I  U.S. ENVIRONMENTAL PROTECTION AGENCY
      /  OFFICE OF INSPECTOR GENERAL
                           Catalyst for Improving the Environment
Special Report
       Fiscal Year 2009
       Federal Information Security
       Management Act Report

       Status of EPA's Computer Security Program
       Report No. 10-P-0030

       November 18, 2009

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                    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                  WASHINGTON, D.C. 20460
                                  November 18, 2009
                                                                           OFFICE OF
                                                                       INSPECTOR GENERAL
MEMORANDUM
SUBJECT:
FROM:
TO:
Fiscal Year 2009 Federal Information Security
Management Act Report: Status of EPA's Computer
Security Program
Report No. 10-P-0030  ^
Bill A. Roderick
Deputy Inspector General

Lisa P. Jackson
Administrator
Attached is the Office of Inspector General's (OIG's) Fiscal Year 2009 Federal Information
Security Management Act (FISMA) Reporting Template, as prescribed by the Office of
Management and Budget (OMB).  Williams, Adley and Company, LLP, performed this review
under the direction of the U.S. Environmental Protection Agency's OIG and performed the
review in accordance with generally accepted government auditing standards. These standards
require them to plan and perform the review to obtain sufficient and appropriate evidence to
provide a reasonable basis for their findings and conclusions based on the objectives of the
review.

Williams, Adley, and Company, LLP, limited their testing to those managerial controls necessary
to achieve the objectives described in OMB Memorandum M-09-29, FY 2009 Reporting
Instructions for the Federal Information Security Management Act and Agency Privacy
Management, August 20, 2009.  Williams, Adley,  and Company, LLP, did not test all managerial
controls relevant to the effectiveness of the Agency's information security program as broadly
defined by FISMA.

We believe the evidence obtained provides a reasonable basis for our findings and conclusions,
and in all material respects meets the FISMA reporting requirements prescribed by OMB.  In
accordance with OMB reporting instructions, I am forwarding this report to you for submission,
along with the Agency's required information, to the Director, OMB.

Furthermore, OIG audit work performed during Fiscal Year 2009 did not disclose material
weaknesses with respect to the Agency's information security program that should be disclosed

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pursuant to the Federal Managers' Financial Integrity Act of 1982. However, OIG audits noted
significant weaknesses with several aspects of EPA's information security program.
Appendix A synopsizes the results of our significant Fiscal Year 2009 information security
audits.

The estimated cost for performing this audit, which includes contract costs and OIG contract
management oversight, is $164,271.

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Inspector General
Section Report
    Environmental Protection Agency

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Question 1: FISMA Systems Inventory & Question 2: Certification and Accreditation, Security Controls
Testing, and Contingency Plan Testing
1.  Identify the number of Agency and contractor systems by component and FIPS 199 impact level (low, moderate, high) reviewed.
2.  For the Total Number of Reviewed Systems Identified by Component/Bureau and FIPS System Impact Level in the table for
Question 1, identify the number and percentage of systems which have: a current certification and accreditation, security controls
tested and reviewed within the past year, and a contingency plan tested in accordance with policy.








Agency/Component

OA




OAR












Category

High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
Question 1
a.
Agency Systems





Total
Number
0
0
2
0
2
1
9
3
0
13
Number
Reviewed
0
0
1
0
1
0
1
0
0
1
b.
Contractor Systems





Total
Number
0
0
0
0
0
0
1
1
0
2
Number
Reviewed
0
0
0
0
0
0
0
0
0
0
c.
Total Number of
Systems(Agency and
Contractor systems)



Total Number
Number Reviewed
0 0
0 0
2 1
0 0
2 1
1 0
10 1
4 0
0 0
15 1
Question 2
a.
Number of
systems certified
and accredited





0
0
1
0
1
0
1
0
0
1
b.
Number of systems
for which security
controls have been
tested and reviewed
in the past year



0
0
1
0
1
0
1
0
0
1
c.
Number of systems
for which
contingency plans
have been tested in
accordance with
policy


0
0
1
0
1
0
1
0
0
1
 2009 Annual FISMA Report - Environmental Protection Agency
Page 1 of 15

