OFFICE OF
INSPECTOR GENERAL
Semiannual
Report to Congress
October 1, 2014-March 31, 2015
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May 2015
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Index of Reporting Requirements
Inspector General Act of 1978, as amended
Requirement
Section 4(a)(2)
Section 5(a)(1)
Section 5(a)(2)
Section 5(a)(3)
Section 5(a)(4)
Section 5(a)(5)
Section 5(a)(6)
Section 5(a)(7)
Section 5(a)(8)
Section 5(a)(9)
Section 5(a)(10)
Section 5(a)(11)
Section 5(a)(12)
Section 5(a)(14-16)
Subject
Review of legislation and regulations
Significant problems, abuses and deficiencies
Significant recommendations for corrective action
Reports with corrective action not completed
Matters referred to prosecutive authorities
Information or assistance refused
List of reports issued
Summaries of significant reports
Audit, inspection and evaluation reports — questioned costs
Audit, inspection and evaluation reports — funds to be put to better use
Prior audit, inspection and evaluation reports unresolved
Significant revised management decisions
Significant management decisions with which OIG disagreed
Peer reviews conducted
Pages
40
13-37,42-43
13-25,42-43
57-78
26-37, 44, 48
None
49-51
13-25,42-43
44-45, 49-51
44-46, 49-51
45-46, 52-56
None
None
79
Abbreviations
CSB
EPA
FBI
FY
OHS
OIG
OMB
SES
U.S. Chemical Safety and Hazard Investigation Board
U.S. Environmental Protection Agency
Federal Bureau of Investigation
Fiscal Year
Office of Homeland Security
Office of Inspector General
Office of Management and Budget
Senior Executive Service
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EPA Office of Inspector General
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Message to Congress
During this semiannual reporting period, individuals from the Office of
Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA)
testified four times before congressional committees and subcommittees, which
demonstrates the keen interest Congress has in the EPA OIG's work. I updated
a committee on progress made regarding impediments the EPA OIG has faced.
Our Director for Contracts and Assistance Agreement Audits briefed a
subcommittee on how the EPA needs to improve oversight of its purchase card
program. Our Assistant Inspector General for Audit testified on EPA records
management practices, including the use of email accounts. And our Assistant
Inspector General for Investigations testified on the improper use of private
emails by the U.S. Chemical Safety and Hazard Investigation Board, for which
we also serve as the Inspector General.
Arthur A. Elkins Jr.
I am pleased to note that an external peer review of the EPA OIG Office of Investigations, completed during
the semiannual reporting period by another federal Inspector General, identified no deficiencies and found
internal safeguards and management procedures compliant with quality standards. In addition, the EPA
OIG's audit organization is currently undergoing an external peer review by a federal Inspector General.
A 2012 peer review of our audit function—the last one completed—did not identify any deficiencies.
Spurring the Agency to Action
The OIG is committed to helping improve EPA efficiencies, and several of our past audit and evaluation
efforts spurred the agency to take actions that have yielded important health and fiscal management results.
For instance, in December 2014, the EPA announced the issuance of its health assessment for the Libby
Amphibole Asbestos Superfund Site in Libby, Montana, as a result of our recommendations. In addition, as a
result of several OIG reports on EPA warehouses, the Deputy Administrator ordered an agencywide review
of all warehouses and storage facilities, which could potentially save as much as $8.9 million.
Protecting Human Health and the Environment
During this reporting period, we continued to propose ways in which the agency could better protect
human health and the environment. In our review of the EPA's oversight of state and local Clean Air Act
Title V programs' fee-based revenue practices, we found that consistent revenue shortfalls could
jeopardize the program and impact compliance monitoring for many of the nation's largest air polluters.
For nine of the nation's largest permitting authorities, we noted a $69 million shortfall out of $672 million
in expenses incurred by these authorities. Further, as Americans nationwide grappled with issues
pertaining to the Ebola virus, the OIG found that the agency could do more to provide complete and
consistent information on EPA Web pages on disinfectants for use against the virus. We also issued a
quick reaction report to note our concern about how the lack of pesticide inspections in North Dakota
might result in exposure to unsafe pesticides and risks to human health and the environment.
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Saving Taxpayer Dollars
We provided the EPA Administrator data on eight EPA employees who had recorded significant amounts
of administrative leave, some for more than a year, at a cost of more than $1 million. Further, we found
that the EPA spent $780,703 in questionable costs related to spending of Coastal Wetlands, Planning,
Protection and Restoration Act funds. All $1.2 million drawn by a regional planning commission in
Massachusetts was questionable due to federal policies not being followed, and the commission already
has agreed to repay $98,891 of that amount. A contractor overbilled the EPA $910,776 for helpdesk
services on an Office of Environmental Information contract.
Investigating Fraud and Abuse
As a result of our investigative work, two scientists who obtained research grants were found guilty of
falsifying records. Further, a company received a $1.2 million fine for illegally manufacturing paints that
contained a pesticide. In addition, a Canadian company agreed to pay $2.7 million in connection with a
New Jersey kickback scheme, and several Montana tribal officials were given jail time for fraud. We also
noted instances of abuse committed by EPA Senior Executive Service-level employees involving
inappropriate use of EPA resources, potential conflict of interest, sexual misconduct, and improper
approval of time and attendance records.
Building Bridges
During the semiannual reporting period, I made various trips to EPA regional offices and met with senior
agency leaders to get a feel for some of their major concerns. In addition, I made a number of field trips,
where I met with state and local officials, business and community leaders, and others. I was generally
accompanied by regional staff during these field trips, and the EPA leaders who accompanied me also had
an opportunity to learn and converse with people in the communities. As a result, these trips helped build
bridges on many levels, enabling the EPA to better serve communities.
Proactive Steps by Agency Help the Most Vulnerable
This report contains numerous examples where the agency could have put funds to better use, done more
to improve efficiencies, or improved business practices and accountability. However, I also want to
commend the agency on its successes, including helping to protect our most vulnerable neighborhoods
from air toxics. Protecting our neighborhoods from air toxics or pollutants known or suspected to cause
cancer or other serious health effects is something we all should be concerned about, and the Office of
Enforcement and Compliance Assurance has developed several tools to help regions target potentially
overburdened environmental justice communities for air toxics inspections.
Arthur A. Elkins Jr.
Inspector General
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Table of Contents
About EPA and Its Office of Inspector General 1
Furthering EPA's Goals and Strategies 2
Scoreboard of Results 3
Congressional Testimony 4
Actions Taken on Prior Reports Result in
Improved Efficiencies and Environment 8
OIG Identifies Funds to Put to Better Use and
Potential Health and Environment Concerns 11
Agency Best Practices Noted 12
Significant OIG Activity 13
Human Health and Environment Issues 13
Agency Business Practices and Accountability 18
I nvestigations 26
Other Activities 38
U.S. Chemical Safety and Hazard Investigation Board 41
Statistical Data 44
Profile of Activities and Results 44
Audit, Inspection and Evaluation Report Resolution 45
Hotline Activity 47
Summary of Investigative Results 48
Appendices 49
Appendix 1—Reports Issued 49
Appendix 2—Reports Issued Without Management Decisions 52
Appendix 3—Reports With Corrective Action Not Completed 57
Appendix 4—Peer Reviews Conducted 79
Appendix 5—OIG Mailing Addresses and Telephone Numbers 80
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
About EPA and Its
Office of Inspector General
U.S. Environmental Protection Agency
The mission of the U.S. Environmental Protection Agency (EPA) is to protect
human health and the environment. As America's steward for the environment since
1970, the EPA has endeavored to ensure that the public has air that is safe to breathe,
water that is clean and safe to drink, food that is free from dangerous pesticide residues,
and communities that are protected from toxic chemicals.
EPA Office of Inspector General
The Office of Inspector General (OIG), established by the Inspector General Act of 1978,
as amended, 5 U.S.C. App. 3, is an independent office of the EPA that detects and
prevents fraud, waste and abuse to help the agency protect human health and the
environment more efficiently and cost effectively. OIG staff are located at headquarters
in Washington, B.C.; at the EPA's 10 regional offices; and at other EPA locations,
including Research Triangle Park, North Carolina, and Cincinnati, Ohio. The EPA
Inspector General also serves as the Inspector General for the U.S. Chemical Safety and
Hazard Investigation Board (CSB).
Our vision, mission and goals are as follows:
Be the best in public service and oversight for a better environment tomorrow.
Mission
Promote economy, efficiency, effectiveness, and prevent and detect fraud, waste, and
abuse through independent oversight of the programs and operations of the EPA and
CSB.
1. Contribute to improved human health, safety, and environment.
2. Contribute to improved EPA and CSB business practices and accountability.
3. Be responsible stewards of taxpayer dollars.
4. Be the best in government service.
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Furthering EPA's Goals and Strategies
When conducting our audit and evaluation work during the first half of fiscal year (FY) 2015, we took into
account the EPA's five strategic goals and four cross-agency strategies in the agency's FYs 2014-2018
Strategic Plan. The table below shows how our reports on the EPA aligned with the agency's goals/strategies.
OIG-lssued Reports — Linkage to EPA Goals and Strategies
OIG Report Title/Number
EPA's Fleet Management Program Needs
Improvement (15-P-0001)
EPA Region 6 Mismanaged Coastal Wetlands
Planning, Protection and Restoration Act Funds
(15-P-0003)
Enhanced EPA Oversight Needed to Address
Risks From Declining Clean Air Act Title V
Revenues (15-P-0006)
No Significant Residual Contamination Found at
Deleted Superfund Sites, But Security Fences
Were Damaged at Some Sites (15-P-0013)
Fiscal Year 2014 Federal Information Security
Management Act Report: Status of EPA's
Computer Security Program (15-P-0020)
Audit of EPA's Fiscal Years 201 4 and 201 3
(Restated) Consolidated Financial Statements
(15-1-0021)
Early Warning Report: Some EPA Employees
Found to Be on Paid Administrative Leave for
Years (15-N-0025)
EPA Needs to Demonstrate Public Health Benefits
of Drinking Water State Revolving Fund Projects
(15-P-0032)
EPA Needs Better Management of Personal
Property in Warehouses (15-P-0033)
Call Center: Contract Management Needs
Improvement to Reduce the Risk of Overbilling
(15-P-0042)
EPA Needs to Improve Outreach and Communi-
cation About the National Pesticide Information
Center's Role and Services (15-P-0046)
Quick Reaction Report: Complete and Clear Infor-
mation on the Effectiveness of Ebola Disinfectants
Will Better Inform the Public (15-P-0064)
Costs of $1 .2 Million for Brownfields Cooperative
Agreement to Pioneer Valley Planning Commis-
sion in Massachusetts Questioned (15-4-0072)
Quick Reaction Report: EPA Pesticide Inspections
Must Resume in North Dakota to Determine
Compliance and Protect Human Health and the
Environment (15-P-0099)
EPA Regions Have Considered Environmental
Justice When Targeting Facilities for Air Toxics
Inspections (15-P-01 01)
EPA Needs to Justify How It Is Using Title 42
Hiring Authority (15-P-0109)
To Ensure Greater Use of Scientific Equipment,
the Office of Research and Development Should
Use an Enterprise Approach to Property
Management (15-P-01 15)
Climate
Change/
Air
Quality
X
X
Protecting
America's
Waters
X
X
Cleaning
Communities/
Sustainable
Development
X
Safe
Chemicals/
Preventing
Pollution
X
X
X
Enforcing
Laws/
Ensuring
Compliance
X
X
X
Working
Toward
Sustainable
Future
Making
Difference in
Communities
X
X
State, Tribal,
Local and
International
Partnerships
X
Embracing
EPA as High-
Performing
Organization
X
X
X
X
X
X
X
X
X
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Scoreboard of Results
The information below shows the taxpayers' return on investment for the work performed by the EPA
OIG during the first half of FY 2015 compared to FY 2015 annual performance goal targets. All results
reported are based on goals and plans established based on the Government Performance and Results Act.
Annual Performance Goal 1:
Environmental and business outcome actions taken or realized by the EPA (based on OIG recommendations)
Target: 268
Reported: 76
(28.35% of goal)
Supporting measures
73 Environmental and management actions implemented or improvements made
2 Critical congressional and public concerns addressed
1 Legislative or regulatory change made
Annual Performance Goal 2:
OIG environmental and business output recommendations, awareness briefing or testimony (for agency action)
Target: 967
Reported: 435
(44.98% of goal)
Supporting measures
397 Environmental and management recommendations or referrals for action
2 Environmental and management certifications, verifications and validations
17 Environmental and management risks and vulnerabilities identified
19 External awareness briefings, training or testimony given
Annual Performance Goal 3:
Monetary return on investment - potential monetary return on investment as percentage of budget
Target: 220% return on
investment
Reported: $66.2 million
(128% return on
investment)
Supporting measures (dollars in millions)
$4.66 Questioned costs
$61.60 Recommended efficiencies, costs saved
$6.01 Fines, penalties, settlements and restitutions
Annual Performance Goal 4:
Criminal, civil and administrative actions reducing risk or loss/operational integrity
Target: 175
Reported: 74
(42% of goal)
Supporting measures
7 Criminal convictions
16 Indictments, informations and complaints
1 Civil action
31 Administrative actions (other than debarments or suspensions)
19 Suspension or debarment actions
0 Allegations disproved
Other (no targets established)
Savings and recommendations sustained from current and prior periods:
• $12.61 million in questioned costs sustained
• $0.15 million in cost efficiencies sustained or realized (21% of cost efficiencies claimed)
• 166 recommendations sustained (70% of recommendations issued)
Reports Issued:
• The OIG issued 27 reports.
• The Single Audit Act requires agencies to resolve findings and recommendations that are reported in single audit
reports by independent auditors. Based upon our reviews, we issued 101 memo reports to the agency
questioning $2.5 million and identifying 160 findings that required agency action. We track the agency's resolution
through the related memo report number.
Sources: OIG Performance Measurement and Results System and Inspector General Enterprise Management System.
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Congressional Testimony
Inspector General Updates Committee on Independence Issues
On February 3, 2015, Inspector General Arthur A. Elkins Jr. testified before the
Committee on Oversight and Government Reform, U.S. House of
Representatives, to update the committee on the progress made regarding
impediments to access faced by the EPA OIG since Elkins' last testimony.
Regarding impediments involving the EPA's Office of Homeland Security (OHS), the
OIG met with senior agency officials multiple times since the last hearing, and the
Inspector General said "we have reached at least a theoretical agreement on a substantial
portion of the issues," including access to information so that the OIG investigates threats
against EPA employees and facilities, conducts certain misconduct investigations, and
investigates computer intrusions. The OIG still has two caveats, regarding:
• The implementation of agreements.
• OHS having a criminal investigator even though it lacks investigative authority.
