation
This is our report on audit followup conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the
problems the OIG has identified and the corrective actions the OIG recommends. This report
represents the opinion of the OIG and does not necessarily represent the final EPA position.
Final determinations on matters in this report will be made by EPA managers in accordance with
established audit resolution procedures.
The estimated cost of this report - calculated by multiplying the project's staff days by the
applicable daily full cost billing rates in effect at the time - is $142,924.
Action Required
The Office of Air and Radiation corrective action plan, if properly implemented, addresses our
concerns. Therefore, in accordance with EPA Manual 2750, EPA 's Audit Management Process,
we are closing this report upon issuance. As outlined in EPA Manual 2750, the Agency is
responsible for tracking the implementation of these records in its Management Audit Tracking
System. We have no objections to the further release of this report to the public. This report will
be available at http://www.epa.gov/oig.
Should you or your staff have any questions regarding this report, please contact Rick Beusse,
Director for Program Evaluation, Air & Research Issues, at (919) 541-5747 or
beusse.rick@epa.gov: or Jim Hatfield, Project Manager, at (919) 541-1030 or
hatfield.iim@epa.gov.
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EPA's Office of Air and Radiation Needs to Improve
Compliance with Audit Followup Process
Table of Contents
Purpose 1
Background 1
Noteworthy Achievements 2
Scope and Methodology 2
Results of Review 3
Corrective Actions Generally Completed but Not Documented 3
Certification Memos Not Completed for Inactive Reports 4
MATS Contained Incorrect and Incomplete Information 4
Conclusions 5
Recommendations 5
Agency Comments and OIG Evaluation 5
Status of Recommendations and Potential Monetary Benefits 6
Appendices
A Audit Management Responsibilities 7
B Status of Agreed-to Recommendations 8
C List of Recommendations without Agreement 9
D Agency Response to Draft Report 12
E Distribution 15
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Purpose
The purpose of this project was to evaluate the status of corrective actions taken by the U.S.
Environmental Protection Agency (EPA) in response to selected Office of Inspector General
(OIG) air reports. Our objectives were to determine:
1. What is the status of agreed-to corrective actions responding to OIG report
recommendations for selected air reports?
2. How complete and up to date is the Management Audit Tracking System (MATS)
report information for selected OIG air reports?
Background
The Inspector General Act of 1978 established OIGs in Federal agencies to conduct independent
audits and investigations of agency programs and operations, and make recommendations to
improve their efficiency and effectiveness. Amendments to the Act added in 1988 directed
agencies to report to Congress semiannually on the status of followup on OIG audit report
recommendations.
The Office of Management and Budget (OMB) Circular A-50 specifies certain timeframes for
audit resolution and requires agencies to develop systems to ensure prompt implementation of
audit recommendations. According to OMB Circular A-50, audit followup is essential to good
management and is a shared responsibility of agency managers and audit organizations. The
EPA OIG's commitment to followup is reflected in the 2004-2008 Strategic Plan, with the aim of
improving accountability for actions leading to environmental improvements.
EPA's policy and procedures on the audit followup process are in EPA Manual 2750, most
recently revised in 1998. EPA Manual 2750 implements OMB Circular A-50 and the Inspector
General Act Amendments of 1988. The Manual specifies a chain of responsibility for the audit
management process, starting with the Chief Financial Officer as the Agency's designated Audit
Followup Official. According to EPA Manual 2750, the Agency's Audit Followup Official has
"personal responsibility" for Agency-wide audit resolution. Other key positions and duties in the
audit management chain include:
• Action Official - Certifies that corrective actions are complete.
• Audit Management Official - Develops and maintains office-specific procedures for
audit followup and resolution and designates office-specific Audit Followup
Coordinators.
• Audit Followup Coordinator (AFC) - Serves as a contact point for the OIG and
maintains official files.
OIG reports usually contain recommendations for Agency action officials to take corrective
actions to address the findings and conclusions of the report. When the Agency and the OIG
agree on the corrective actions, this decision is documented in the Management Decision letter.