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Question 1: FISMA Systems Inventory & Question 2: Certification and Accreditation, Security Controls
Testing, and Contingency Plan Testing








Agency/Component

OARM




OCFO




OECA




OEI












Category

High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
Question 1
a.
Agency Systems





Total
Number
0
8
0
0
8
0
15
1
0
16
0
7
2
0
9
0
17
11
0
28
Number
Reviewed
0
3
0
0
3
0
2
0
0
2
0
0
1
0
1
0
1
2
0
3
b.
Contractor Systems





Total
Number
0
2
0
0
2
0
0
0
0
0
0
0
0
0
0
0
4
3
0
7
Number
Reviewed
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
2
c.
Total Number of
Systems(Agency and
Contractor systems)



Total Number
Number Reviewed
0 0
10 3
0 0
0 0
10 3
0 0
15 2
1 0
0 0
16 2
0 0
7 0
2 1
0 0
9 1
0 0
21 3
14 2
0 0
35 5
Question 2
a.
Number of
systems certified
and accredited





0
3
0
0
3
0
1
0
0
1
0
0
1
0
1
0
3
1
0
4
b.
Number of systems
for which security
controls have been
tested and reviewed
in the past year



0
2
0
0
2
0
2
0
0
2
0
0
1
0
1
0
3
1
0
4
c.
Number of systems
for which
contingency plans
have been tested in
accordance with
policy


0
3
0
0
3
0
2
0
0
2
0
0
0
0
0
0
3
1
0
4
2009 Annual FISMA Report - Environmental Protection Agency
Page 2 of 15

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Question 1: FISMA Systems Inventory & Question 2: Certification and Accreditation, Security Controls
Testing, and Contingency Plan Testing








Agency/Component

OGC




OIA




OIG




OPPTS












Category

High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
Question 1
a.
Agency Systems





Total
Number
0
0
0
0
0
0
0
0
0
0
0
7
0
0
7
0
4
1
0
5
Number
Reviewed
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
b.
Contractor Systems





Total
Number
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
1
Number
Reviewed
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
c.
Total Number of
Systems(Agency and
Contractor systems)



Total Number
Number Reviewed
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
7 0
0 0
0 0
7 0
0 0
5 0
1 0
0 0
6 0
Question 2
a.
Number of
systems certified
and accredited





0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
b.
Number of systems
for which security
controls have been
tested and reviewed
in the past year



0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
c.
Number of systems
for which
contingency plans
have been tested in
accordance with
policy


0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
 2009 Annual FISMA Report - Environmental Protection Agency
Page 3 of 15

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Question 1: FISMA Systems Inventory & Question 2: Certification and Accreditation, Security Controls
Testing, and Contingency Plan Testing








Agency/Component

ORD




OSWER




OW




R1












Category

High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
Question 1
a.
Agency Systems





Total
Number
0
5
9
0
14
0
3
4
0
7
0
3
0
0
3
0
1
0
0
1
Number
Reviewed
0
0
1
0
1
0
1
0
0
1
0
1
0
0
1
0
0
0
0
0
b.
Contractor Systems





Total
Number
0
0
0
0
0
0
1
1
0
2
0
0
0
0
0
0
0
0
0
0
Number
Reviewed
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
c.
Total Number of
Systems(Agency and
Contractor systems)



Total Number
Number Reviewed
0 0
5 0
9 1
0 0
14 1
0 0
4 1
5 0
0 0
9 1
0 0
3 1
0 0
0 0
3 1
0 0
1 0
0 0
0 0
1 0
Question 2
a.
Number of
systems certified
and accredited





0
0
1
0
1
0
1
0
0
1
0
1
0
0
1
0
0
0
0
0
b.
Number of systems
for which security
controls have been
tested and reviewed
in the past year



0
0
1
0
1
0
1
0
0
1
0
0
0
0
0
0
0
0
0
0
c.
Number of systems
for which
contingency plans
have been tested in
accordance with
policy


0
0
0
0
0
0
1
0
0
1
0
1
0
0
1
0
0
0
0
0
2009 Annual FISMA Report - Environmental Protection Agency
Page 4 of 15

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Question 1: FISMA Systems Inventory & Question 2: Certification and Accreditation, Security Controls
Testing, and Contingency Plan Testing