The OIG and the agency have agreed that there is no category of activity at the EPA—
including in OHS—to which the OIG does not have unfettered access, as provided by the
Inspector General Act. However, the EPA had unilaterally entered into a memorandum of
understanding with the Federal Bureau of Investigation (FBI) that the EPA asserted
precluded it from sharing information with the OIG. FBI senior management has since
indicated that it does not require withholding information from the OIG. A three-way
meeting among the EPA, OIG and FBI is still needed to rescind or substantially modify
the memorandum of understanding. Regarding OHS's conducting investigative activities
on its own, thereby interfering with—and in some cases fouling—OIG investigations, we
still do not know whether OHS continues to conduct investigative activity.
Inspector General Elkins also discussed recent problems with interviewing individuals,
which he said represent "big picture challenges that my office, and many other OIGs
from across the government, continue to face." Elkins provided several examples:
• An Office of General Counsel attorney refused to cooperate with the OIG even
when prompted (although not directed) by the agency to do so. While the agency
had the opportunity to take disciplinary action against the attorney for this failure
to cooperate with the OIG, it did not do so. Rather, the attorney eventually left
the EPA to work for another federal agency.
• Another instance involves a GS-15 program advisor in the Office of Research
and Development who refused to cooperate with the OIG as part of an
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Semiannual Report to Congress October 1, 2014—March 31, 2015
administrative investigation regarding violations of security policy. This action is
still pending, but to the OIG's knowledge the agency has not taken any action
against this EPA employee for not cooperating with the OIG.
Also, Elkins noted that although the Inspector General Act gives the OIG unfettered
access to all information "available" to its department or agency, including access to
people, the act "provides no remedy for an employee's violation of this obligation." For
example, the OIG was investigating allegations that a senior EPA employee engaged in
inappropriate behavior with 16 women, violated security procedures, and mishandled
classified information. While the OIG had interviewed the senior official during the
initial stages of the investigation, the OIG determined that it needed to interview the
official again. However, by that time, the employee was on paid administrative leave and
refused to cooperate. When the OIG requested the follow-up interview, the employee
retired within one day, and the OIG had no further access to the person and the agency
had no disciplinary remedies available to it.
"I believe that this committee should look into the 'gap' between what the IG Act
requires and OIG's ability to achieve those requirements in such circumstances. Subject
to constitutional due process rights, there might be ways to strengthen an agency's ability
to discipline an employee for failure to comply with an OIG request," Elkins testified.
Also, Elkins noted during his testimony that there is a "disconnect between what the
oversight committees observe and the appropriations that emerge from Congress as a
whole." Although he acknowledged he was not testifying before an appropriations
committee, Elkins noted that while the EPA OIG returned $7.33 for every dollar given to
it in the past year, the budget levels made available to the EPA OIG "are impeding our
ability to do our work.... When the OIG is not able to carry out its responsibilities
because of inadequate funding, it is a net loss to the federal government and American
taxpayers."
Testimony Given on Records Management, Including Emails
On March 26, 2015, Kevin Christensen, the EPA OIG Assistant Inspector General
for Audit, testified on EPA records management practices—including the use of
email accounts—before the Committee on Science, Space, and Technology,
Subcommittees on Oversight and Environment, U.S. House of Representatives.
Christensen noted that an EPA OIG audit on emails, issued in September 2013, did not find
any evidence that senior EPA officials used emails to circumvent records management
responsibilities, but did note that improvements in email practices are needed.
"We found no evidence that senior EPA officials had used, promoted or encouraged the
use of private 'nongovernmental' email accounts to circumvent records management
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Semiannual Report to Congress October 1, 2014—March 31, 2015
responsibilities or reprimanded, counseled or took administrative actions against
personnel for using private email or alias accounts for conducting official business,"
Christensen said.
Christensen said that the previous Administrator and subsequent acting Administrator
each had two EPA email accounts—one intended for messages from the public and one
for communicating with select senior management officials. We found that others in the
agency also followed this practice, and Christensen noted that this practice "presents risks
to the agency's records management efforts if these additional email accounts are not
searched to preserve federal records."
In response to our 2013 audit report recommendations, Christensen said that the EPA
published an updated interim records management policy providing guidance on emails,
and developed a process to train all EPA employee and contractors on their records
management responsibilities. The EPA also reported completing corrective action to
implement an electronic content management tool to capture email records with the
agency's new email system.
OIG Director Testifies on Need to Improve Purchase Card Program
On October 14, 2014, an OIG Director testified before the U.S. House of
Representatives' Oversight and Government Reform Committee, Subcommittee
on Government Operations, on how the EPA needs to improve oversight of its
purchase card program.
"Overall, we found that the EPA's oversight is not effective—
because of inattention to EPA policies by cardholders, approving
officials and the purchase card team—to ensure that purchase
cardholders and approving officials comply with internal control
procedures," noted Janet Kasper, Director, Contracts and Assistance
Agreement Audits, in her statement to the subcommittee.
Kasper's testimony was based on a March 2014 EPA OIG report,
Ineffective Oversight of Purchase Cards Results in Inappropriate
Janet Kasper testifies before a Purchases at EPA (14-P-0128), which reviewed 80 of 67,000
congressional subcommittee. purchase card transactions. Of the 80 transactions, valued at
$152,602, Kasper said that $79,254 involved prohibited, improper
and erroneous purchases. As a result of our report, the agency stopped the purchase of gift
cards for employee recognition while it assesses its policies, requires training, and
implements an automated system for documenting and approving transactions. "Improved
purchase card oversight potentially saves money by reducing prohibited, improper and
erroneous purchases, which would be especially helpful in the current budget
environment," Kasper said.
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Semiannual Report to Congress October 1, 2014—March 31, 2015
The EPA continues to take action to improve oversight of purchase cards. On March 24,
2015, the EPA Office of Acquisition Management issued a memorandum, "Purchase
Card Oversight," to all Senior Resource Officials. The memorandum outlines actions the
agency is taking as a result of the OIG audit report. The Office of Acquisition
Management has created a new business model to significantly improve internal control
for how the agency manages and oversees purchase cards and convenience checks. The
improvements include reducing the number of rarely used accounts; developing and
implementing revised training for all cardholders and approving officials; and revising
purchase card policy/guidance to mandate a standard purchase card transaction process,
minimum documentation requirements supporting purchase card purchases, and a zero-
tolerance disciplinary action policy. In addition, the Office of Acquisition Management
has incorporated compliance reviews and oversight into its performance management and
quality assurance programs. The improvements undertaken by the agency are good
examples of the impact and value of OIG work products.
In addition to our report on the agency's purchase card controls, to improve OIG
transparency, the OIG published a report on its own controls for purchase cards. That
report, Ineffective Oversight of Purchase Cards Resulted in Improper Purchases at
EPA OIG (15-B-0014), issued November 10, 2014, found internal control weaknesses for
46 of 48 transactions reviewed. Although we did not find any fraudulent or prohibited
transactions, we found that $36,488 in transactions were improper because they were
outside the cardholder's authority or should not have been made under the administrative
requirements. We made various recommendations for the OIG to improve procedures,
and we have initiated corrective actions.
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Actions Taken on Prior Reports Result in
Improved Efficiencies and Environment
OIG Efforts Contribute to Libby Superfund Site Cleanup
The EPA announced in a December 8, 2014, press release that it has issued its
health assessment for the Libby Amphibole Asbestos Superfund site in Libby,
Montana, which found that the agency's indoor and outdoor cleanups have been
effective in reducing both cancer and non-cancer risks. The OIG had
recommended that the agency conduct such an assessment.
"The agency's acceptance and implementation of the OIG's recommendation to execute a
comprehensive amphibole toxicity assessment to determine the effectiveness of the Libby
removal actions, and the positive outcome of that assessment, represents a good example
of the value of OIG work products in helping the agency achieve its mission to protect
public health and the environment," noted Inspector General Elkins.
In 2009, the EPA declared the agency's first public health emergency at the Libby
Superfund site because of amphibole asbestos contamination, which has cost over
$400 million to clean up. The vermiculite mined in Libby was sold as agricultural
fertilizer or as household insulation nationwide. It was contaminated with amphibole
asbestos, which resulted in contamination in Libby as well as the rest of the country.
The OIG had issued a number of reports on the Libby cleanup effort, including the report
EPA Needs to Plan and Complete a Toxicity Assessment for the Libby Asbestos Cleanup
(2007-P-00002), issued December 5, 2006. In that report, we recommended that the EPA
"fund and execute a comprehensive amphibole toxicity assessment" to determine the
effectiveness of the Libby removal actions and whether more actions are necessary. A
former Senator from Montana was a strong advocate of the OIG report and wrote an open
letter to the EPA urging acceptance of the recommendations. The agency subsequently
responded that "We recognize the importance of this assessment, and we are working to
finalize it while ensuring that it reflects the best possible science."
In the December 2014 press release, Region 8 Regional Administrator Shaun McGrath
said that "EPA's scientific evaluation shows that our cleanup approach is working and we
are reducing health risks for residents in the community." The press release further noted
that the assessment—an Integrated Risk Information System health assessment—shows
that "the asbestos air concentrations in Libby today are about 100,000 times lower than
when mine and processing facilities were in operation, making the air quality in Libby
similar to other Montana cities. The information will be used to identify how exposures
can be reduced to protect human health now and in the future." The Integrated Risk
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Information System values now provide a means to calculate health-based limits of
amphibole asbestos exposures for the rest of the country.
EPA Develops New "Safer Choice" Logo Following OIG Report
Subsequent to the EPA OIG issuing a report that recommended the EPA come
up with a new Design for the Environment logo "that better conveys the
program's objective and eliminates any appearance of an EPA endorsement,"
the agency developed and implemented a new logo.
For more than 15 years, the EPA's Design for
the Environment Safety Product Labeling
Program has labeled products that meet the
criteria to be considered safer for families and
the environment. Products include carpet
cleaners, dish and hand soaps, floor care
products, laundry detergents, glass cleaners, and
car care products. Our report, EPA Can Help
Consumers Identify Household and Other
Products with Safer Chemicals by Strengthening Its "Design for the Environment"
Program (14-P-0349, issued September 9, 2014), noted that the logo used "does not
adequately communicate to the consumer that the product is a safer product." We also
found a risk that an EPA endorsement may be implied by the prior logo, but EPA
endorsement is not allowed. The agency concurred with our report, and recently issued a
new "Safer Choice" logo.
Agency Issues EPA Order in Response to OIG Audit on Passports
SAFER
CHOICE
Meets U.S. EPA
Safer Product
Standards
epa.gov/saferchoice
The old logo (left) and new logo.
(EPA images)
In response to our recommendation in a 2014 audit report to develop and
implement an agencywide policy for managing official passports issued to
EPA employees, the agency on March 12, 2015, issued EPA Order 2656,
No-Fee Passport Application Acceptance Program Policy, to improve controls for
processing and managing passports.
In our Audit of EPA Passport Controls (14-P-0243, issued May 1, 2014), we found that
the EPA Office of International and Tribal Affairs, which is responsible for obtaining and
monitoring EPA passports, was not in compliance with agency guidance over the control
and security of sensitive personally identifiable information—specifically, official and
diplomatic passports issued to agency employees. We noted that the agency lacked a
formal written policy and procedure for issuing, monitoring and securing passports. Of
the 417 passports purported to be in the Office of International and Tribal Affairs,
199 could not be located.
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Before (top) and after photos at the
National Service Center for
Environmental Publications in Blue
Ash, Ohio. As a result of our report,
the center recycled nearly 8 million
publications. (EPA OIG photos)
EPA Takes Actions to Better Manage Warehouses
As a result of several reports the OIG had issued regarding EPA management of
its warehouses, the EPA already has made significant improvements at its
warehouses across the country.
On December 8, 2014, we issued a report, EPA Needs Better
Management of Personal Property in Warehouses (15-P-0033),
which noted some overarching problems at warehouses storing EPA
property. This followed an early warning report we issued in May
2013 regarding problems at the EPA's headquarters warehouse in
Landover, Maryland, and a March 2014 early warning report
regarding the agency's publications warehouse in Blue Ash, Ohio.
As a result of our various reports, the Deputy Administrator issued
three memorandums that identified corrective actions taken by the
agency. At one warehouse, the agency indicated it inventoried and
identified the dollar value of furniture, conducted records
management training, reviewed and disposed of records, and sold
furniture. At another warehouse, the agency recycled nearly
8 million publications. The Deputy Administrator also ordered an
agencywide review of all warehouses and storage facilities,
including a review of agency employee actions, for potential
performance failures and necessary disciplinary actions.
EPA Proposes Rule for Disposal of Pharmaceutical Hazardous Waste
In March 2015, the EPA submitted a proposed rule to the OMB, "Management
Standards for Hazardous Waste Pharmaceuticals," based on its outreach efforts
with states and health care facilities. This rule addresses the recommendations
the OIG made in a 2012 report, EPA Inaction in Identifying Hazardous Waste
Pharmaceuticals May Result in Unsafe Disposal (12-P-0508), to address EPA's
inaction in updating its list of hazardous waste Pharmaceuticals.
Specifically, the OIG recommended that the EPA establish a process to review
Pharmaceuticals for regulation as hazardous waste and develop an outreach and
compliance assistance plan for health care facilities in managing hazardous waste
Pharmaceuticals. In the proposed rule, the EPA asks whether it should develop and
promulgate new criteria that treats all discarded pharmaceuticals as hazardous wastes.
The agency indicated no regulatory action is being proposed with respect to expanding
the number of hazardous waste pharmaceuticals and any action taken will be part of a
separate proposed future rulemaking.
10
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Semiannual Report to Congress October 1, 2014—March 31, 2015
OIG Identifies Funds to Put to Better Use and
Potential Health and Environment Concerns
During the semiannual reporting period, a number of reports that we issued noted
instances of funds that could be put to better use. For example:
• The EPA spent $780,793 in questionable costs related to Region 6 implementation
of Coastal Wetlands, Planning, Protection and Restoration Act funds.
• The EPA can achieve up to $8.9 million in monetary benefits by improving the
management of property at its warehouses.
• All $1.2 million drawn by a regional planning commission in Massachusetts was
questioned due to federal policies not being followed, and the commission
already has agreed to repay $94,891 of that amount.
• A contractor overbilled the EPA by $910,776 for helpdesk services on an Office
of Environmental Information contract.
In addition, we found instances in which the EPA can better protect human health and the
environment. For example:
• Diminishing revenues from fees charged to Title V facilities (the nation's largest
stationary sources of air pollution) could jeopardize program implementation and
adversely impact compliance monitoring for many of the nation's largest sources
of air pollution.
• To better address public concerns about the Ebola virus, the agency can better
ensure that relevant EPA Web pages have ongoing, clear information about the
effectiveness of disinfectants for use against the virus.
• Individuals in North Dakota and elsewhere may be exposed to unsafe pesticides
because EPA Region 8 and the state were not conducting sufficient inspections.
• The EPA needs to obtain more data from states for Drinking Water State
Revolving Fund loan projects to demonstrate public health results achieved from
the more than $ 11 billion the EPA has invested in drinking water infrastructure
since 2009.
Details on these issues are in the "Significant OIG Activity" section.
11
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Agency Best Practices Noted
During the semiannual reporting period, several reports that we issued highlighted
"best practices" of value to other components in the agency. Examples follow.