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EPA Manual 2750 requires actions to be completed within 365 days of the management
decision, or otherwise explain reasons for delay.
The Office of the Chief Financial Officer (OCFO), responsible as the Audit Followup Official,
maintains and operates MATS to track audit followup, report, and resolution dates, and
corrective actions Agency-wide. However, OCFO only requires limited information to be
entered into MATS, including milestone dates, financial information (if applicable), and
explanations for missed deadlines. Further details on the status and actions taken to implement
corrective actions must be documented by the Action Official's office. This information is
essential for the Agency to assess and certify that agreed-to actions are completed.
According to EPA Manual 2750, official files are required to include seven major elements:
• Names of Action Official and other parties responsible for implementing, tracking,
following up, and reporting on corrective actions
• Draft reports
• Response to draft reports
• Final reports
• Approved Management Decisions
• OIG Management Decision acceptance memoranda
• All pertinent documentation and certification information
Together, MATS and official files document an audit's history, as well as the actions taken by
the Agency to address recommendations and correct deficiencies. Appendix A provides
additional details on position responsibilities in the audit management process.
Noteworthy Achievements
In response to a prior OIG report that found problems with the Agency's audit follow process,
OCFO, in conjunction with OIG, conducted training in August 2007 for AFCs on complying
with EPA Manual 2750 and the audit followup process. The AFC in the Office of Air and
Radiation's (OAR's) Office of Air Quality Planning and Standards (OAQPS) completed this
training in August, about 1 year after he took over the audit followup responsibilities for OAR.
Recognizing the complexity of the air quality programs, OAR/OAQPS assigned AFC duties to a
technical staff member to improve both communication and responsiveness to the OIG.
The OAQPS AFC recently completed a number of actions to correct issues noted during our
review. For example, the MATS database was corrected for the three reports that were in error
and certification memorandums were obtained for both of the inactive reports. Further, the AFC
was in the process of implementing the OCFO's September guidance to verify MATS data for all
reports.
Scope and Methodology
We conducted our evaluation from July 2007 to December 2007. We selected for review five
OIG Office of Program Evaluation air reports issued from September 2003 to May 2006 (see
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Appendix B). This allowed us to test the implementation status of agreed-to corrective actions
after the 1-year implementation timeframe provided in EPA Manual 2750. We reviewed 29
agreed-to corrective actions resulting from the reports' recommendations. These five reports
also contained 21 recommendations the Agency did not agree to implement (see Appendix C);
consequently, no corrective action was required at this time.
Our evaluation consisted of reviewing: (1) official OAR report files, (2) EPA MATS reports
generated in July and October 2007, and (3) EPA documentary evidence obtained from the
affected program entities regarding actions taken. In addition, we interviewed key EPA officials
responsible for implementing or overseeing these corrective actions, including the EPA AFC for
OAQPS. We used this information to assess the completeness of Agency actions on our reports.
We did not review the entire MATS system or MATS files for OIG reports other than the five in
our scope. We did not assess the effectiveness of the Agency's corrective actions in resolving
the findings identified in each report.
We performed this review in accordance with generally accepted government auditing standards
issued by the Comptroller General of the United States.
Results of Review
OAR needs to improve its audit management process to comply with EPA Manual 2750. We
found that OAR:
• Generally completed corrective actions but did not document evidence of completion
in the official files.
• Did not complete certification memorandums for reports classified as inactive.
• Entered incorrect or incomplete information in MATS for approximately half of the
corrective actions reviewed.
We believe these conditions existed because of a lack of OAR internal controls over the audit
management process. Not complying with EPA Manual 2750 can result in loss of accountability
over corrective actions, and adversely affects the completeness and accuracy of the Agency's
annual reporting process and its reports to Congress.