Agency/Component

R10




R2




R3




R4












Category

High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
Question 1
a.
Agency Systems





Total
Number
0
1
0
0
1
0
2
0
0
2
0
1
0
0
1
0
1
0
0
1
Number
Reviewed
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
b.
Contractor Systems





Total
Number
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Number
Reviewed
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
c.
Total Number of
Systems(Agency and
Contractor systems)



Total Number
Number Reviewed
0 0
1 0
0 0
0 0
1 0
0 0
2 0
0 0
0 0
2 0
0 0
1 0
0 0
0 0
1 0
0 0
1 0
0 0
0 0
1 0
Question 2
a.
Number of
systems certified
and accredited





0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
b.
Number of systems
for which security
controls have been
tested and reviewed
in the past year



0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
c.
Number of systems
for which
contingency plans
have been tested in
accordance with
policy


0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2009 Annual FISMA Report - Environmental Protection Agency
Page 5 of 15

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Question 1: FISMA Systems Inventory & Question 2: Certification and Accreditation, Security Controls
Testing, and Contingency Plan Testing

Agency/Component
R5

R6


R7



R8






Category
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Sub Total
Question 1
a.
Agency Systems
Total
Number
0
2
1
0
3
0
1
0
0
1
0
1
0
0
1
0
1
1
0
2

Number
Reviewed
0
1
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
1
0
1

b.
Contractor Systems
Total
Number
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Number
Reviewed
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
c.
Total Number of
Systems(Agency and
Contractor systems)
Total Number
Number Reviewed
0 0
2 1
1 0
0 0
3 1
0 0
1 0
0 0
0 0
1 0
0 0
1 0
0 0
0 0
1 0
0 0
1 0
1 1
0 0
2 1
Question 2
a.
Number of
systems certified
and accredited

0
1
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
1
0
1
b.
Number of systems
for which security
controls have been
tested and reviewed
in the past year

0
1
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
1
0
1
c.
Number of systems
for which
contingency plans
have been tested in
accordance with
policy

0
1
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
1
0
1
2009 Annual FISMA Report - Environmental Protection Agency
Page 6 of 15

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 Question 1: FISMA Systems Inventory & Question 2: Certification and Accreditation, Security Controls
 Testing, and Contingency Plan Testing








Agency/Component

R9




Agency Totals












Category

High
Moderate
Low
Not Categorized
Sub Total
High
Moderate
Low
Not Categorized
Total Systems
Question 1
a.
Agency Systems





Total
Number
0
1
0
0
1
1
90
35
0
126
Number
Reviewed
0
0
0
0
0
0
10
6
0
16
b.
Contractor Systems





Total
Number
0
1
0
0
1
0
10
5
0
15
Number
Reviewed
0
1
0
0
1
0
3
0
0
3
c.
Total Number of
Systems(Agency and
Contractor systems)



Total Number
Number Reviewed
0 0
2 1
0 0
0 0
2 1
1 0
100 13
40 6
0 0
141 19
Question 2
a.
Number of
systems certified
and accredited





0
1
0
0
1
0
12
5
0
17
b.
Number of systems
for which security
controls have been
tested and reviewed
in the past year



0
1
0
0
1
0
11
5
0
16
c.
Number of systems
for which
contingency plans
have been tested in
accordance with
policy


0
1
0
0
1
0
13
3
0
16
2009 Annual FISMA Report - Environmental Protection Agency
Page 7 of 15

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Question 3: Evaluation of Agency Oversight of Contractor Systems and Quality of Agency System Inventory
The Agency performs oversight and evaluation to ensure information systems used or operated by a contractor of the Agency or other
organization on behalf of the Agency meet the requirements of FISMA, OMB policy and NIST guidelines, national security policy, and
Agency policy.