• Increased charges for call center services had not been communicated with
program offices in the headquarters, regions and centers until the end of the fiscal
year. To avoid unexpected year-end increases in costs and assist in managing the
budget, the EPA's Office of Environmental Information started providing
customers with a Monthly Utilization Report to inform them of actual usage.
(Report No. 15-P-0042, Call Center: Contract Management Needs Improvement
to Reduce the Risk ofOverbilling, December 23, 2014)
• The EPA Office of Enforcement and Compliance Assurance is beginning to
use the agency's GeoPlatform tool in conjunction with environmental justice
community data (EJSCREEN) to produce targeting tools that allow EPA
regions to more easily factor environmental justice in air toxics facility
inspection plans. GeoPlatform allows the EPA to develop and share detailed
maps of selected environmental stressors in a given geographical area. The
Office of Enforcement and Compliance Assurance recently developed two
GeoPlatform targeting tools for air toxics. By using these new tools, EPA
Region 1 has produced a regional map view of leaking storage tanks in areas
of potential environmental justice concern that would not be available to
regions using EJSCREEN alone. (ReportNo. 15-P-0101, EPA Regions Have
Considered Environmental Justice When Targeting Facilities for Air Toxics
Inspections, February 26, 2015)
• In support of the headquarters program offices and regions and centers, the
EPA Office of Administration and Resources Management plans to improve
management of the $6 million-per-year fleet program through monthly usage
and operator responsibility checks. (Report No. 15-P-0001, EPA 's Fleet
Management Program Needs Improvement, October 6, 2014)
12
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Significant OIG Activity
Human Health and Environment Issues
Clean Air Act Title V Program Expenses Exceeded Permit Revenues
We found significant weaknesses in the EPA's oversight of state and local Title V
programs' fee revenue practices. Annual Title V program expenses often
exceeded annual revenues from fees charged to Title V facilities. This could
jeopardize program implementation and adversely impact compliance monitoring
for many of the nation's largest sources of air pollution.
Clean Air Act Title V permit fees are used to implement and enforce the permitting
program for the nation's largest stationary sources of air pollution. This includes acting
on new permit applications and revisions or renewals, monitoring facility compliance,
and taking enforcement actions for noncompliance.
Our survey of nine of the nation's largest permitting authorities
(eight states and a regional authority) showed that annual
Title V revenues were not sufficient to cover annual Title V
expenses 62 percent of the time from 2008 to 2012. We noted a
$69 million shortfall out of $672 million in expenses incurred
by these authorities during that time. Periodic monitoring of
facility compliance, to ensure adequate protection of human
health and the environment, could be adversely impacted by
insufficient funding.
A smokestack at a coal-fired power plant.
(EPA photo)
We recommended that the EPA assess, update and re-issue its 1993 Title V fee guidance
as appropriate, establish a fee oversight strategy, and emphasize and require periodic
reviews of Title V fee revenue and accounting practices. The agency agreed with all
recommendations and provided corrective action plans.
(Report No. 15-P-0006, Enhanced EPA Oversight Needed to Address Risks From
Declining Clean Air Act Title VRevenues, October 20, 2014)
13
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
EPA Needs to Better Inform Public About Ebola Disinfectants
A training participant with a
jug of chlorinated
disinfectant prepares to
demonstrate a disinfection
procedure. (Centers for
Disease Control and
Prevention photo)
Our quick reaction report on the completeness and consistency of information
provided on the EPA's website concerning disinfectants for use against the Ebola
virus found that relevant EPA Web pages should have ongoing, clear information
about the effectiveness of disinfectants for use against the Ebola virus.
The EPA's Web page http://www.epa.gov/oppad001/list-l-ebola-virus.html.
Disinfectants for Use Against the Ebola Virus, contains a list (known as
List L) of 192 registered disinfectants that meet the Centers for Disease
Control and Prevention criteria for hospital disinfectants. Of the 192
products listed, 29 recently registered products (since 2010) have not been
tested for effectiveness by the EPA's Antimicrobial Testing Program, and
that status is not disclosed on the Web page. In addition, we identified eight
products on List L that are not listed on the EPA's Antimicrobial Testing
Program Web page.
We recommended that the EPA update its Web pages as needed. The
agency agreed with our recommendations and completed necessary actions.
(Report No. 15-P-0064, Quick Reaction Report: Complete and Clear
Information on the Effectiveness of Ebola Disinfectants Will Better Inform
the Public, January 21, 2015)
Federal Pesticide Inspections Not Being Conducted in North Dakota
EPA Region 8 was not conducting inspections at establishments that produce
pesticides and inspections of pesticide imports in North Dakota, and North
Dakota did not have a state inspector with qualifications equivalent to a federal
inspector to conduct inspections on the EPA's behalf. This may result in
exposure to unsafe pesticides and risks to human health and the environment.
The Federal Insecticide, Fungicide and Rodenticide Act regulates the safe use of pesticides
in the United States. An EPA inspector or credentialed state inspector is required to
conduct inspections of pesticide establishments and imported pesticides to ensure
compliance with the act. While assessing state inspections, we found that federal
inspections of pesticide establishments had not occurred in North Dakota for 14 years and
the last import inspection was conducted in 2011. EPA staff said this was the case because
North Dakota officials did not want federal inspections conducted in their state.
14
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
We recommended that the EPA immediately initiate appropriate inspections in North
Dakota and take other necessary actions, and the agency agreed with our recommendations.
(Report No. 15-P-0099, Quick Reaction Report: EPA Pesticide Inspections Must Resume
in North Dakota to Determine Compliance and Protect Human Health and the
Environment, February 23, 2015)
EPA Needs to Better Communicate Pesticide Information Center Role
A lack of outreach and communication with states has resulted in confusion
regarding the role of the National Pesticide Information Center, which has led to
confusion and dissatisfaction with the center's services.
The mission of the National Pesticide Information Center is to
operate a call center that provides information to medical
professionals, veterinarians and the public regarding pesticide-related
issues, including pesticide product usage, pesticide identification and
pesticide health effects. The center, funded by a cooperative
agreement between the EPA and Oregon State University, also
operates a website. While the center can provide product-specific
information to state and local governments if a spill occurs, it does not determine whether
an incident constitutes a violation of state or federal law.
Pesticide application. (EPA photo)
The National Pesticide Information Center's role is not well understood, and that has led
to confusion and dissatisfaction by some state lead agencies. This confusion stems from
the lack of outreach regarding the center's role. Although there is no requirement in the
program's statutory basis to engage in proactive outreach or communication with the
states, we believe such action would be beneficial. We made recommendations for the
center to improve its outreach, and the center agreed with our recommendations and
initiated corrective actions.
(Report No. 15-P-0046, EPA Needs to Improve Outreach and Communication About the
National Pesticide Information Center's Role and Services, January 7, 2015)
EPA Needs to Obtain Drinking Water Fund Data From States
The EPA did not obtain all required Drinking Water State Revolving Fund loan
project data from states. The EPA needs such data to demonstrate public health
results of the $11.37 billion it has invested in drinking water infrastructure since
2009.
The 1996 Safe Drinking Water Act Amendments authorize the EPA to provide funding
for capitalization grants to states for drinking water projects. The states use these funds to
15
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
support low-interest loans and other types of assistance to public water systems. The EPA
capitalization grant agreements direct states to inform the EPA about project-level data
on a quarterly basis.
The EPA did not always obtain the required Drinking Water State Revolving Fund loan
project data from states, and the EPA does not always use annual reviews of state
programs to assess project outcomes. Incomplete data hamper the EPA's ability to
evaluate program effectiveness and public health outcomes. We recommended that the
EPA enforce grant requirements for states to input data and review data completeness as
part of the agency's annual review. The agency agreed with our recommendations and
provided corrective actions.
(Report No. 15-P-0032, EPA Needs to Demonstrate Public Health Benefits of
Drinking Water State Revolving Fund Projects, December 5, 2014)
EPA Considers Environmental Justice When Selecting
Air Toxics Facilities to Inspect
All 10 EPA regions have considered environmental
justice when targeting facilities for air toxics
inspections, and the implementation of new tools
should enhance agency efforts.
A podcast on this report on
environmental justice is at:
http://www.epa.gov/oiq/rep
orts/2015/report 15-P-
0101 podcast 02-25-
2015. mp3.
Air toxics are pollutants known or suspected to cause cancer or other serious health
effects. Communities that experience elevated or disproportionate impacts from air toxics
may be areas of environmental justice concern. Executive Order 12898 on environmental
justice directs federal agencies to identify and address any of their programs, policies and
activities that may have disproportionately high and adverse environmental or human
health effects on minority and low-income populations.
The EPA Office of Enforcement and Compliance Assurance has developed several tools
to help regions select air toxics facilities for inspection. One tool—the High-Risk
Facilities list—identifies large facilities in areas with elevated
cancer risks associated with air toxics. The office also
developed new mapping tools to help regions target potentially
overburdened communities for air toxics inspections. Because
of the actions being taken, we did not make any
recommendations.
A neighborhood in close proximity to an
operating power plant. (EPA photo)
(Report No. 15-P-0101, EPA Regions Have Considered
EnvironmentalJustice When Targeting Facilities for Air
Toxics Inspections, February 26, 2015)
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Evidence of Trespassing and Vandalism at Some Superfund Sites
Could Pose Health Risks
During the OIG's assessment of whether hyperspectral imaging data can be
used to help assess pollutant concentrations at deleted Superfund sites, we
found evidence of trespassing and vandalism at two sites in Pennsylvania.
Hyperspectral imaging is a remote sensing tool that can collect and process information
from across the electromagnetic spectrum. Imaging identified vegetation stress at three
sites but results of soil testing did not confirm that this was due to elevated pollutant
concentrations. Further, results of soil testing did not identify any significant residual soil
contamination at the 11 Pennsylvania sites reviewed. However, on-site observations
found significant amounts of debris at two sites. Further, fences surrounding those two
sites were damaged and evidence of trespassing and vandalism were found, thus exposing
trespassers to safety or health risks. The EPA agreed to take sufficient corrective actions.
(Report No. 15-P-0013, No Significant Residual Contamination Found at Deleted
Superfund Sites, But Security Fences Were Damaged at Some Sites, November 10, 2014)
Left: Hyperspectral image of vegetation stress at the Taylor Borough Dump site,
Taylor, Pennsylvania. (U.S. Geological Survey-created image from hyperspectral data)
Right: Aerial photo of the Taylor Borough Dump site. (EPA photo)
17
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Agency Business Practices and Accountability
Employees Found to Be on Administrative Leave for Years
We provided to the EPA Administrator data on
eight EPA employees who had recorded significant
amounts of administrative leave, some for more
than a year, at a cost of more than $1 million.
A podcast on this report on
administrative leave is at:
http://www.epa.gov/oiq/rep
orts/2014/report 15-N-
0025 podcast 11-19-
2Q14.mp3.
In reaction to an October 2014 U.S. Government Accountability Office report regarding
governmentwide problems with administrative leave, members of Congress requested
information from the EPA Administrator concerning administrative leave taken by EPA
employees. As a result of that congressional request, we conducted a review and provided
an early warning report to the Administrator providing information on administrative
leave at the EPA.
The eight employees noted recorded a total of 20,926 hours of administrative leave that
cost the government an estimated $1,096,868. Each of these employees was on extended
administrative leave for 4 or more months. For four of the eight employees, the
administrative leave covered more than a year. According to the Government
Accountability Office, there is no general statutory authority for the use of paid
administrative leave, which is an excused absence without loss of pay or charge to other
leave, such as annual or sick leave.
(Report No. 15-N-0025, Early Warning Report: Some EPA Employees Found to Be on
Paid Administrative Leave for Years, November 19, 2014)
Administrative leave information for sampled EPA employees
Employee
No.
1
2
3
4
5
6
7
8
Total
Administrative
leave hours
1,820
5,883
767
6,300
3,916
1,050
300
890
20,926
Period when leave
was taken
07/28/13-09/20/14
01/03/10-09/20/14
01/12/14-09/20/14
05/09/10-09/20/14
01/16/11 -01/11/14
03/09/14-09/20/14
09/08/13-01/11/14
04/06/14-09/20/14
Total estimated
cost
$69,593
300,671
35,226
351,300
239,600
61,145
15,385
23,948
$1,096,868
Sources: OIG analysis and EPA's Compass Financial Data Warehouse.
18
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Title 42 Hiring Authority for Research Positions Needs Improvement
The EPA Office of Research and Development's justification for using its Title 42
special hiring authority to fill positions is ambiguous, which leaves the office
vulnerable to misuse and abuse of the authority.
The Title 42 hiring authority under the U.S. Code is a flexible hiring mechanism for
obtaining the services of experienced and talented scientists who otherwise may be
difficult to hire or retain. Title 42 employees can earn pay within or exceeding pay levels
found in the Executive Schedule, which is a pay schedule applicable to the highest-
ranking executive appointments in the federal government under Title 5.
The Office of Research and Development did not demonstrate the need to use Title 42 to
fill positions once held by Title 5 employees. Four Title 42 appointees who converted
from Title 5 positions received salary increases ranging from $6,149 to $17,700 after the
conversion. As a result, stakeholders have raised concerns about the agency's use of the
Title 42 hiring authority. By articulating its approach, the EPA can show how the
remaining 27 authorized Title 42 appointments, with a potential annual salary total
between $3.5 million and $6.75 million, could be used to fulfill the agency's mission.
Salary comparison for four converted employees
Example
1
2
3
4
Title 5 salary
$156,973
144,550
175,695
165,300
Title 42 salary
$171,715
153,223
181,844
183,000
Difference
$14,742
8,673
6,149
17,700
Source: Agency Initial Compensation Forms.
The Office of Research and Development did not agree with our recommendation
regarding the justification of the use of Title 42 for appointments or reappoinrments, and
this issue needs to be resolved.
(Report No. 15-P-0109, EPA Needs to Justify How It Is Using Title 42 Hiring Authority,
March 5, 2015)
Contractor Did Not Justify Increase in Charges to EPA
A contractor overbilled the EPA by $910,776 for helpdesk
services on an Office of Environmental Information contract.
The OIG had received a hotline complaint regarding management of a contract for
helpdesk call center and related services, for which the contractor had billed the EPA
$11,490,228 through September 2014. The task order does not clearly define the criteria
19
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
and methodology to be used to increase or decrease the task order price. Therefore, the
EPA does not have assurance that the pricing of the task order is reasonable. Also, as a
result of not requesting and periodically reviewing detailed data that support contact
volume, the EPA runs the risk of being overcharged for call center services.
We recommended that the EPA require, in negotiation with the contractor, modification
of the task order to provide an explicit definition of call volume and explicitly define the
basis on future modifications. We also recommended that the EPA eliminate the conflict
in the task order and recover $910,776 of unsupported charges. The EPA agreed with our
recommendations and provided a corrective action plan.