Corrective Actions Generally Completed but Not Documented
OAR completed and implemented the agreed-to corrective actions for 26 of 29
recommendations. However, the Agency's documentation of corrective actions was not
in the official files as required. OAQPS's official files contained status reports indicating
that OAR was taking steps toward fulfilling the corrective actions. However, evidence of
completion of agreed-to corrective actions was documented in the files for only 1 of the
29 corrective actions. EPA Manual 2750 requires that the official files contain
documentation showing completion of the corrective actions. Upon reviewing additional
information not contained in the official files, we determined that 26 of the 29 corrective
actions were completed and the Agency had ongoing actions to address the 3 remaining
agreed-to corrective actions. The two reports for which the three corrective actions were
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not completed were properly classified as "active" in MATS. According to the AFC,
OAQPS's practice was to maintain evidence of corrective actions in decentralized files,
but will now maintain such evidence in the official files as required by EPA Manual
2750.
Certification Memos Not Completed for Inactive Reports
EPA designated three of the five reports under followup review as "active" in MATS,
meaning that corrective actions have not yet been completed. For the two remaining
reports, MATS listed them as "inactive," meaning that corrective actions were complete.
The two inactive reports' official files did not contain the certification memos required by
EPA Manual 2750. The following table lists the two inactive reports.
Table 1: Reports in Inactive Status Without Certification Memos in Official Files
Report Name
Decline In EPA Particulate Matter Methods
Development Activities May Hamper Timely
Achievement of Program Goals
EPA Needs to Direct More Attention, Efforts, and
Funding to Enhance Its Speciation Monitoring
Program for Measuring Fine Particulate Matter
Report No.
2003-P-00016
2005-P-00004
Date
September 30,
2003
February 7, 2005
Source: MATS and OIG review of official files.
EPA Manual 2750 establishes a process for closure of OIG reports. An Action Official is
responsible for maintaining documentation of corrective actions. For each action, the
designated Action Official is also required to certify "in writing that the corrective
actions are complete." The AFC is then required to keep this certification in the official
file. A report should not be placed in inactive status in MATS until this step has
occurred. Entry of a final action date by an AFC automatically triggers MATS to
inactivate the report without further verification by OCFO. OCFO believes it is the
AFC's responsibility to have the certification memo in-hand before entering the final
action date into MATS. Without the accountability of a certification memo, reports can
be inactivated from the audit tracking system without corrective actions actually being
completed.
MATS Contained Incorrect and Incomplete Information
The MATS record was incomplete or inaccurate for 16 of the 29 agreed-to corrective
actions we reviewed. These 16 corrective actions pertained to 3 of the 5 reports we
reviewed. For one report, the official file contained updates on agreed-to corrective
actions from a different OIG report. As a result, the MATS record reflected the status of
the corrective actions for the wrong report and did not show the status of the six agreed-to
corrective actions for the subject report. In another instance, OAR had not entered any
information into MATS for the eight agreed-to corrective actions resulting from the OIG
report. Similarly, information was missing in the MATS database for two corrective
actions resulting from another OIG report. The three reports are listed in Table 2, while
additional details are in Appendix B.
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Table 2: Reports with Incomplete or Inaccurate MATS Records
Report Name
Decline In EPA Particulate Matter Methods
Development Activities May Hamper Timely
Achievement of Program Goals
EPA and States Not Making Sufficient Progress in
Reducing Ozone Precursor Emissions in Some Major
Metropolitan Areas
Substantial Changes Needed in Implementation and
Oversight of Title V Permits If Program Goals Are to
Be Fully Realized
Report No.
2003-P-00016
2004-P-00033
2005-P-00010
Date
September 30, 2003
September 29, 2004
March 9, 2005
Source: MATS and OIG review of official files.
In September 2007, in response to a prior OIG report that found problems with the
Agency's audit followup process, OCFO issued a memorandum that stressed that
program offices should make certain that information in the Agency's MATS is
complete, accurate, and verifiable.
Conclusions
OAR generally implemented agreed-to corrective actions. However, OAR did not comply with
EPA Manual 2750. Thus, it is vulnerable to loss of accountability over corrective actions and
inaccurate external reporting. Official files containing accurate and complete documentation of
corrective action implementation are important to properly managing audit report followup. It
also assists in the continuity of followup when staff turnover occurs. Inaccurate audit followup
adversely affects the completeness and accuracy of the Agency's annual reporting process and its
reports to Congress.