Agencies are responsible for ensuring the security of information systems used by a contractor of their Agency or other organization on
behalf of their Agency; therefore, self reporting by contractors does not meet the requirements of law. Self-reporting by another
Federal Agency, for example, a Federal service provider, may be sufficient. Agencies and service providers have a shared
responsibility for FISMA compliance.
 3a. Does the Agency have policies for oversight of contractors?
     Yes

     3a(l). Is the policy implemented?
            Yes
                     Comments:
EPA's Network Security Policy states that the Agency must monitor contractor's compliance with information
security responsibilities in Agency contracts. The policy is implemented; however, procedures and training
could be improved for the Certification and Accreditation process.
 3b. Does the Agency have a materially correct inventory of major information systems (including national security systems)
 operated by or under the control of such Agency?
     Yes

 3c. Does the Agency maintain an inventory of interfaces between the Agency systems and all other systems, such as those not
 operated by or under the control of the Agency?
     Yes
 3d. Does the Agency require agreements for interfaces between systems it owns or operates and other systems not operated by
 or under the control of the Agency?
     Yes
 3e. The Agency inventory is maintained and updated at least annually.
     Yes


 2009 Annual FISMA Report - Environmental Protection Agency                                                                 Page 8 of 15

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 3f. The IG generally agrees with the CIO on the number of Agency-owned systems.
     Yes

 3g. The IG generally agrees with the CIO on the number of information systems used or operated by a contractor of the Agency or
 other organization on behalf of the Agency.
     Yes
Question 4: Evaluation of Agency Plan of Action and Milestones (POA&M) Process
Assess whether the Agency has developed, implemented, and is managing an Agency-wide plan of action and milestones (POA&M)
process, providing explanatory detail in the area provided.
4a.  Has the Agency developed and documented an adequate policy that establishes a POA&M process for reporting IT security
deficiencies and tracking the status of remediation efforts?
    Yes
          Comments:
EPA has developed and implemented the following:

- Procedure for Information Security Plans of Actions and Milestones
 (POA&Ms), dated June 18, 2004
- EPA Certification and Accreditation Process, dated May 11, 2006
- Quarterly and Annual Training to Information Security Officers on
 Entering POA&Ms
- Automated Process for Entering POA&Ms in Agency's tracking and
 reporting database
    4a(l). Has the Agency fully implemented the policy?
            Yes
4b. Is the Agency currently managing and operating a POA&M process?
    Yes
 2009 Annual FISMA Report - Environmental Protection Agency
                                                                                              Page 9 of 15

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4c.  Is the Agency's POA&M process an Agency-wide process, incorporating all known IT security weakness, including
IG/external audit findings associated with information systems used or operated by the Agency or by a contractor of the Agency or
other organization on behalf of the Agency?
    Yes

4d.  Does the POA&M process prioritize IT security weakness to help ensure significant IT security weaknesses are corrected in
a timely manner and receive appropriate resources?
    Yes
4e.  When  an IT security weakness is identified, do program officials (including CIOs, if they own or operate a system) develop,
implement, and manage POA&Ms for their system(s)?
     Yes
4f.  For Systems Reviewed:
    4f(l).  Are deficiencies tracked and remediated in a timely manner?
          Yes
     4f(2). Are the remediation plans effective for correcting the security weakness?
          Yes
     4f(3). Are the estimated dates for remediation reasonable and adhered to?
          Yes
4g. Do Program officials and contractors report their progress on security weakness remediation to the CIO on a regular basis (at
least quarterly)?
    Yes
4h.  Does the Agency CIO centrally track, maintain, and independently review/validate POA&M activities on at least a quarterly
basis?
    Yes
  2009 Annual FISMA Report - Environmental Protection Agency                                                          page \Q Of 15

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Question 5: IG Assessment of the Certification and Accreditation Process
Provide a qualitative assessment of the Agency's certification and accreditation (C&A) process, including adherence to existing policy,
guidance, and standards. Agencies shall follow NIST Special Publication 800-37, "Guide for the Security Certification and Accreditation
of Federal Information Systems" for C&A work initiated after May 2004. This includes use of the FIPS 199, "Standards for Security
Categorization of Federal Information and Information Systems," to determine a system impact level, as well as associated NIST
documents used as guidance for completing risk assessments and security plans.
 5a. Has the Agency developed and documented an adequate policy for establishing a C&A process that follows the NIST
 framework?
     Yes
 5b. Is the Agency currently managing and operating a C&A process in compliance with its policies?
     Yes
 5c. For Systems reviewed, does the C&A process adequately provide:
     5c(l). Appropriate risk categories
            Yes
     5c(2). Adequate risk assessments
            No
     5c(3). Selection of appropriate controls
            Yes
     5c(4). Adequate testing of controls
            No
     5c(5). Regular monitoring of system risks and the adequacy of controls
            Yes
 5d. For systems reviewed, is the Authorizing Official presented with complete and reliable C&A information to facilitate an
 informed system Authorization to Operate decision based on risks and controls implemented?
     No
             Comments:
                           Based on the systems selected for review, information security documentation was not complete nor accurate in order
                           for an authorizing official to make an informed decision to authorize a system for operation.
Question 6: IG Assessment of Agency Privacy Program and Privacy Impact Assessment (PIA) Process
                                                                                                                        Page 11 of 15
 2009 Annual FISMA Report - Environmental Protection Agency