(Report No. 15-P-0042, Call Center: Contract Management Needs Improvement to
Reduce the Risk of Overtoiling, December 23, 2014)
EPA Region 6 Mismanaged Coastal Wetlands Funds
The EPA's Region 6 Water Quality Protection Division
mismanaged Coastal Wetlands Planning, Protection and
Restoration Act funds, resulting in $780,793 of questioned costs
and violations of appropriations law.
A hotline complainant alleged that the Region 6 Water Quality Protection Division
mismanaged Coastal Wetlands Planning, Protection and Restoration Act funds, as well as
EPA travel funds. We conducted an audit to determine whether the funds were used in
accordance with applicable federal laws, regulations and other agreements.
We found that, from 2010 to 2013, the Region 6 Water
Quality Protection Division used Coastal Wetlands Planning,
Protection and Restoration Act funds for purposes that were
not consistent with the act's authority, appropriations law and
principles, and interagency agreements. The division spent
$780,793 on questioned costs, augmented the EPA's annual
appropriations, and overstated program costs. These
questioned costs included misallocated intern and
administrative support costs; unapproved equipment costs;
travel, training, labor and awards funded from the wrong
appropriation; and outreach overspending. This mismanagement resulted in "purpose
violations" of appropriations law, and put Region 6 at risk of committing Antideficiency
Act violations. The effectiveness of the funds in protecting and restoring coastal wetlands
is impaired if the funds are not properly spent and accounted for.
We made various recommendations, including that Region 6 reimburse the U.S. Army
Corps of Engineers for questioned costs totaling $780,793 unless Region 6 management
A dune restoration of Whiskey Island
Back Barrier in Louisiana. (EPA photo)
20
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
could provide sufficient and appropriate documentation. We also recommended that
Region 6 work with the EPA's Chief Financial Officer to perform an internal review of
the division's Coastal Wetlands program spending to identify any additional improper
spending that occurred. Region 6 agreed with some of our recommendations but
disagreed with others.
(Report No. 15-P-0003, EPA Region 6 Mismanaged Coastal Wetlands Planning,
Protection and Restoration Act Funds, October 9, 2014)
EPA Can Save Up to $8.9 Million by Better Managing Warehouses
The EPA did not adequately manage personal property at its warehouses, and
up to $8.9 million in monetary benefits can be achieved through improved
warehouse management.
Following concerns noted during prior
reviews at two warehouses, we conducted
an audit at eight selected warehouses and
storage facilities (including the prior two)
to determine the extent to which the EPA's
personal property is stored and effectively
utilized, accounted for and disposed of by
the EPA. In addition to various
management and inventory issues at the
eight warehouses, for which the EPA
contracted for almost $50 million for
warehouse management, we found that
the EPA:
Empty space at the warehouse in
Landover, Maryland. (EPAOIG photo)
• Did not timely excess or dispose of property.
• Did not sufficiently utilize warehouse space to store property.
• Unnecessarily stored items that were readily available locally or did not fulfill an
immediate need.
• Did not prevent the unauthorized use of government property.
We recommended that the EPA update inventory policies and make other inventory
improvements, optimize space, improve property storage procedures, and address
oversight and accountability. The agency agreed with our recommendations and provided
corrective actions.
(Report No. 15-P-0033, EPA Needs Better Management of Personal Property in
Warehouses, Decembers, 2014)
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
EPA Financial Statements Earn Unqualified Opinion
We rendered an unqualified opinion on the EPA's Consolidated Financial
Statements for FYs 2014 and 2013 (restated), meaning that the statements were
fairly presented and free of material misstatements. However, we noted a
material weakness and several significant deficiencies.
Software costs not being capitalized, leading to the FY 2013 financial statements needing
to be restated, represented a material weakness. In addition, we noted the following
significant deficiencies:
• Lab renovation costs were not capitalized.
• Controls over accountable personnel inventory needed improvement.
• The property management and accounting systems did not reconcile.
• The Cincinnati Finance Center needed to clear suspense transactions timely.
• An FY 2013 collection was recorded to an incorrect fund.
• Originating offices did not timely forward accounts receivable documents.
• Accounts receivable were not properly reconciled.
• Unliquidated funds were not deobligated timely.
• Restricted entry access to server rooms was not consistently enforced.
• Information technology assets needed to be better monitored and secured.
• Information technology assets needed to be better protected from threats.
• Server room cameras needed to be reconfigured to fully monitor assets.
• Documentation was needed for approval of posting module changes.
EPA OIG One of Few OIGs to Perform
Financial Statement Audits
Having qualified staff and being able to offer the
taxpayer significant savings, the EPA OIG is one of
the few OIGs in the federal government that conducts
financial statement audits of its agency. (When the
EPA OIG sought to contract out its financial statement
auditing in 2007 per OMB Circular A-76, Performance
f Commercial Activities, the EPA OIG submitted its
bid and came in more than $1 million under the
lowest acceptable bid from a Certified Public
Accounting firm.) The EPA OIG team that audits
financial statements is led by an experienced Certified
Public Accountant and many of the team members
are also Certified Public Accountants. In addition to
conducting the mandated annual audits of the
agency's overall consolidated financial statements,
the EPA OIG also audits the financial statements for
several EPA pesticide funds.
We also noted noncompliance issues in that
standards for recording interest were not
sufficiently followed, and the EPA's 2014 Financial
Managers' Financial Integrity Act Annual
Assurance Statement was inaccurate.
The agency generally agreed with our findings and
recommendations. The agency disagreed that the
timely forwarding of receivables was a significant
internal control deficiency, and also disagreed with
certain details of the material weakness cited.
(Report No. 15-1-0021, Audit of EPA's Fiscal Years
2014 and 2013 (Restated) Consolidated Financial
Statements, November 17, 2014)
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
EPA Can Better Manage Scientific Research Equipment
The EPA's Office of Research and Development can better manage its scientific
research equipment to ensure that equipment is being used more efficiently and
obsolete equipment is not being retained.
As the scientific research arm of the EPA, the Office of Research and Development uses
sensitive and often expensive equipment. The office's capital equipment list totaled more
than $73 million in value. Property management regulations
require that agencies identify and reassign any idle equipment and
maintain adequate inventory controls and accountability systems.
A plasma mass spectrometer at an
EPA laboratory. (EPA OIG photo)
Our review of a sample of 99 pieces of research equipment within
three laboratories found that 30 of the pieces had not been used for
2 to 14 years. Further, six of those 99 pieces were obsolete. This
occurred because either there was no ongoing research
necessitating the specific equipment's use or the item was being
kept as backup. We also found that the EPA did not manage its
scientific equipment as a business unit or enterprise, managers and staff were not always
aware of federal property management requirements, and there were not clear lines of
authority for equipment accountability and usage.
We recommended that the Office of Research and Development establish an equipment
list, an equipment pool, and regular equipment utilization walkthroughs, among other
things. The office agreed with our recommendations and corrective actions are pending.
(Report No. 15-P-0115, To Ensure Greater Use of Scientific Equipment, the Office of
Research and Development Should Use an Enterprise Approach to Property
Management, March 16, 2015)
Costs of $1,261,665 for Brownfields Agreement Questioned
The Pioneer Valley Planning Commission
in Massachusetts did not follow federal
requirements when administering a
brownfields cooperative agreement with
the EPA. We questioned all $1,261,665
drawn by the commission, and the
commission has so far agreed to repay
$94,891 of that amount.
The Pioneer Valley Planning Commission—
which covers a region that encompasses
The South Main Street School Brownfields
Revolving Loan Fund site, Town of
Monson, Massachusetts. (EPA OIG photo)
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
43 cities and towns in Hampden and Hampshire counties in Massachusetts—received a
cooperative agreement from the EPA to clean up brownfields. However, the commission
did not adhere to federal requirements when administering the agreement, and its
accounting system could not provide an accurate, current or complete disclosure of
financial results. Of the funds drawn, $94,891 involved duplicate invoices, unverified
costs, costs associated with another federal agreement, and ineligible indirect costs.
We made various recommendations to the EPA to address the conditions noted. This
included questioning and recovering the $1,261,665 in federal funds drawn, and the
commission agreed to repay $94,891 of that amount.
(Report No. 15-4-0072, Costs of $1.2 Million for Brownfields Cooperative Agreement to
Pioneer Valley Planning Commission in Massachusetts Questioned, February 2, 2015)
Agency Can Improve Fleet Management Programs
If oversight of the EPA's fleet is not improved, the
$6 million-per-year program could be ineffective and
inefficient in supporting the agency's mission and
reporting data to the federal system, and could
place taxpayer funds at risk.
A podcast on our EPA fleet
management report is at:
http://www.epa.gov/oiq/rep
orts/214/report 15-P-
0001 podcast 10-6-
2Q14.mp3.
An audit was conducted to determine whether the EPA's
fleet program is in accordance with federal fleet
requirements for vehicle operations, acquisitions and
utilization. The audit revealed that the agency has not
finalized or issued guidance documentation to manage the
fleet in over 5 years. Also, fleet managers were not
following program requirements and federal regulations
for emission testing, tracking vehicle usage, and ensuring
operator responsibilities. Further, the agency did not have
documentation to support approval of law enforcement
vehicles in home-to-work status. The agency agreed with our recommendations and
provided corrective actions.
(Report No. 15-P-0001, EPA 's Fleet Management Program Needs Improvement,
October 6, 2014)
An EPA fleet vehicle. (EPA OIG photo)
24
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Improvements Can Be Made in Computer Security Program
Our review of the EPA's implementation of the Federal Information Security
Management Act during FY 2014 disclosed that improvements could be made.
The act requires federal agencies to develop an information security program that protects
its operations and assets, and the OIG is required to perform an annual evaluation of the
program. Federal information systems are subject to threats, including purposeful attacks.
The EPA had established an agencywide information security program to assess the
security state of information systems that was consistent with requirements. However, the
EPA should place more emphasis on remediating deficiencies within the agency's
Configuration Management program related to addressing deviations identified by scans
and for installing patches. Also, the EPA had an outdated Business Impact Analysis. We
reported this information to OMB in the required matrix.
(Report No. 15-P-0020, Fiscal Year 2014 Federal Information Security Management Act
Report: Status of EPA 's Computer Security Program, November 13, 2014)
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Investigations
Significant Investigations
Scientists Convicted of Fraudulently Obtaining EPA Contract Funds
On March 20, 2015, two Tampa Bay area scientists were found guilty by a
federal jury in the Middle District of Florida of conspiracy to commit wire fraud,
aggravated identity theft, and falsification of records.
According to testimony and evidence presented during the trial, Mahmoud Aldissi and
Anastassia Bogomolova, both Ph.D. scientists, fraudulently obtained over $10.5 million
worth of small business research awards from the federal government, including
$400,000 in EPA funds. These awards were intended to promote U.S. technological
innovation. To obtain these awards, Aldissi and Bogomolova—through their companies
Fractal Systems Inc. and Smart Polymers Research Corporation—submitted proposals to
the U.S. government using the stolen identities of real people, including one who was
deceased, to create false endorsements for their proposed contracts and grants. In the
proposals, they also lied about their facilities, costs, the principal investigator on some of
the contracts, and the certifications in the proposals. Additionally, Aldissi and
Bogomolova were convicted of falsifying records with the intent to impede, obstruct and
influence an investigation being conducted by the National Science Foundation.
This investigation was conducted jointly with the Defense Criminal Investigative Service,
Major Procurement Fraud Unit of the U.S. Army Criminal Investigation Division,
National Aeronautics and Space Administration OIG, National Science Foundation OIG,
Department of Homeland Security OIG, and Department of Energy OIG.
Company, Officials Sentenced for Producing Paints With Pesticide
On Decembers, 2014, a Clearwater, Florida, company received a criminal fine of
$1,235,315 and 3 years of probation for a conspiracy to defraud the United
States. A sister company was sentenced to 1 year of probation, and four officers
of the companies received prison sentences or probation.
New Nautical Coatings Inc. was investigated for illegally manufacturing marine paints that
contained the regulated pesticide tributyltin after entering into an agreement with the EPA
to cease manufacturing the product. On February 6, 2014, a federal grand jury in the
U.S. District Court for the Southern District of Florida indicted New Nautical and its sister
company, Sea Hawk Refmish Line Inc. Four officers of the companies were also indicted,
arrested and arraigned. The charges included knowingly selling an unregistered pesticide,
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Semiannual Report to Congress October 1, 2014—March 31, 2015
conspiracy to defraud the United States, wire fraud, conspiracy to commit mail fraud and
wire fraud, obstruction of justice, and misuse of a government seal.
On December 5, 2014, David Norrie was sentenced to federal prison for 5 months and,
upon release from prison, supervised release for 3 years. Erik Norrie was sentenced to
federal prison for 3 months. Tommy Craft and Jason Revie were both sentenced to
probation for 1 year.
This investigation was conducted jointly with the EPA Criminal Investigation Division.
Company Pays $2.72 Million in New Jersey Kickback Scheme
In November 2014, a Canadian national was extradited to the United States to
face charges in a kickback scheme in the U.S. District Court for the District of
New Jersey. In a related matter, Sevenson Environmental Services Inc. came to a
civil settlement agreement in which it would pay $2.72 million to the United States.
On November 14, 2014, John Bennett, a Canadian national, was extradited from Canada on
a charge of participating in a conspiracy to pay kickbacks and commit fraud at the EPA-
designated Federal Creosote Superfund site, located in Manville, New Jersey. He also was
charged with a count for major fraud against the United States related to contracts obtained
at the Federal Creosote site. Bennett was a former Chief Executive Officer with a
Canadian-based company that treated and disposed of contaminated soil and was a
subcontractor to Sevenson on the Federal Creosote site. Bennett carried out the conspiracy
by providing kickbacks to the project manager at the Federal Creosote site to influence the
award of sub-contracts and inflate the prices charged to the EPA by the prime contractor.
On November 17, 2014, a settlement agreement was finalized between the U.S.
Department of Justice and Sevenson Environmental Services Inc., of Niagara Falls,
New York. Sevenson agreed to pay the United States $2,727,200 plus interest at a rate of
3 percent per annum. Subsequent to the agreement, on November 18, 2014, the EPA's
Suspension and Debarment Division terminated the Suspension and Proposed Debarment
for various Sevenson executives, and also terminated the Interim Administrative
Agreement that had been in place since March 1, 2013, for Sevenson and some of its
affiliates.
This case is being conducted with the Internal Revenue Service Criminal Investigation
Division.
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Montana Tribal Officials Given Jail Time for Fraud
Individuals associated with the Rocky Boy Indian Reservation received jail time,
restitution and other penalties in the U.S. District Court for the District of Montana
related to bribery and theft, and others have been indicted for bribery and theft.
The charges involved embezzlement and taking bribes in relation to contracts
that involved EPA funds.
In March 2015, three tribal officials received jail time. Bruce Sunchild, former Tribal
Chairman of the Chippewa Cree Indian Tribe at the Rocky Boy Reservation, was
sentenced to 34 months' incarceration and 36 months' supervised release, and ordered to
pay $370,088 in restitution. James Eastlick Jr., former clinical psychologist at the Rocky
Boy Indian Reservation Clinic, was sentenced to 6 years' incarceration and 3 years'
supervised release, and ordered to pay $424,800 in restitution and a $100,000 fine.