Recommendations
We recommend that the Principal Deputy Assistant Administrator for Air and Radiation:
1. Comply with EPA Manual 2750 by:
a. biannually reviewing audit management information for accuracy and
completeness,
b. completing the certification process for closing out reports, and
c. maintaining a list of specific corrective actions taken.
2. Ensure that newly appointed AFCs receive audit management training before they
take over the position's roles and responsibilities.
Agency Comments and OIG Evaluation
EPA concurred with our recommendations and submitted a corrective action plan with
milestones to implement the recommendations. The Agency's proposed corrective actions
sufficiently address our concerns. A copy of the Agency's complete response to our draft report,
including its corrective action plan, is found in Appendix D.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
1
Page
No.
5
Subject Status1
Comply with EPA Manual 2750 by: (a) biannually 0
reviewing audit management information for
accuracy and completeness, (b) completing the
certification process for closing out reports, and
(c) maintaining a list of specific corrective actions
taken.
Action Official
Principal Deputy
Assistant Administrator
for Air and Radiation
Planned
Completion
Date
6/11/2008
POTENTIAL MONETARY
BENEFITS (in $OOOs)
Claimed Agreed To
Amount Amount
5 Ensure that newly appointed AFCs receive audit
management training before they take over the
position's roles and responsibilities.
Principal Deputy
Assistant Administrator
for Air and Radiation
6/11/2008
0 = recommendation is open with agreed-to corrective actions pending;
C = recommendation is closed with all agreed-to actions completed;
U = recommendation is undecided with resolution efforts in progress
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Appendix A
Audit Management Responsibilities
Title
Duties
Agency Audit Followup
Official
Ensures Agency-wide audit resolution and that systems for audit
followup are in place
Ensures corrective actions are actually implemented
Designates an Agency Audit Followup Coordinator
Agency Audit Followup
Coordinator
Maintains and conducts quality assurance and analysis of the
Agency audit tracking system and data
Prepares reports to Congress
Action Officials
Implements the audited program (commonly the Regional or
Assistant Administrator to whom the report is addressed)
Ensures that corrective actions are documented, tracked, and
implemented
Certifies that corrective actions are complete (or designates a
certifying official to do so)
Audit Management
Officials
Is designated in each regional and national program office
Develops and maintains office-specific procedures for audit
followup and resolution
Designates office-specific Audit Followup Coordinators
Ensures managers and staff within their office understand the
audit management process and take timely and appropriate
corrective actions
Audit Followup
Coordinators
Serves as a contact point for OIG
Provides guidance and ensures that responses to OIG reports
are complete and timely
Maintains official files containing the record of management
decisions and certifications of completed corrective actions
Provides status reports to the Agency Audit Followup Coordinator
on corrective actions and audit resolution, and tracks reasons for
delay
Source: EPA Manual 2750.
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Appendix B
Status ofAgreed-to Recommendations
OIG Report
Decline in EPA Particulate Matter
Methods Development Activities May
Hamper Timely Achievement of
Program Goals (Report No.
2003-P-00016, September 30, 2003)
EPA and States Not Making Sufficient
Progress in Reducing Ozone Precursor
Emissions in Some Major Metropolitan
Areas (Report No. 2004-P-00033,
September 29, 2004)
EPA Needs to Direct More Attention,
Efforts, and Funding to Enhance Its
Speciation Monitoring Program for
Measuring Fine Particulate Matter
(Report No. 2005-P-00004,
February 7, 2005)
Substantial Changes Needed in
Implementation and Oversight of Title V
Permits If Program Goals Are to Be
Fully Realized (Report No.
2005-P-00010, March 9, 2005)
Monitoring Needed to Assess Impact of
EPA's Clean Air Mercury Rule on
Potential Hotspots (Report No.