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Provide a qualitative assessment of the Agency's process, as discussed in the SAOP section, for protecting privacy-related information,
including adherence to existing policy, guidance and standards. Provide explanatory information in the area provided.
 6a. Has the Agency developed and documented adequate policies that comply with OMB guidance in M-07-16, M-06-15, and
 M-06-16 for safeguarding privacy-related information?
     Yes
 6b. Is the Agency currently managing and operating a privacy program with appropriate controls in compliance with its policies?
     Yes
 6c. Has the Agency developed and documented an adequate policy for PIAs?
     Yes
 6d. Has the Agency fully implemented the policy and is the Agency currently managing and operating a process for performing
 adequate PIAs?
     Yes
Question 7: Configuration Management
 7a. Is there an Agency wide security configuration policy?
    Yes
 7a(l).  For each OS/platform/system for which your Agency has a configuration policy, please indicate the status of implementation for
 that policy.
OS/Platform/System
Microsoft Windows 2000
Implementation Status
Policy fu
What to(
lly implemented
)ls and techniques is your Agency using for monitoring compliance?
Tool/Technique Name
Symantec RMS, Bindview, Security
Configuration Management Tool
Lumension Patchlink
Tool Category
Network Monitoring Software
Patch Scanners
    2009 Annual FISMA Report - Environmental Protection Agency
Page 12 of 15

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OS/Platform/System
Redhat Enterprise Linux 4
IBM AIX 5
Microsoft Windows XP
Sun Solaris 9
Implementation Status
Policy fu
What to(
Policy fu
What to(
Policy fu
What to(
Policy fu
What to(
lly implemented
)ls and techniques is your Agency using for monitoring compliance?
Tool/Technique Name
Unix Security Checklist, Tripwire,
Enterprise Security Manager,
Bindview, NOS Admin, Symantec
Control Compliance Suite
Tool Category
Network Monitoring Software
lly implemented
)ls and techniques is your Agency using for monitoring compliance?
Tool/Technique Name
Afick, Symantec Control
Compliance Suite Product
Tool Category
Network Monitoring Software
lly implemented
)ls and techniques is your Agency using for monitoring compliance?
Tool/Technique Name
Symantec RMS, Bindview,Security
Configuration Management Tool
Lumension Patchlink
Tool Category
Network Monitoring Software
Patch Scanners
lly implemented
)ls and techniques is your Agency using for monitoring compliance?
Tool/Technique Name
Unix Security Checklist, Tripwire,
Bindview, NOS Admin Basic
Security Module
C2 Auditing
Enterprise Security Manager
Tool Category
Network Monitoring Software
Log Analysis Software
Vulnerability Scanners
2009 Annual FISMA Report - Environmental Protection Agency
Page 13 of 15

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OS/Platform/System
Sun Solaris 10
Implementation Status
Policy fu
What to(
lly implemented
)ls and techniques is your Agency using for monitoring compliance?
Tool/Technique Name
Unix Security Checklist, Tripwire,
Bindview, NOS Admin Basic
Security Module
C2 Auditing
Enterprise Security Manager
Tool Category
Network Monitoring Software
Log Analysis Software
Vulnerability Scanners
7b.  Indicate the status of the implementation of Federal Desktop Core Configuration (FDCC) at your Agency:
    7b(l). Agency has documented deviations from FDCC standard configuration.