Mark Leischner, Eastlick's brother-in-law, was sentenced to 2 years' incarceration and
3 years' supervised release, and ordered to pay $281,313 in restitution.
In addition, four other tribal officials have pleaded guilty or were indicted for various
changes related to theft and bribery. The individuals are Tim Rosette, former Director of
the Rocky Boy Roads Department and Director of the Rocky Boy Health Clinic's
Environmental Health Division; John C. Houle, former Chairman of the Chippewa Cree
Indian Tribe; Theodora Morsette, former Finance Manager of the Rocky Boy Health
Clinic; and Wade Colliflower, a member of the Chippewa Cree Indian Tribe.
This case is being conducted by the Montana Guardian Task Force, which is made up of
the FBI; the Internal Revenue Service; and the OIGs of the Department of the Interior,
Department of Health and Human Services, Department of Agriculture, and EPA.
Man Sentenced for Falsifying Methamphetamine Remediation Data
On December 15, 2014, a Savannah, Tennessee, man was sentenced in the
U.S. District Court for the Western District of Tennessee to 6 months in prison,
3 years of supervised release, and $102,225 in restitution for falsely certifying that
quarantined methamphetamine homes were safe for inhabitation after remediation.
On April 14, 2013, Douglas McCasland, owner of HAZ-TECH, performed a remediation
of a quarantined methamphetamine house in Manchester, Tennessee, and signed a
Certificate of Fitness claiming the property to be cleaned to proper standards and certifying
that the property was safe for human use. The Tennessee Department of Environment and
Conservation advised that McCasland was not certified by the department as a Clandestine
Methamphetamine Laboratories hygienist—an industrial hygienist at properties where
methamphetamine was manufactured. Investigation further disclosed that McCasland had
18 cases of remediated houses that he had certified. The Tennessee Department of
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Environment and Conservation retested 11 of the houses, and nine were found to still be
contaminated. McCasland falsified remediation data in 17 counties in Tennessee.
McCasland, who previously was indicted and charged with 10 counts of mail fraud and
three counts of false statements, had pleaded guilty to a violation of false statements.
Debarments Occur Related to New York Lab Fraud Case
Two individuals and two entities were debarred from participation in federally
funded projects related to the falsification of laboratory results by a New York firm.
On February 17, 2015, Upstate Laboratories Inc., of East Syracuse, New York; Enalytic
LLC, also of East Syracuse; Anthony J. Scala, Owner, Upstate Laboratories Inc.; and his
wife Carole A. Scala, Owner, Enalytic LLC, were debarred from participation in
federally funded projects for a period of 5 years. Upstate Laboratories previously had
been fined $150,000 and placed on 5 years' probation.
Upstate Laboratories performed chemical analysis of water and soil samples supplied by
public and private clients. Certain analyses were required to be performed within
specified timeframes ("holding times") after the samples were obtained due to the
potential for chemical degradation. Upstate Laboratories further promised to use required
procedures to ensure that the samples did not degrade. However, from 2008 through
2010, Upstate Laboratories engaged in routine "backdating" of sample results where
employees changed the dates for when the samples were analyzed to make it appear that
analysis had occurred within the required time periods when in fact they had not. Upstate
Laboratories thereafter prepared false and fraudulent analysis reports representing that the
samples were properly analyzed within required time frames and the results were valid.
This case was conducted jointly with the EPA Criminal Investigation Division.
Man Indicted for Threatening to Kill EPA Employee
On October 1, 2014, a Missouri man was indicted in the
U.S. District Court for the Western District of Missouri and
arrested for threatening to kill an EPA employee and others.
The EPA has been involved in a contaminated ground water remediation effort that
stemmed from a derelict mining site in the Joplin, Missouri, area for approximately
20 years. The person indicted and arrested owns two Superfund site parcels in the area,
one approximately 160 acres and the other approximately 20 acres. The remediation at
the 160-acre parcel, which was conducted with the permission of the land owner, was
nearly completed when an EPA employee communicated to the land owner that during a
walk-through of the 20-acre parcel one or more violations had been found regarding
dumping and waste. The EPA employee was orally threatened by telephone. In addition,
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Semiannual Report to Congress October 1, 2014—March 31, 2015
at least two other people were the subjects of threats made by the land owner. When the
land owner was arrested, two firearms were seized.
Man Arrested for Wire Fraud and Smuggling
On January 8, 2015, a Republic of Korea man was arrested in Daejeo-City,
Korea, by the Interpol (International Criminal Police Organization) Fugitive
Tracing Unit in the Seoul Metropolitan Police Agency for violations of the
American Recovery and Reinvestment Act "Buy American" provision.
Heon Seok Lee had served as President of KTurbo Inc. in the Republic of Korea, and
President of its subsidiary—KTurbo USA Inc.—with an office and warehouse in Illinois.
From January 2010 to February 2011, Lee directed others to procure contracts for
KTurbo to provide centrifugal turbo blowers to municipal wastewater treatment facilities
receiving Recovery Act funds from the EPA. Lee and others sent at least five email
communications to U.S. municipal wastewater treatment facilities falsely representing
that KTurbo would manufacture and deliver the municipalities' turbo blowers in
compliance with the "Buy American" provision of the Recovery Act. Lee had three
shipments of a total of nine turbo blowers sent to the KTurbo facility in Illinois from
Korea. The blowers arrived in the United States largely assembled but were affixed with
"Assembled in USA" placards. Lee and others did not intend to perform substantial
transformation of the turbo blowers, and Lee was subsequently indicted in the Northern
District of Illinois on five counts of wire fraud and three counts of smuggling. In total,
Lee and others intended to fraudulently obtain over $1.3 million in Recovery Act funds.
This case is being conducted with Interpol, the U.S. Department of Homeland Security,
and the U.S. Department of Justice.
Former Tribal Official Pleads Guilty to Embezzling Over $240,000
On March 23, 2015, a former official of the Alaska Inter-Tribal Council,
Anchorage, Alaska, pleaded guilty to theft of over $240,000 in tribal grant funds
in the U.S. District Court for the District of Alaska.
A federal grand jury indicted two former directors at the Alaska Inter-Tribal Council on
charges that they stole from a nonprofit that advocates for tribal governments across the state.
Steven D. Osborne, former Executive Director for the council, commingled federal funds
from a $ 1 million EPA grant with non-federal funds received from the Venezuelan
government for managing a home heating program. Osborne did not maintain records
that adequately identified the source and application of the council's financial
transactions. Osborne obtained approximately $218,000 in council funds entrusted to his
care as Executive Director and misapplied them for his personal use.
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Semiannual Report to Congress October 1, 2014—March 31, 2015
The investigation also found that Thomas R. Purcell, former Finance Director of the
Alaska Inter-Tribal Council, may have conspired with Osborne to cover the personal
expenditures. Osborne authorized Purcell to receive an additional $19,200 among 26 pay
periods charged to the home heating program account as a vendor. Additionally, Purcell
obtained approximately $11,000 in council funds entrusted to his care as the Finance
Director/Interim Executive Director and misapplied them for his personal use.
Tennessee Company Submits Fraudulent Asbestos Lab Results
On January 27, 2015, the president of a Tennessee firm was sentenced in the
U.S. District Court for the Eastern District of Tennessee to 3 years of probation
and fined $500 for submitting fraudulent lab results regarding asbestos.
The Tennessee Department of Environment and Conservation reported that it received
fraudulent laboratory test documents from Environmental Consulting and Testing LLC in
support of an asbestos survey. David Weekley, company president, submitted a survey
report to the state claiming he had 57 samples from seven separate locations tested by Fiber
Com Laboratory. Contact with Fiber Com disclosed that it had only performed four tests
for Environmental Consulting, and this was confirmed by a search of Weekley's computer.
Weekley pleaded guilty to one count of wire fraud. On March 31, 2015, Weekley and
Environmental Consulting and Testing LLC were issued a Notice of Suspension and
Proposed Debarment for participation in federal contracts and assistance activities.
Gang Member Charged With Assaulting EPA Special Agent
On November 9, 2014, a suspect in the assault of an EPA
Criminal Investigation Division Special Agent and the carjacking
of a government law enforcement vehicle was arrested and
jailed. The suspect, a known gang member in the Atlanta, Georgia, area, was
charged with numerous robberies and carjacking, and is a suspect in a homicide.
On October 22, 2014, an EPA Special Agent was carjacked by two gunmen in Atlanta.
The gunmen physically assaulted the agent; fired a shot during the incident; and stole an
EPA-assigned, fully equipped law enforcement vehicle. The agent received minor
injuries. On October 23, 2014, the stolen vehicle was used in another carjacking, where
the perpetrators used the law enforcement equipment to make a traffic stop. Later that
evening, the perpetrators carjacked another vehicle (not using the stolen government
vehicle) and one of the perpetrators was arrested after a vehicle chase through the Atlanta
metro area. On October 24, 2014, after a citizen's tip, the stolen law enforcement vehicle
was recovered in a neighborhood south of Atlanta. On November 6, 2014, the EPA
Special Agent positively identified the suspect in a photo lineup.
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Semiannual Report to Congress October 1, 2014—March 31, 2015
On November 9, 2014, the suspect and three other individuals attempted a home invasion
in Atlanta, during which the suspect was wounded and subsequently arrested. The
suspect's fingerprints matched prints found at a previous homicide. The Atlanta Gang Unit
reported there were 25 carjackings and robberies in the Atlanta metro area associated with
this gang. The suspect has been charged with murder and 63 other charges, including the
assault of the EPA agent. Fourteen co-defendants were also charged.
This investigation is being conducted jointly with Atlanta Violent Crimes Task Force
(Atlanta Police Department and the Bureau of Alcohol, Tobacco, Firearms and
Explosives), the Atlanta Gang Unit, and the Sandy Springs Police Department.
Former Contractor Sentenced for Theft of Government Property
On October 2, 2014, a former information technology contractor in Region 4 was
sentenced to 3 years of probation and $118,614 in restitution for stealing EPA
computers. On March 11, 2015, he was debarred from participation in federally
funded projects for a period of 3 years.
In 2012, EPA Region 4, headquartered in Atlanta, Georgia, discovered that 72 computer
devices (laptops, tablets and desktops), valued at $84,842, were stolen/missing from the
region's information technology department. Contact with manufacturers disclosed that one of
the missing/stolen items had been registered online, and an OIG interview of the identified
buyer disclosed that the computer was purchased via Ebay. Approximately 30 computers
linked to the missing EPA computers were sold via Ebay. The owners of the EBay account
provided details of their purchase of the computers from an individual subsequently identified
as the EPA contractor. The former EPA contractor—David Lee McCallum, of Stockbridge,
Georgia—was charged with theft of government property over $1,000. McCallum was
sentenced in the U.S. District for the Northern District of Georgia to 3 years of probation with
1 year of electronically monitored home confinement, 80 hours of community service, and
$118,614 in restitution. The investigation also uncovered computers that were stolen from the
U.S. Army, with whom the former EPA contractor was formerly employed.
This case is being conducted jointly with the Federal Protective Service and the
U.S. Army Criminal Investigation Division.
Probation Given to EPA Employee for Theft of Government Cameras
On October 13, 2014, an EPA Region 4 employee was sentenced in the Georgia
Superior Court of Fulton County to 3 years of probation, $3,118 in restitution and
a $1,000 fine for the theft of EPA-owned cameras.
Following the theft of a large number of computers in Region 4 (see above), the EPA
conducted an inquiry into all missing property listed by Region 4 over a 2-year period
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Semiannual Report to Congress October 1, 2014—March 31, 2015
and found that several cameras listed as missing were identified as being pawned at a
local pawn shop. The perpetrator was identified as an EPA GS-12 Public Affairs
Specialist assigned to Region 4 who subsequently confessed to seven instances of theft.
The employee, who pleaded guilty to one count of felony theft, received a 30-day
suspension from the EPA.
Actions Taken Against Two EPA Employees for Viewing Pornography
In two separate cases, EPA employees received a Notice of Proposed Removal
from the EPA related to charges of viewing and downloading pornography on
EPA computers during work hours.
On March 24, 2015, an EPA employee received a Notice of Proposed
Removal after Special Agents went to the employee's work location and
found the employee viewing a pornographic image on an EPA computer.
The investigation disclosed that the EPA employee downloaded tens of thousands of
pornographic images, some of which were stored on an EPA shared drive. For several
years, the employee had spent approximately 2 to 6 hours a day viewing and
downloading pornography with EPA computer equipment during core work hours.
Also on March 24, 2015, a second EPA employee received a Notice of Proposed Removal
as a result of having been witnessed viewing pornographic material on an EPA computer
during work hours by a minor who was in the building for the EPA's "Bring Your
Daughters and Sons to Work Day." The investigation substantiated that the EPA employee
had spent approximately 1 to 4 hours viewing and downloading pornography with EPA
computer equipment during core work hours daily.
Senior Executive Issued Notice of Proposed Removal
On November 14, 2014, a Senior Executive Service (SES)-level employee
received a Notice of Proposed Removal from the EPA for selling products to
EPA employees and inappropriately using EPA resources. The employee is
appealing the decision.
The senior executive was the subject of an investigation that found that the employee
sold products from three businesses to EPA subordinates and colleagues in EPA office
space during office hours. The executive was also found to have used EPA resources—
including the employee's office, laptop computer, BlackBerry and EPA email system—in
furtherance of these business activities. Further, the senior executive's child—an intern in
an EPA student summer hire program—was paid two EPA cash performance awards
totaling approximately $790 with funds that originated directly from the employee's
operating budget. In addition, the senior executive recommended a friend and an
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Semiannual Report to Congress October 1, 2014—March 31, 2015
acquaintance for employment to a company that had contracted to conduct work for the
EPA. During the period of the investigation, this senior executive had received a
Presidential Meritorious Rank Award for $33,928.
Senior Executive's Investments Are Potential Conflict of Interest
An SES-level EPA employee violated the "Acts Affecting a
Personal Financial Interest" (18 U.S.C. § 208) by participating in
a specific agency matter related to one of the employee's assets
in an outside company that represented a potential conflict of
interest.
In March 2014, the employee signed a motion on behalf of the EPA to intervene as a
commenter on the Canadian environmental review process for the Trans Mountain
Pipeline Expansion Project while owning over $30,000 worth of stock in the company.
This occurred even though the EPA provided the senior executive with a Letter of
Caution in September 2013 regarding the employee's stock in the company and the
potential for a conflict of interest. The employee did not consult with EPA ethics counsel
in advance regarding the motion.
A report of investigation was presented to the EPA on January 16, 2015. On February 19,
2015, an EPA regional official verbally counseled the senior executive regarding the
aforementioned conflict of interest and on employee ethics obligations. The regional
official reviewed the situation with the employee.
Senior Executive Retires After Misconduct
An SES-level EPA employee retired after issues of misconduct
involving a 21-year-old female intern from another government
entity were raised.