2006-P-00025, May 15, 2006)
Recom-
mend-
ation
2-1
2-2
2-3
3-1
3-2
3-3
3-1
3-4
3-6
6-2
6-3
8-1
8-2
8-4
3-1
3-2
3-3
3-4
3-5
2-3
2-4
2-5
2-6
2-7
3-2
3-3
3-4
4-1
3-1
Evidence of
Corrective
Action in
OAR File?
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
Corrective
Action
Complete?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Correct
Information
Recorded in
MATS?
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Notes
1/
21
3/
Source: Data obtained from OIG reports, MATS, and review of OIG files.
NOTES: 1/ Information in OAR official file and MATS was for another report's recommendations. No data on this
report's corrective actions were in MATS.
21 No information recorded in MATS for this report's corrective actions. OAQPS plans to complete
corrective action for Recommendation 6-2 in February 2008.
3/ No information recorded in MATS for two of report's corrective actions. OAQPS plans to complete
corrective action for Recommendation 2-4 by Spring 2008. OAR has not implemented corrective
action for Recommendation 2-6 and maintained that recommended training is unnecessary.
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Appendix C
List of Recommendations without Agreement
OIG Report
Recommendation
EPA and States Not
Making Sufficient
Progress in Reducing
Ozone Precursor
Emissions in Some
Major Metropolitan
Areas (Report No.
2004-P-00033,
September 29, 2004)
2-1
2-2
3-2
3-3
3-5
4-1
4-2
Perform an in-depth evaluation of the compliance of all serious to extreme
nonattainment areas with emission reduction requirements using, at a
minimum, precursor emissions data contained in the Agency's National
Emissions Inventory database.
Implement contingency measures and additional controls, where
appropriate, as required under Section 182(g)(3) of the Act, if
nonattainment areas have not met the Act's emission reduction
requirements, including the use of any enforcement and/or sanctions
available under Section 179 of the Act for failure of a State to submit
adequate plans and/or failure to timely and adequately implement planned
controls to achieve required emission reductions by the statutory milestone
dates.
Require evaluation of proposed Rate-of-Progress Plans by EPA regional
air programs to assure the propriety of Rate-of-Progress assumptions,
projections, and related emission reductions in comparison to available
emission databases and historical data.
Develop guidance for analyzing and comparing periodic emission
inventories to projected emission target levels and evaluating assumptions
used in applicable Rate-of-Progress Plans, in order to: (1) reconcile
differences between projected and actual inventories; (2) identify any
incorrect assumptions or projections and understatement of needed
emission reductions; and (3) establish improvements that may be needed
in the Rate-of-Progress development process, and ensure training of staff
in conducting these analyses.
Revise EPA's "Clean Data" policy to require meteorologically adjusted
ozone trend analyses and trend analyses of ambient Volatile Organic
Compound and Nitrogen Oxide concentrations for nonattainment areas
that attain the ozone standard based on ambient ozone monitoring data, to
better assure the permanence of such attainments before suspending
Rate-of-Progress Plan development and approval.
Subject the policy claiming outside emissions to the notice-and-comment
rulemaking process, which will allow broad public comment and feedback.
Revise policy for nonattainment area outside emission reduction credit to:
a. Encourage broadening of controls for sources in outside areas in order
for a nonattainment area to claim emission reduction credits.
b. Require atmospheric modeling to support the impact of outside
emissions and sources on nonattainment area ozone levels.
c. Require that the emission baselines from all selected outside areas be
included in Rate-of-Progress baseline emissions for calculating required
emission reductions and measuring achievement of reductions.
d. Establish a methodology, such as atmospheric modeling, to document
the extent of benefits that Nitrogen Oxide and Volatile Organic Compound
emissions reductions from outside the area have on individual
nonattainment areas to prevent improper double-counting of emission
reductions when a State has multiple nonattainment areas.
e. Require that outside sources or areas included in post-1996 Rates-of-
Progress also be included in subsequent Periodic Emissions Inventories
for each applicable nonattainment area.