           Yes

    7b(2). New Fedebral Acquisition Regulation 2008-004 language, which modified "Part 39-Acquisition of Information Technology,"
    is included in all contracts related to common security settings.
           Yes
8a.  How often does the Agency comply with documented policies and procedures for identifying and reporting incidents internally?

    90 % to 100 %
8b. How often does the Agency comply with documented policies and procedures for timely reporting of incidents to US-CERT?
    90 % to 100 %
8c.  How often does the Agency follow documented policies and procedures for reporting to law enforcement?
    90 % to 100 %
 2009 Annual FISMA Report - Environmental Protection Agency
Page 14 of 15

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Question 9: Security Awareness Training
Provide an assessment of whether the Agency has provided IT security awareness training to all users with log-in privileges, including
contractors. Also provide an assessment of whether the Agency has provided appropriate training to employees with significant IT
security responsibilities.

9a. Has the Agency developed and documented an adequate policy for identifying all general users, contractors, and system
owners/employees who have log-in privileges, and providing them with suitable IT security awareness training?
     Yes
9b. Report the following for your Agency:
     9b(l). Total number of people with log-in privileges to Agency systems.
            22,325
     9b(2). Number of people with log-in privileges to Agency systems that received information security awareness training during the
     past fiscal year, as described in NIST Special Publication 800-50, "Building an Information Technology Security Awareness and
     Training Program."
            22,281      (100  %)
     9b(3). Total number of employees with significant information security responsibilities.
            507
     9b(4). Number of employees with significant security responsibilities that received specialized training, as described in NIST
     Special Publication 800-16, "Information Technology Security Training Requirements: A Role- and Performance-Based Model."

            491         (97 %)
Question 10: Peer-to-Peer File Sharing
10. Does the Agency explain policies regarding the use of peer-to-peer file sharing in IT security awareness training, ethics training,
or any other Agency-wide training?
     Yes
2009 Annual FISMA Report - Environmental Protection Agency                                                                  p   , -  r-, -

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                                                                    Appendix A

       Summary of Significant Fiscal Year 2009
                       Security Control Audits

During Fiscal Year 2009, the U.S. Environmental Protection Agency's (EPA's) Office of
Inspector General (OIG) initiated the following audits of EPA's information technology security
program and information systems. The following synopsizes key findings.
1.  Improved Security Planning Needed for the Customer Technology Solutions
   (CIS) Project, Report No. 10-P-0028, November 16, 2009

  In general, EPA needs to (1) direct the CIS contractor to develop and implement a
  vulnerability testing and remediation process for CTS equipment, (2) issue a memorandum to
  Agency Senior Information Officials requiring their program office to conduct vulnerability
  testing of CTS equipment until a formal vulnerability testing and management process with
  CTS has been established, (3) require the CTS contractor to remediate identified
  vulnerabilities in a timely manner and inform the respective Senior Information Official when
  they complete the corrective action, and (4) ensure all key actions outlined in the conditional
  CTS authorization to operate are completed by the defined milestone dates.

2. Project Delays Prevent EPA from Implementing an Agency-wide Information
   Security Vulnerability Management Program, Report No. 09-P-0240,
   September 21, 2009

   EPA needs to (1) create plans of action and milestones for unimplemented recommendations,
   (2) update the Management Audit Tracking System to show the status of each implemented
   audit recommendation, (3) provide EPA program and regional offices with an alternative
   solution for vulnerability management, (4) establish a workgroup to solicit input on training
   needs and facilitate rolling out the Agency-wide vulnerability management program, and
   (5) issue an updated memorandum discussing guidance and requirements.

   EPA concurred with the recommendations and subsequently implemented corrective actions
   to adequately address the report recommendations.

3. ECHO Data Quality Audit - Phase I Results: The Integrated Compliance
   Information System Needs Security Controls to Protect Significant
   Non-Compliance Data,  Report No. 09-P-0226, August 31, 2009

   EPA needs to implement data security features to limit the end users' ability to change data
   field information.  EPA plans to explore additional options to restrict manual  override of data
   field information.