The SES employee engaged in a series of interactions with the intern, who reported the
interactions to her supervisor and indicated that she was "uncomfortable and scared" by
the interactions. The investigation revealed additional allegations regarding the senior
executive's behavior toward women, security violations and other actions.
The investigation substantiated that the senior executive engaged in a series of interactions,
including some of a sexual nature, involving the intern. Also, the investigation
substantiated that from 2004 through July 2014 this senior executive engaged in conduct
and exchanges, including some of an inappropriate nature, considered to be unwelcome by
16 additional females. The investigation also substantiated that the senior executive was
not in compliance with building entry security procedures in bypassing the security
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Semiannual Report to Congress October 1, 2014—March 31, 2015
checkpoint with the intern and not having her sign in as a visitor. The senior EPA
employee retired January 9, 2015, prior to administrative action being taken.
Senior Executive Retires After Allowing Fraud by EPA Employee
In a Report of Investigation dated April 17, 2014, the OIG determined that an SES-level
employee responsible for the oversight and approval of time and attendance records and
travel vouchers for John C. Beale lacked due diligence and cost the government $184,193.
The employee retired on February 28, 2015, prior to administrative action being taken.
Beale is a former Senior Policy Advisor for the EPA Office of Air and Radiation who had
pleaded guilty to multiple frauds.
Senior Executive Retires After Approving False Time Cards
An SES-level employee approved and signed false time and attendance records for a
GS-15 scientist who was suffering from a debilitating disease and was not working. For
at least 1 year, the subject approved the scientist's time and attendance records certifying
that he was working. Colleagues reported that for at least the past few months the
employee had been physically incapable of completing basic tasks such as speaking or
typing, but was allowed to receive full pay and benefits while living in an assisted living
facility and unable to perform his duties as a scientist. The SES-level employee retired
from the EPA on December 31, 2014, and the scientist retired January 3, 2015, both prior
to administrative action being taken.
Supervisor Terminated for Allowing Employee to Get Paid Without
Working
An EPA supervisor who admitted to allowing an employee to stay home
and not perform any work while the employee collected full pay and
benefits for approximately 6 years, costing the government over $600,000, was terminated
by the EPA on October 7, 2014. The supervisor stated that it was easier to allow this
arrangement than go through the medical retirement process for the employee and deal with
the employee's union. The employee retired prior to administrative action being taken.
Former Special Agent Pleads Guilty for False Statement
On March 11, 2015, a former EPA Criminal Investigation Division Special Agent
pleaded guilty in the U.S. District Court of Connecticut to making a false statement for
intentionally not documenting reportable earnings on the OGE Form 450, Confidential
Financial Disclosure Report, and then certifying the document as accurate. The earnings
not reported were derived from the Special Agent's involvement in a pyramid
scheme. The employee retired from federal service in January 2015.
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Timekeeper Pleads Guilty to Falsifying Records
On January 8, 2015, an EPA employee pleaded guilty to second degree
felony fraud in the District of Columbia Superior Court for falsification
of time and attendance records totaling over $15,600. From September
2012 through July 2014, the employee submitted fraudulent time and attendance
records. As the office timekeeper, the employee had manipulated the EPA's electronic
time and attendance record system, enabling the employee to obtain pay for work not
performed. On February 9, 2015, the EPA placed the employee on indefinite suspension.
EPA Employee Removed for Time Card Fraud
On November 1, 2014, an EPA employee in Research Triangle Park, North Carolina, was
removed from employment for inaccurately reporting time, being absent without leave,
and a lack of candor during an investigation. In June 2013, it was alleged that time card
fraud was being committed by a Research Triangle Park employee. The employee's
office provided to the OIG the employee's timesheets, badge logs and overtime requests.
The employee had been paid for a substantial amount of overtime and had accumulated a
large sum of compensatory time over a 2-year period. During an interview, the employee
admitted to falsely claiming overtime and compensatory time on numerous occasions for
at least 3 years. Based on the admission and the findings of the investigation, the
employee was removed from federal service. The U.S. Attorney's Office, Middle District
of North Carolina, is pursuing possible criminal prosecution of the employee.
Agency Failure to Act on (or to Report to OIG That It Acted on)
Reports of Investigations
CASE 1, Report of Investigation to EPA Office of Administration
and Resources Management, November 25, 2013: The investigation
revealed information to support the allegation that a GS-15 EPA
employee engaged in private business activities with contract employees during official
work time, used a government position to assist a contract employee's attempt to gain
federal employment with the EPA, and may have misused government property and acted
in a manner unbecoming a federal employee with a contract employee.
CASE 2, Report of Investigation to EPA Office of Chemical Safety and Pollution
Prevention, June 10, 2014: The investigation revealed information to support the
allegation that a GS-13 EPA employee violated the Code of Federal Regulations and
EPA administrative policies with the viewing and downloading of pornographic materials
as well as various movies and video clips with an EPA-issued computer through the EPA
network during core working hours.
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
CASE 3, Report of Investigation to EPA Office of Administration
and Resources Management, October 8, 2014: The investigation
revealed that, during an employment suitability background
investigation of an EPA employee, conducted by the Office of Personnel Management,
criminal and financial indebtedness information surfaced that previously had not been
divulged by the employee when completing form OF-306, Declaration for Federal
Employment, and form SF-85P, Questionnaire for Public Trust Positions. The EPA's
Personnel Security Branch requested documentation evidencing the paying down of
accumulated debts from the employee. The documentation tendered by the employee did
not appear authentic and was determined to be fraudulent. The employee provided false
information to the EPA concerning criminal history and failed to pay accrued personal
debts, which included an EPA travel card balance of $10,226.
Closed Employee Integrity Cases
Statistics on employee integrity investigation cases closed during the semiannual
reporting period follow.
Pending 10/1/14
Open
Closed
Pending 3/31/15
Political
appointees
4
0
3
1
SES
11
0
2
8
GS-14/15
24
2
1
25
GS-13 and
below
42
9
14
37
Misc.*
3
2
1
4
Total
82
13
21
75
* Adjusted from prior period.
I Political Appointees
I SES
14/15
113 and below
Misc
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Other Activities
EPA OIG Will Make Improvements in Areas of Timekeeping, Hiring
and Fleet Management
As a result of congressional inquiries, the OIG conducted reviews of the EPA in
three personnel-related areas—time and attendance reporting, compliance with
overtime policies, and the employee hiring process. In addition to reviewing the
agency overall, the auditors looked at how the OIG itself performed in these areas,
and found that the OIG could make improvements. Although our reviews of the
agency are still in process, the OIG issued three reports on how the OIG performed
in these areas, as summarized below. In addition, the OIG conducted an audit to
determine how well the EPA OIG manages its law enforcement vehicles.
• Time and Attendance Reporting. The OIG did not always comply with its own
policy for using its official internal system for recording time and attendance,
including approval for leave and premium pay. Some employees did not submit
or have approved planned or actual timesheets in the OIG's internal system. As a
result, the OIG was not always able to verify that the data in the agency's official
payroll system were accurate, and employees may use leave without
authorization. The report recommended, and OIG management agreed to,
improve its guidance in this area. Corrective actions are in process.
(Report No. 15-B-0074, EPA OIG Not Fully Compliant With OIG Policy on
Time and Attendance Reporting, February 4, 2015)
• Overtime Policies. The OIG did not always use the EPA's Request for
Authorization of Overtime Work form for overtime requests and authorization, as
required by agency policy. Also, OIG employees did not always comply with
OIG policy to have overtime approved in advance. As a result, OIG employees
may have incurred overtime without proper authorization. The report
recommended, and OIG management agreed to, clarify its policy in this area, and
inform management and employees of the need to comply with EPA overtime
policies. Corrective actions are in process. (Report No. 15-B-0075, EPA OIG
Not Fully Compliant With Overtime Policies, February 4, 2015)
• Employee Hiring Process. The OIG does not have a requirement to verify
information in a job application, including job employment history or references.
The OIG relies on the applicant self-certifying information submitted. Without
verification of prior employment or references, the potential exists that the OIG
will not hire the best possible candidate or will hire someone based on misleading
information. The report recommended, and OIG management agreed to, require
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Semiannual Report to Congress October 1, 2014—March 31, 2015
selecting officials to verify prior employment and references before making any
hires, and establish policies for employee vetting. Corrective actions are in process.
(Report No. 15-B-0076, Improvements Needed by EPA OIG to Reduce Risk in
Employee Hiring Process, February 5, 2015)
• Fleet Management. The auditors sought to determine whether the EPA OIG
managed its law enforcement vehicles in accordance with federal fleet
requirements. The OIG conducted this audit in conjunction with an audit of the
agency's overall fleet management. As of November 2013, the EPA OIG had a
total of 29 vehicles used by the OIG Office of Investigations. The audit identified
opportunities for management consideration. Corrective actions are complete or in
process. (Report No. 15-B-0002, EPA OIG Compliance With Managing Vehicles
Within EPA 's Fleet Management Program, October 6, 2014)
Administrator Issues Message to All EPA Employees
on Importance of Cooperating With OIG
In response to requests from the OIG, EPA Administrator Gina McCarthy issued
a message to all EPA employees stressing the importance of everyone
cooperating with the OIG to better ensure that the agency functions as a high-
performing organization.
"One of the ways we can ensure that we all perform at our best is to support the internal
review and oversight carried out by our Office of Inspector General. The OIG serves as
an independent office within our agency, preventing and rooting out fraud, waste and
abuse in agency programs and operations, largely through audits and investigations. This
important work enables us all to be more effective in achieving the agency's mission,"
McCarthy noted in a January 2, 2015, email to all EPA employees.
"The vigilance of EPA staff is key to successful OIG oversight. I expect all employees to
report fraud, waste and abuse to the OIG if they see it. The types of conduct that should
be included include: theft of EPA funds, misuse of contract or grant monies, misuse of
EPA equipment or assets for personal gain, falsification of EPA reports or records,
serious employee misconduct, or participation in EPA fraud," she said.
McCarthy noted that employees should use the OIG hotline if they become aware of a
matter of concern, and pointed out they may request anonymity.
EPA OIG Whistleblower Protection Ombudsman Activities Advancing
The Whistleblower Protection Enhancement Act of 2012 (Public Law No. 112-199) assigned
the OIG responsibility for educating employees about Whistleblower protections, rights and
remedies. The EPA OIG has placed this function within its Office of Counsel.
39
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Semiannual Report to Congress October 1, 2014—March 31, 2015
During this semiannual period, the EPA OIG Whistleblower Protection Ombudsman
received more inquiries than in previous periods, as more employees became aware that
this function had been created. The ombudsman saw a modest increase in the number of
consultations requested by employees who felt they were being subjected to prohibited
personnel practices in retaliation to whistle blowing. After consultations with inquiring
employees, the ombudsman referred them to the government's Office of Special Counsel
to start the applicable process establishing whistleblower status or action for a prohibited
personnel practice.
While not trying to "drum up business," the Inspector General believes that an aware
workforce will be a more engaged workforce, attuned to call attention to problems when
warranted. To that end, the Inspector General commenced an outreach program focusing
on fraud, waste and abuse, emphasizing reporting: "If you see it, say something!"
Delivered to agency managers, these outreach presentations have been well received.
During the last semiannual period, the EPA OIG Whistleblower Protection Ombudsman
and other staff members from the OIG's Office of Counsel and Office of Investigations
made six such presentations.
The Office of Special Counsel has a certification program whereby it will certify a
federal agency's compliance with training and awareness provisions of the Whistleblower
Protection Act if the agency meets five requirements in those areas. While the OIG can
and does reach out to the agency with the OIG awareness program as noted above, it is
the agency that must take the steps to receive the Office of Special Counsel certification,
and the EPA has not done so.
Legislation and Regulations Reviewed
Section 4(a) of the Inspector General Act requires the Inspector General to review
existing and proposed legislation and regulations relating to the program and operation of
the EPA and to make recommendations concerning their impact. The OIG also reviews
drafts of OMB circulars, memorandums, executive orders, program operations manuals,
directives and reorganizations. The primary basis for the OIG's comments are the audit,
evaluation, investigation and legislative experiences of the OIG, as well as its
participation on the Council of the Inspectors General on Integrity and Efficiency. During
the reporting period, the EPA OIG reviewed 15 proposed changes to legislation,
regulations, policy, procedures or other documents that could affect the EPA or the
Inspector General, and provided comments on three.
40
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
U.S. Chemical Safety and Hazard Investigation Board
The U.S. Chemical Safety and Hazard Investigation
Board (CSB) was created by the Clean Air Act
Amendments of 1990. The CSB's mission is to
investigate accidental chemical releases at facilities,
report to the public on the root causes, and
recommend measures to prevent future occurrences.
In FY 2004, Congress designated the EPA Inspector General to serve as the Inspector
General for the CSB. As a result, the EPA OIG has the responsibility to audit, evaluate,
inspect and investigate the CSB's programs, and to review proposed laws and regulations
to determine their potential impact on the CSB's programs and operations. Details on our
work involving the CSB are available at http://www.csb.gov/inspector-general.
OIG Testifies on CSB Improperly Using Private Email Accounts
Patrick Sullivan, EPA Assistant Inspector General for Investigations, testified
March 4, 2015, before the Committee on Oversight and Government Reform,
U.S. House of Representatives, on the improper use of private emails by CSB.
Sullivan testified that the OIG had submitted a Report of Investigation to President
Obama noting that the CSB's Chairperson, General Counsel and Managing Director
"used private, nongovernmental email systems to communicate on CSB matters, and
those communications were not preserved as official records." Further, Sullivan said that
the Chairperson and General Counsel "purposely employed nongovernmental systems so
that certain CSB business did not appear on CSB systems." Sullivan noted that although
CSB subsequently issued guidance telling staff to cease using nongovernmental email
accounts for CSB business, the OIG found that the practice continued.
The EPA OIG had difficulty obtaining documents related to this investigation, and on
September 5, 2013, the EPA OIG had issued a Seven Day Letter to the CSB
Chairperson regarding CSB's refusal to provide requested documents. EPA OIG
Inspector General Elkins brought this matter to the attention of the House committee
during testimony on June 19, 2014, and as a result of that testimony the committee
instructed CSB to provide the documents that the OIG sought. CSB subsequently
provided requested documents. The emails sought were part of an investigation
regarding whistleblowers who had filed confidential complaints with the Office of
Special Counsel. The documents led the OIG to conclude that there was sufficient
evidence to find the CSB violated the Federal Records Act.
41
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Semiannual Report to Congress October 1, 2014—March 31, 2015
During other testimony by Elkins on February 3, 2015, to update the committee on
progress being made with CSB, he noted that although CSB had complied with the
committee's instructions to provide certain documents to the OIG, "they have yet to
provide an affirmation of full compliance with our requests." Sullivan indicated on
March 4, 2015, that the affirmation had still not been received.
CSB Needs to Improve Controls for Approving Acquisitions
CSB did not implement internal controls designed to ensure that
acquisitions over $50,000 receive board approval, resulting in over
$1.9 million in acquisitions being at risk due to the lack of board
approval.