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OIG Report
Recommendation
5-1
5-2
5-3
5-4
5-5
6-1
7-1
7-2
8-3
8-5
Expedite issuance of the milestone compliance guidance, but restrict the
use of observed ambient zone levels as a stand-alone indicator of
emission reductions. The guidance should also require the use of
meteorologically adjusted ozone trends and trends in ambient
concentrations of Volatile Organic Compounds and Nitrogen Oxides in the
weight of evidence approach.
Instruct States to utilize indicators, as reflected in the draft milestone
compliance demonstration guidance, and/or provide annual updates to
emissions inventories (one third of sources per year or one third of States
per year) to determine potential or actual emission reductions within the
Act's 90-day time frame for milestone compliance demonstrations.
Require that nonattainment areas update baseline inventories and,
subsequently, perform more in-depth assessments of actual emission
reductions, once the applicable Periodic Emissions Inventories are
completed. This subsequent determination of actual emission reductions
may not meet the milestone compliance demonstration 90-day time frame
but will provide a measure of progress that is not currently available.
Incorporate the use of updated National Emissions Inventory data and
other available measures, where appropriate, into milestone compliance
demonstration guidance as top-down indicators or measures of
nonattainment area progress in reducing precursor emissions.
Require State and local agencies to update past baseline and periodic
emission inventories based on the latest models, emission factor, and
methodologies, and complete milestone compliance demonstrations for
1990 through 1999 (or later milestone year) for nonattainment areas based
on the issued milestone compliance guidance. Further, for future
inventories, require States to continuously update inventories as new
emissions data and methods are developed, to provide timely
assessments of nonattainment area progress in reducing precursor
emissions.
Develop analytical procedures and processes for EPA and/or States to
utilize updated National Emissions Inventory data for measuring the
progress of individual 8-hour nonattainment areas in reducing precursor
emissions and complying with the Act's emission reduction mandates.
Establish annual and multi-year goals and performance measures for
ozone precursor emission reductions by individual nonattainment areas
and require State and local agencies to submit evidence that these goals
have been met.
Once annual goals and measures are established, include the goals and
measures in EPA, State, and local agencies' annual and strategic plans,
and provide accomplishments toward these goals in EPA's annual
performance reports.
To the extent possible, expedite the regulatory process for releasing ozone
Data Quality Objectives for use in State air monitoring Quality Assurance
Project Plans.
Promulgate policies and procedures which require regions to obtain State
Periodic Emissions Inventories and review the Periodic Emissions
Inventories for quality and compliance with EPA emission inventory
development guidance.
10
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OIG Report
Substantial Changes
Needed in
Implementation and
Oversight of Title V
Permits If Program
Goals Are to Be Fully
Realized (Report No.
2005-P-00010, March 9,
2005)
Monitoring Needed to
Assess Impact of EPA 's
Clean Air Mercury Rule
on Potential Hotspots
(Report No. 2006-P-
00025, May 15,2006)
Recommendation
2-1
2-2
3-1
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.
Issue the draft rule regarding intermittent versus continuous monitoring as
it relates to annual compliance certifications and including credible
evidence.
Promulgate the draft order of sanctions rule which provides notice to State
and local agencies, as well as the public, regarding the actions that will be
taken when Notices of Deficiency are not timely resolved by State and
local Title V permitting authorities.
2-1
Work with the Assistant Administrator for the Office of Research and
Development to develop and implement a mercury monitoring plan,
including milestones and responsible program offices for implementing
each component of the plan, to: (1) assess the impact of Clean Air
Mercury Rule, if adopted, on mercury deposition and fish tissue; and
(2) evaluate and refine, as necessary, mercury estimation tools and
models. This effort should consider the suitability of the Office of Research
and Development's mercury research plan for addressing these
objectives.
Source: Data obtained from OIG reports, MATS, and review of OIG files.