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4. EPA Should Delay Deploying Its New Acquisition System until Testing Is
   Completed, Report No. 09-P-0197, July 20, 2009

   EPA needs to (1) identify and document all system requirements; (2) update, review, and
   implement formal testing policies and procedures; (3) test all system requirements; (4) update
   the project schedule to communicate the current status of and future project activities; and
   (5) develop and implement oversight  procedures to ensure system development activities and
   future projects adhere to all requirements.

   EPA concurred with the findings and  will delay deployment until the next fiscal year.

5. Steps Taken But More Work  Needed to Strengthen Governance, Increase
   Utilization, and Improve Security Planning for the Exchange Network, Report
   No. 09-P-0184, June 30, 2009

   In general, EPA needs to (1) submit an updated correction action plan for unimplemented
   recommendations, (2) recertify and reaccredit the Central Data Exchange, (3) update the
   Central Data Exchange security plan and develop the contingency plan in accordance with
   federal guidance, and (4) conduct a formal, independent risk assessment for the Central Data
   Exchange.

6. Lack  of Project Plan  Resulted in Transition and Contractor Performance
   Problems for the Institutional Controls Tracking System, Report No. 09-P-0128,
   March 25, 2009

   In general, EPA needs to (1) document procedures for overseeing development activities as
   prescribed by Agency guidance, and (2) conduct and document a review of system
   documentation to ensure the document is current.

   EPA concurred with findings and recommendations and provided a complete corrective
   action plan to address the report's recommendations.

7. Review of the Quality of Self-Reported Security Information in EPA's
   Automated Security Self-Evaluation and Remediation Tracking  (ASSERT)
   System, Assignment No. 2008-0003

   The primary objective of this assignment is to determine whether EPA has implemented
   effective management control processes for maintaining the quality of the data in EPA's
   ASSERT system. The OIG plans to issue a final report by December 2009.

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As part of the Fiscal Year 2009 Federal Information Security Management Act
audit, the following series of network vulnerability reports were issued to
EPA's offices to address high-risk vulnerabilities:

   Results of Technical Network Vulnerability Assessment: EPA's Great Lakes National
   Program Office, Report No. 09-P-0185, June 30, 2009
   Results of Technical Network Vulnerability Assessment: EPA's National Computer
   Center, Report No. 09-P-0186, June 30, 2009
   Results of Technical Network Vulnerability Assessment: Region 8, Report No.
   09-P-0187, June 30,2009
   Results of Technical Network Vulnerability Assessment: EPA's Potomac Yard
   Buildings, Report No. 09-P-0188, June 30, 2009
   Results of Technical Network Vulnerability Assessment: EPA's 1310 L Street Building,
   Report No. 09-P-0189, June 30, 2009
   Results of Technical Network Vulnerability Assessment: EPA's Research Triangle Park
   Finance Center, Report No. 09-P-0227, August 31, 2009

EPA officials developed plans of action and milestones to remediate the network
vulnerabilities.
As part of the Fiscal Year 2008 Federal Information Security Management Act
audit, the following series of network vulnerability reports were issued to
EPA's offices to address high- and medium-risk vulnerabilities:

   Results of Technical Network Vulnerability Assessment: EPA Headquarters, Report No.
   09-P-0097, February 23, 2009
   Results of Technical Network Vulnerability Assessment: EPA's Research Triangle Park
   Campus, Report No. 09-P-0055, December 9, 2008
   Results of Technical Network Vulnerability Assessment: EPA's Las Vegas Finance
   Center, Report No. 09-P-0054, December 9, 2008
   Results of Technical Network Vulnerability Assessment: EPA's Radiation and Indoor
   Environments National Laboratory, Report No. 09-P-0053, December 9, 2008
   Results of Technical Network Vulnerability Assessment: Region 9, Report No.
   09-P-0052, December 9, 2008

EPA officials developed plans of action and milestones to remediate the network
vulnerabilities.

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                                                                       Appendix B

                                 Distribution
Office of the Administrator
Acting Assistant Administrator for Environmental Information and Chief Information Officer
Acting Director, Office of Technology Operations and Planning, Office of Environmental Information
Senior Agency Information Security Officer, Office of Environmental Information
Acting Director, Technology and Information Security Staff, Office of Environmental Information
General Counsel
Agency Follow-up Official (the CFO)
Agency Follow-up Coordinator
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Deputy Inspector General

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