The OIG initiated this review after receiving a hotline complaint about a CSB contract
awarded for about $1 million. While the OIG's audit work continues, this early warning
report addressed issues of concern that the OIG believed needed immediate attention.
CSB had 14 acquisitions (interagency agreements, contracts and purchase orders) each
over $50,000 that did not have the required board approval; these acquisitions totaled
over $1.9 million. Also, CSB did not record its market research actions for two contracts
totaling over $380,000, or its quality assurance surveillance plan actions for seven
contracts totaling over $1.4 million. Therefore, funds were at risk and there was
insufficient assurance that CSB received the best value for government money spent.
The initial response from CSB indicated there were dissenting views within the
organization regarding the issues that the OIG noted.
(Report No. 15-P-0007, Early Warning Report: Not Following Internal Controls Put
Acquisitions at Risk, October 29, 2014)
CSB Should Improve Information Security Program
CSB should improve key aspects of its information security program related to
planning and security controls, its vulnerability testing process, and internal
control over information technology inventory.
The Federal Information Security Management Act requires federal agencies to develop
an information security program that protects its operations and assets, and the OIG is
required to perform an annual evaluation of the program. Federal information systems are
subject to threats, including purposeful attacks.
The OIG recommended that CSB update it system security plan, implement a risk
management network, improve security room controls, develop a process for orderly
shutdown of critical information technology assets, create plans to remediate systems
42
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Semiannual Report to Congress October 1, 2014—March 31, 2015
with known vulnerabilities, and improve its inventory control practices. CSB concurred
with the recommendations and has initiated corrective actions.
(Report No. 15-P-0073, Key Aspects of CSB Information Security Program Need
Improvement, February 3, 2015)
CSB Financial Statements Found to Be Fairly Presented
The firm that audited CSB's financial statements for FYs 2014 and 2013 on behalf of the
EPA OIG found that the statements were fairly presented and free of material
misstatements. The auditors found no matters involving CSB internal controls that they
considered to be a material weakness, and the firm found no instances of noncompliance.
(Report No. 15-1-0022, Audit of the U.S. Chemical Safety and Hazard Investigation
Board's Fiscal Years 2014 and 2013 Financial Statements, November 17, 2014)
43
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Statistical Data
Profile of Activities and Results
Audit and evaluation operations
OIG reviews
October 1, 2014-
March31,2015
($ in millions)
Questioned costs *
Recommended efficiencies *
Costs disallowed to be recovered
Costs disallowed as cost efficiency
Reports issued by OIG
Reports resolved
(Agreement by agency officials
to take satisfactory corrective actions) **
$2.1
$61.6
$8.8
$0.0
27
70
Audit and evaluation operations
Reviews performed by Single Audit Act auditors
Questioned costs *
Recommended efficiencies *
Costs disallowed to be recovered
Costs disallowed as cost efficiency
Single Audit Act reviews
Agency recoveries
Recoveries from audit resolutions
of current and prior periods
(cash collections or offsets to
future payments) ***
October 1, 2014-
March31,2015
($ in millions)
$2.5
$0.0
$0.0
$0.0
101
$0.7
Investigative operations
Total Fines and Recoveries ****
Cost Savings
Cases Opened During Period
Cases Closed During Period
Indictments/Informations of
Persons or Firms
Convictions of Persons or Firms
Civil Judgments/Settlements/Filings
October 1, 2014-
March31, 2015
($ in millions)
$6.0
$0.02
42
57
16
7
1
Questioned costs and recommended efficiencies are
subject to change pending further review in the audit
resolution process.
Reports resolved are subject to change pending
further review.
Information on recoveries from audit resolutions is
provided by the EPA's Office of Financial
Management and is unaudited.
Fines and recoveries resulting from joint
investigations.
44
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Audit, Inspection and Evaluation Report Resolution
Status report on perpetual inventory of reports in resolution process
for semiannual period ending March 31, 2015
Report category
A. For which no management
decision was made by
October 1,201 4*
B. Which were issued during the
reporting period
C. Which were issued during the
reporting period that required
no resolution
Subtotals (A + B - C)
D. For which a management
decision was made during the
reporting period
E. For which no management
decision was made by
March 31, 201 5
F. Reports for which no
management decision was
made within 6 months of
issuance
No. of
reports
80
128
70
138
107
31
47
Report issuance
($ in thousands)
Questioned
costs
$37,144
4,660
0
41,804
23,119
18,685
15,007
Recommended
efficiencies
$19,577
61,600
0
81,177
1,728
79,449
19,577
Report resolution costs
sustained
($ in thousands)
To be
recovered
$190
8,883
0
9,073
8,886
187
79
As
efficiencies
$0
0
0
0
0
0
0
Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this
report and our previous semiannual report results from corrections made to data in our audit tracking system.
45
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Table 1: Inspector General-issued reports with questioned costs for semiannual period ending
March 31, 2015 ($ in thousands)
Report category
A. For which no management decision was made by
October 1,201 4**
B. New reports issued during period
Subtotals (A + B)
C. For which a management decision was made during the
reporting period:
(i) Dollar value of disallowed costs
(ii) Dollar value of costs not disallowed
D. For which no management decision was made by
March 31, 201 5
Reports for which no management decision was made
within 6 months of issuance
No. of
reports
22
8
30
3
2
3
19
13
Questioned
costs *
$37,144
4,660
41,804
23,119
8,883
14,236
18,685
15,007
Unsupported
costs
$14,721
2,753
27,474
14,121
0
14,121
13,353
11,511
Questioned costs include unsupported costs.
Any difference in number of reports and amounts of questioned costs between this report and our previous
semiannual report results from corrections made to data in our audit, inspection and evaluation tracking system.
Table 2: Inspector General-issued reports with recommendations that funds be put to better use
for semiannual period ending March 31, 2015 ($ in thousands)
Report Category
A. For which no management decision was made by October 1, 2014 *
B. Which were issued during the reporting period
Subtotals (A + B)
C. For which a management decision was made during the reporting period:
(i) Dollar value of recommendations from reports that were
agreed to by management
(ii) Dollar value of recommendations from reports that were
not agreed to by management
(iii) Dollar value of nonawards or unsuccessful bidders
D. For which no management decision was made by March 31, 2015
Reports for which no management decision was made
within 6 months of issuance
No. of
reports
5
5
10
3
0
3
0
8
5
Dollar
Value
$19,577
61,600
81,177
1,728
0
1,728
0
79,449
19,577
Any difference in number of reports and amounts of funds put to better use between this report and our previous
semiannual report results from corrections made to data in our audit, inspection and evaluation tracking system.
Audits, inspections, and evaluations with no final action as of March 31, 2015, over 365 days past
the date of the accepted management decision (including audits, inspections and evaluations in appeal)
Audits, inspections and evaluations
Program
Assistance agreements
Contract audits
Single audits
Financial statement audits
Total
Total
49
12
0
19
5
85
Percentage
58
14
0
22
6
100
46
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Hotline Activity
The following table shows EPA OIG hotline activity regarding complaints of fraud, waste and abuse
in EPA programs and operations during the semiannual reporting period ending March 31, 2015.
Semiannual period
(October 1,201 4-
March 31, 201 5)
Issues open at the beginning of the period
Inquiries received during the period
Inquiries closed during the period
Inquiries pending at the end of the period
Issues referred to others
OIG offices
EPA program offices
Other federal agencies
State/local agencies/other
Contacts made to the EPA OIG Hotline
(telephone, voicemails, emails, website and correspondence)
189
168
219
138
110
37
8
13
5,059
The hotline makes it easy to report allegations of fraud, waste, abuse, mismanagement or misconduct in
the programs and operations of the EPA. Employees, as well as contractors, grantees, program
participants and members of the general public, may report allegations to the OIG.
The Inspector General Act of 1978, as amended, and other laws (such as the Whistleblower Protection
Enhancement Act of 2012) protect those who make hotline complaints. Individuals who contact the
hotline are not required to identify themselves and may request confidentiality. However, the OIG
encourages those who report allegations to identify themselves so that they can be contacted if the OIG
has additional questions. Pursuant to Section 7 of the Inspector General Act, the OIG will not disclose the
identity of an EPA employee who provides information unless that employee consents or the Inspector
General determines that such disclosure is unavoidable during the course of the investigation, audit or
evaluation. As a matter of policy, the OIG will provide comparable protection to employees of
contractors, grantees and others who provide information to the OIG and request confidentiality.
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail: OIG_Hotline@epa.gov
phone: 1-888-546-8740
fax: 202-566-2599
online: http://www.epa.gov/oig/hotline.htm
write OIG EPA Hotline
1200 Pennsylvania Ave NW
Mailcode2431T
Washington, DC 20460
47
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Summary of Investigative Results
Summary of investigative activity during reporting period
Cases open as of October 1, 2014 *
Cases opened during period
Cases closed during period
Cases pending as of March 31 , 201 5
224
42
57
209
* Adjusted from prior period.
Investigations pending by type as of March 31, 2015
Contract fraud
Grant fraud
Laboratory fraud
Employee integrity
Program integrity
Computer crimes
Threat
Retaliation
Other
Total
Superfund
9
0
3
3
1
0
0
0
3
19
Management
8
19
5
35
9
0
5
1
13
95
Split funded
11
7
3
35
5
6
2
0
8
77
Recovery Act
4
10
0
0
1
0
0
0
1
16
CSB
0
0
0
2
0
0
0
0
0
2
Total
32
36
11
75
16
6
7
1
25
209
Results of prosecutive actions
Criminal indictments/informations/complaints
Convictions
Civil judgments/settlements/filings
Deportations
Fines and recoveries (including civil)
Prison time
Prison time suspended
Home detention
Probation
Community service
EPA OIG only
5
3
0
0
$4,718
0 months
0 months
0 months
72 months
48 hours
Joint*
11
4
1
0
$3,068,345
146 months
3 days
12 months
336 months
100 hours
Total
16
7
1
0
$3,073,063
146 months
3 days
12 months
408 months
148 hours
'With another federal agency.
Administrative actions
Suspensions
Debarments
Other administrative actions
Total
Administrative recoveries
Cost avoidance
EPA OIG only
1
12
30
43
$172,045
$20,305
Joint*
6
0
1
7
$0
$0
Total
7
12
31
50
$172,045
$20,305
*With another federal agency.
48
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Appendices
The Inspector General Act of 1978, as amended, requires a listing, subdivided according to subject matter, of each report issued by
the OIG during the reporting period. For each report, where applicable, the Inspector General Act also requires a listing of the dollar
value of questioned costs and the dollar value of recommendations that funds be put to better use.
Questioned Costs
Report No.
Report
Date
Ineligible Unsupported Unreasonable
Costs Costs Costs
Federal
Recommended
Efficiencies
PERFORMANCE REPORTS
15-P-0001
15-P-0003
15-P-0006
15-P-0007
15-P-0013
15-P-0020
15-P-0032
15-P-0033
15-P-0042
15-P-0046
15-P-0064
15-P-0073
15-P-0099
15-P-0101
15-P-0109
15-P-0115
EPA's Fleet Management Program Needs Improvement
EPA Region 6 Mismanaged Coastal Wetlands Funds
Enhanced EPA Oversight for Clean Air Act Title V Revenues
Not Following Internal Controls May Put CSB Acquisitions at Risk
No Significant Contamination Found at Deleted Superfund Sites
EPA FY 2014 Federal Information Security Management Act Audit
EPA Needs to Demonstrate Benefits of Drinking Water Fund Projects
EPA Needs Better Management of Personal Property in Warehouses
Call Center: Contract Management Needs Improvement
EPA Needs to Improve National Pesticide Info. Center Outreach
EPA's Antimicrobial Testing Program Efficacy Results Reporting
Aspects of CSB Information Security Program Need Improvement
Quick Reaction: EPA Pesticide Inspections Needed in North Dakota
EPA Has Considered Environmental Justice for Air Toxic Inspections
EPA Needs to Justify How it is Using Title 42 Hiring Authority
Scientific Equipment Use Needs Enterprise Approach to Manage
TOTAL PERFORMANCE REPORTS = 16
Oct. 06, 2014
Oct. 09, 2014
Oct. 20, 2014
Oct. 29, 2014
Nov. 10, 2014
Nov. 13, 2014
Dec. 05, 2014
Dec. 08, 2014
Dec. 23, 2014
Jan. 07, 2015
Jan. 21, 2015
Feb. 03, 201 5
Feb. 23, 201 5
Feb. 26, 201 5
Mar. 05, 2015
Mar. 16, 2015
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
$0
0
0
0
0
0
0
0
910,776
0
0
0
0
0
0
0
$910,776
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
$0
780,793
0
0
0
0
0
57,234,594
0
0
0
0
0
3,531 ,870
0
$61,547,257
SINGLE AUDIT REPORTS
15-3-0004
15-3-0005
15-3-0009
15-3-0010
15-3-0011
15-3-0012
15-3-0015
15-3-0016
15-3-0017
15-3-0018
15-3-0019
15-3-0023
15-3-0024
15-3-0026
15-3-0027
15-3-0028
15-3-0029
15-3-0030
15-3-0031
15-3-0034
15-3-0035
15-3-0036
15-3-0037
15-3-0038
15-3-0039
15-3-0040
15-3-0041
15-3-0043
15-3-0044
15-3-0045
15-3-0047
Montana, State of- FYs 2012 & 2013 (biennial report)
New York, State of-FY 201 3
Bluffdale, Utah, City of-FY 2011
Santa Barbara, California, City of-FY 2012
Two Buttes, Colorado, Town of-FY 2012
Ute Mountain Ute Tribe, Colorado - FY 2012
Iowa, State of-FY 201 3
Illinois, State of-FY 201 3
Idaho, State of-FY 201 3
Hawaii Department of Health, State of-FY 2013
Connecticut, State of-FY 2013
Lowell, Wisconsin, Village of-FY 2012
NW Regional Planning Commission, Spencer, Wisconsin - FY 2012
Seymour, Wisconsin, City of-FY 2012
Clark County, Wisconsin, - FY 2013
Door County, Wisconsin - FY 2012
Florence County, Wisconsin - FY 2012
Fond Du Lac County, Wisconsin - FY 2012
Forest County, Wisconsin - FY 2012
Barbourville Utility Commission, Kentucky - FY 201 3
Bay County, Florida -FY 201 3
Belzoni, Mississippi, City of-FY 2012
New Hampshire, State of-FY 2013
New Jersey, State of - FY 201 3
Ohio, State of-FY 201 3
South Carolina, State of-FY 2012
Washington, State of-FY 2013
West Virginia, State of-FY 2013
Wisconsin, State of-FY 2013
Wyoming, State of-FY 2013
Jackson, Mississippi, City of-FY 2013
Oct. 15, 2014
Oct. 15, 2014
Nov. 04, 2014
Nov. 04, 2014
Nov. 04, 2014
Nov. 04, 2014
Nov. 06, 2014
Nov. 06, 2014
Nov. 06, 2014
Nov. 06, 2014
Nov. 06, 2014
Nov. 17, 2014
Nov. 17, 2014
Nov. 18, 2014
Nov. 18, 2014
Nov. 18, 2014
Nov. 18, 2014
Nov. 18, 2014
Nov. 18, 2014
Dec. 04, 201 4
Dec. 05, 201 4
Dec. 05, 2014
Dec. 08, 2014
Dec. 08, 2014
Dec. 08, 2014
Dec. 08, 201 4
Dec. 08, 201 4
Dec. 30, 201 4
Dec. 30, 201 4
Dec. 30, 2014
Jan. 09, 2015
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
71,035
0
53,972
0
0
0
0
$0
0
0
0
0
0
0
0
673,856
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
$0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
49
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Questioned Costs
Report No.