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Appendix D
Agency Response to Draft Report
February 1,2008
MEMORANDUM
SUBJECT: Response to Draft Evaluation Report: "EPA's Office of Air
and Radiation Needs to Improve Compliance with Audit
Followup Process, Assignment No. 2007-00926
FROM: Robert J. Meyers
Principal Deputy Assistant Administrator
TO: Wade T. Najjum
Assistant Inspector General for Program Evaluation
Thank you for the opportunity to comment on the draft report, "EPA's Office of Air and
Radiation Needs to Improve Compliance with Audit Followup Process, (Assignment No. 2007-
00926). The Office of Air and Radiation concurs with the findings described in the draft report
and the proposed recommendations.
We recognize the importance of audit followup procedures and have made it a priority to quickly
correct any deficiencies and take action to ensure a high quality followup program. OAR has
started development of a standard operating procedure to enhance our compliance with EPA
Order 2750. Additionally, we have taken corrective actions for the issues identified in the report
such as updating the Management Audit Tracking System (MATS) and obtaining certification
memoranda for closure of OIG reports. OAR's Corrective Action Plan and schedule are attached.
Thank you again for the opportunity to comment on the draft evaluation report. If you have
questions, please contact Michael Boucher, OAQPS Audit Follow-up Coordinator, at
(919) 541-7627.
Attachments
cc: Elizabeth Craig, OAR
Steve Page, OAR
Omayra Salgado, OAR
Michael Boucher, OAR
Peter Cosier, OAR
Jim Hatfield, OIG
Sharon Tant, OCFO
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Attachment 1
EVALUATION OF OIG's RECOMMENDATIONS
Recommendation 1: Comply with EPA Order 2750 by: (a) biannually reviewing audit
management information for accuracy and completeness, (b) completing the certification
process for closing out reports, and (c) maintaining a list of specific corrective actions
taken.
OAR concurs with this recommendation. OAR is currently developing a Standard Operating
Procedure to ensure the following actions:
a) review all audit management information including completeness of official
files on a biannual basis. These reviews will be conducted every March and
September to coincide with the Agency's requirement under EPA Order 2750
and the IG Act to report to Congress on the status of completing corrective
actions. Every effort will be made to maintain the completeness and accuracy of
the information.
b) ensure certification memorandums are filed upon completion of correction
action plans as a final action to close out audits. OAR AFCs will ensure Action
Officials, or their designates, for all current and past audits understand that they
are required to provide a certification letter to the AFC when all corrective actions
are completed. Once the certifications letters are received, the AFC will enter the
necessary information into MATS; provide OCFO notification of the Final Action
Date enabling them to move the report to Inactive status.
c) maintain a brief description of the corrective actions taken by the Action
Official in MATS and the official file.
Recommendation 2: OAR ensure that newly appointed Audit Followup Coordinators
receive audit management training before they take over the position's roles and
responsibilities.
OAR concurs with this recommendation. Future AFC's will be required to be trained on
EPA Order 2750 requirements before accepting full responsibilities as an AFC. This
requirement will be included on the SOP being developed to satisfy recommendation 1.
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OAR's CORRECTIVE ACTION PLAN
Attachment 2
Number
1
2
Recommendation
Comply with EPA Order 2750
by:
(a) biannually reviewing audit
management information for
accuracy and completeness,
(b) completing the
certification process for
closing out reports, and
(c) maintaining a list of
specific corrective actions
taken.
Ensure that newly appointed
AFCs receive audit
management training before
they take over the position's
roles and responsibilities.
Planned Corrective
Action
Conduct an assessment
of MATS to ensure
current information is
complete, accurate and
verifiable
Develop an SOP which
fully addresses
compliance with EPA
Order 2750
Require that future AFC's
be trained on EPA Order
2750 requirements
before accepting full
responsibilities
Planned
Completion
Within 60 days of
issuance of OIG's
Final report
Within 3 months
of the issuance of
the OIG's Final
Report
As soon as
training is
available before
accepting AFC's
responsibilities.
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Appendix E
Distribution
Office of the Administrator
Principal Deputy Assistant Administrator for Air and Radiation
Agency Followup Official (the CFO)
Agency Followup Coordinator
Office of General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Audit Followup Coordinator, Office of Air and Radiation
Deputy Inspector General
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