15-3-0048
15-3-0049
15-3-0050
15-3-0051
15-3-0052
15-3-0053
15-3-0054
15-3-0055
15-3-0056
15-3-0057
15-3-0058
15-3-0059
15-3-0060
15-3-0061
15-3-0062
15-3-0063
15-3-0065
15-3-0066
15-3-0067
15-3-0068
15-3-0069
15-3-0070
15-3-0077
15-3-0078
15-3-0079
15-3-0080
15-3-0081
15-3-0082
15-3-0083
15-3-0084
15-3-0085
15-3-0086
15-3-0087
15-3-0088
15-3-0089
15-3-0090
15-3-0091
15-3-0092
15-3-0093
15-3-0094
15-3-0095
15-3-0096
15-3-0097
15-3-0098
15-3-0100
15-3-0102
15-3-0103
15-3-0104
15-3-0105
15-3-0106
15-3-0107
15-3-0108
15-3-0110
15-3-0111
15-3-0112
15-3-0113
15-3-0114
15-3-0116
15-3-0117
15-3-0118
15-3-0119
15-3-0120
15-3-0121
15-3-0122
15-3-0123
15-3-0124
Report
Tennessee, State of- FY 2013
Hiawassee, Georgia, City of- FY 2013
Delaware, State of- FY 2013
California, State of- FY 201 3
Blue Island, Illinois, City of- FY 2013
Casselberry, Florida, City of- FY 2013
North Carolina, State of- FY 2013
Puerto Rico Safe Drinking Water Revolving Loan Fund - FY 201 3
United States Virgin Islands, Government of- FY 2012
United States Virgin Islands - FY 2013
Aiken County, South Carolina - FY 2012
Windham Regional Commission, Vermont - FY 2013
Putney School, Inc., Vermont - FY 2013
Southern Maine Regional Planning Commission, Maine - FY 201 3
Warwick, New York, Village of- FY 201 1
Shoshone & Arapaho Tribes of Wind River Reservation, Wyoming
Wrens, Georgia, City of - FY 201 2
Washington, Georgia, City of -FY 201 2
Thomaston, Georgia, City of- FY 2012
Louisville, Georgia, City of -FY 201 2
Richmond Hill, Georgia, City of- FY 2012
Covelo Community Services District, California - FY 2012
Hardinsburg, Kentucky, City of- FY 2012
Wurtsboro, New York, Village of- FY 201 1
Hernando, Mississippi, City of- FY 2012
Claiborne County, Mississippi - FY 201 2
West Point, Mississippi, City of- FY 2012
Tunica, Mississippi, Town of- FY 2012
Jasper, Georgia, City of - FY 201 3
Lakeland, Florida, City of- FY 2013
Marco Island, Florida, City of -FY 201 3
New Mexico Environment Department, New Mexico - FY 2013
Puerto Rico Aqueduct and Sewer Authority, Puerto Rico - FY 201 3
Woodville, Mississippi, Town of- FY 2012
Tonopah, Nevada, Town of- FY 2012
Te-Moak Tribe of W. Shoshone/Battle Mt. Band, Nevada- FY 2012
Welch, West Virginia, City of- FY 2012
East Tawakoni, Texas, City of- FY 2012
Spring Hill, Tennessee, City of- FY 2012
Puerto Rico Environmental Quality Board - FY 2013
Colorado, State of- FY 201 3
Arizona, State of- FY 201 3
New Mexico Finance Authority, New Mexico - FY 2013
Alaska, State of- FY 201 3
District of Columbia Water and Sewer Authority - FY 2013
Old Town Water District, Maine - FY 2013
Berlin Water Works, New Hampshire - FY 2013
Narragansett Bay Commission, Rhode Island - FY 201 3
Portsmouth Water and Fire District, Rhode Island - FY 2013
Warren, Rhode Island, Town of- FY 2013
Community Develop. Improvement Corp, South Carolina - FY 201 1
Jefferson County, Mississippi - FY 2012
McDonough, Georgia, City of-FY 2013
Moultrie, Georgia, City of-FY 2013
Webster, Florida, City of-FY 2013
Nashville, Georgia, City of-FY 201 3
Prentiss County, Mississippi - FY 201 1
Ishpeming, Michigan, City of-FY 201 3
Chicago Park District, Illinois - FY 2013
Texas, State of-FY 201 3
Puerto Rico Water Pollution Control Revolving Fund - FY 201 3
Putnam Public Service District-Sewer Fund, West Virginia - FY 201 1
Ozone Transport Commission, District of Columbia, -FY 2012
Scott Township Sewer and Water Authority, Pennsylvania - FY 201 1
Ozone Transport Commission, District of Columbia - FY 2013
Sheffield, Pennsylvania, Municipal Authority - FY 2012
Date
Jan. 09, 2015
Jan. 09, 2015
Jan. 09, 2015
Jan. 09, 2015
Jan. 09, 2015
Jan. 09, 2015
Jan. 14, 2015
Jan. 14, 2015
Jan. 14, 2015
Jan. 14, 2015
Jan. 16, 2015
Jan. 16, 2015
Jan. 16, 2015
Jan. 16, 2015
Jan. 16, 2015
Jan. 20, 2015
Jan. 21, 2015
Jan. 21, 2015
Jan. 21, 2015
Jan. 21, 2015
Jan. 21, 2015
Jan. 22, 2015
Feb. 05, 201 5
Feb. 09, 2015
Feb. 09, 2015
Feb. 09, 2015
Feb. 09, 2015
Feb. 09, 201 5
Feb. 09, 201 5
Feb. 09, 201 5
Feb. 09, 201 5
Feb. 10, 2015
Feb. 10, 2015
Feb. 17, 2015
Feb. 17, 2015
Feb. 17,2015
Feb. 17,2015
Feb. 17,2015
Feb. 17,2015
Feb. 18, 2015
Feb. 18, 2015
Feb. 18, 2015
Feb. 19, 2015
Feb. 19, 2015
Feb. 23, 201 5
Mar. 02, 201 5
Mar. 02, 201 5
Mar. 02, 2015
Mar. 02, 2015
Mar. 02, 2015
Mar. 03, 2015
Mar. 03, 201 5
Mar. 04, 2015
Mar. 04, 2015
Mar. 04, 2015
Mar. 04, 2015
Mar. 04, 2015
Mar. 23, 2015
Mar. 23, 2015
Mar. 30, 201 5
Mar. 30, 201 5
Mar. 30, 201 5
Mar. 30, 201 5
Mar. 30, 2015
Mar. 30, 2015
Mar. 31,2015
Federal
Ineligible Unsupported Unreasonable Recommended
Costs Costs Costs Efficiencies
0
0
0
0
0
0
1,668,169
0
0
0
0
0
0
0
0
19,271
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,825
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
50
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Questioned Costs
Federal
Report No.
Report
Date
Ineligible
Costs
Unsupported Unreasonable Recommended
Costs Costs Efficiencies
15-3-0125 Alexandria-Porter Joint Sewer Authority, Pennsylvania-FY 2012 Mar. 31,2015 0 0
15-3-0126 Crab Orchard-Macarthur Public Srv. Dist., West Virginia -FY 2012 Mar. 31,2015 0 0
15-3-0127 New Castle, Delaware, City of - FY 2012 Mar. 31, 2015 0 0
15-3-0128 Ann Arbor, Michigan, City of- FY 2012 Mar. 31,2015 0 0
TOTAL SINGLE AUDIT REPORTS = 101 $1,812,447 $675,681
ATTESTATION REPORTS
15-4-0071 Pegasus Technical Services Inc. Improved Its Internal Control Jan. 29, 2015
15-4-0072 Pioneer Valley Planning Commission Costs Questioned Feb. 02, 2015
TOTAL ATTESTATION REPORTS = 2
NON-AUDIT REPORTS
15-N-0008 Compendium of Unimplemented Recommendations Sept. 30 2014 Oct. 31, 2014
15-N-0025 Early Warning: Some at EPA on Paid Administrative Leave for Years Nov. 19,2014
TOTAL NON-AUDIT REPORTS = 2
94,891
1,166,774
$1,166,774
19,277
$19,277
DIG INTERNAL BRIEFING REPORTS
15-B-0002 EPA DIG Compliance With Managing Fleet Vehicles Oct. 06, 2014
15-B-0014 Ineffective Oversight of Purchase Cards at EPA DIG Nov. 10,2014
15-B-0074 EPA DIG Not Fully Compliant with Time and Attendance Policy Feb. 04, 2015
15-B-0075 Congressional Request—EPA Tracking of Overtime Compensation Feb. 04, 2015
15-B-0076 Improvements Needed by EPAOIG in Employee Hiring Process Feb. 05, 2015
TOTAL DIG INTERNAL BRIEFING REPORTS = 5
36,488
0
0
0
FINANCIAL AUDITS
15-1-0021 EPA's FYs 2014 and 2013 Financial Statements
15-1-0022 CSB's FYs 2014 and 2013 Financial Statements
TOTAL FINANCIAL AUDIT REPORTS = 2
Nov. 17, 2014
Nov. 17, 2014
TOTAL REPORTS ISSUED = 128
$1,907,338 $2,753,231
$0
$61,603,022
51
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Appendix 2—Reports Issued Without Management Decisions
For Reporting Period Ended March 31, 2015
The Inspector General Act of 1978, as amended, requires a summary of each audit report issued before the
commencement of the reporting period for which no management decision had been made by the end of the
reporting period, an explanation of the reasons such management decision had not been made, and a statement
concerning the desired timetable for achieving a management decision on each such report. OMB Circular A-50
requires resolution within 6 months of a final report being issued. In this section, we report on audits with
no management decision or resolution within 6 months of final report issuance. In the summaries below, we note the
agency's explanation of the reasons a management decision has not been made, the agency's desired timetable for
achieving a management decision, and the OIG follow-up status as of March 31, 2015.
In a February 4, 2015, memorandum seeking updates from senior agency staff on the status of recommendations,
the EPA's acting Chief Financial Officer noted the EPA continues to make progress in reaching timely management
decisions (agreement within 180 days of OIG report issuance). He noted that only 5 percent of management
decisions were late as of the end of the first quarter of FY 2015, compared with 15 percent at the end of the first
quarter of FY 2012. "Productive engagement between the agency and the OIG prior to issuance of the final audit
report has helped to resolve many potential disagreements and led to more timely management decisions," he said.
Report No. 14-P-0359, EPA's Alternative Asbestos Control Method Experiments Lacked Effective Oversight
and Threatened Human Health, September 25, 2014
Summary: This review assessed the EPA's oversight of Alternative Asbestos Control Method experiments. The OIG
found that the EPA conducted the Alternative Asbestos Control Method research for over a decade without
appropriate oversight or an agreed research goal. This resulted in wasted resources and the potential exposure of
workers and the public to unsafe levels of asbestos. The OIG recommended that the EPA improve research oversight
by requiring significant research to follow a controlled process, tracking project costs and contributions, and reviewing
and resolving internal EPA comments. The OIG also recommended that the EPA establish a process for the review of
alternative regulatory emission control method submissions, and establish and follow standard procedures.
Agency Explanation: The Office of Research and Development provided the OIG with proposed corrective action to
the last outstanding recommendation. The agency is still waiting on an OIG response and determination of corrective
action acceptance.
OIG Follow-Up Status: The OIG is reviewing the Office of Research and Development's response.
Office of Environmental Information
Report No. 14-P-0332, Cloud Oversight Resulted in Unsubstantiated and Missed Opportunities for Savings,
Unused and Undelivered Services, and Incomplete Policies, August 15, 2014
Summary: This review was conducted to determine whether the EPA had: (1) implemented its cloud initiatives in
accordance with the Federal Cloud Computing Strategy and associated requirements; and (2) developed formal
processes to monitor cloud vendors. The OIG found that the EPA developed processes to monitor cloud vendors.
However, controls for the EPA's cloud computing initiatives are incomplete and need improvement. As a result, the
EPA paid $2.3 million for services that were not fully rendered or did not comply with federal requirements. The OIG
recommended the EPA to undertake a number of corrective actions to address deficiencies in EPA's cloud computing
initiatives, including: improving related policies and procedures; providing additional training and oversight to
contracting officers; performing documented cost-benefit analyses that are in compliance with federal requirements;
and implementing a strategy to perform a documented analysis of all the assets in the EPA's information technology
portfolio to determine which assets should be consolidated, retired or moved to the cloud.
Agency Explanation: In December 2014, the Office of Environmental Information and the OIG were able to come to
consensus on the recommendations and corrective actions. The revised corrective action plan is in the process of
being approved by the Office of Environmental Information and sent to the OIG.
OIG Follow-Up Status: Agency provided incomplete response.
52
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Office of Grants and Debarment
Report No. 13-P-0341, Lead Remediation Association of America, August 6, 2013
Summary: The OIG found that the Lead Remediation Association of America's financial management system did not
meet the standards established under the Code of Federal Regulations. The association's accounting system data
were not updated timely. The association also made cash draws and submitted its final federal financial report using
the grant budget amounts rather than actual costs incurred. In addition, the association did not maintain source
documentation to support the costs incurred or claimed as required. We also found that the association did not meet
the grant objectives as outlined in the approved workplan. As of the date of OIG's report—2 years after the grant
period end date of June 30, 2011—the association had not produced the required DVDs, provided evidence of
brochure distribution, or completed the required training and workshops. As a result of the issues noted, the OIG
questioned the $249,870 claimed and recommended recovery of the $249,882 drawn under the grant.
Agency Explanation: The OIG has reactivated this audit and notified Office of Grants and Debarment that it can
proceed with work on developing the management decision. The Office of Grants and Debarment will contact principals
of the Lead Remediation Association of America to obtain additional materials available for evaluation in order to
develop its management decision. The forecast date to issue the management decision for the audit is June 30, 2015.
OIG Follow-Up Status: Resolution pending receipt of additional information.
Report No. 14-P-0131, National Association of State Departments of Agriculture Research Foundation Needs
to Comply With Certain Federal Requirements and EPA Award Conditions to Ensure the Success of Pesticide
Safety Education Programs, March 10, 2014
Summary: The National Association of State Departments of Agriculture Research Foundation's financial
management system did not meet certain federal requirements and conditions of the EPA award. Specifically, the
foundation incorrectly calculated and applied indirect cost rates, reported outlays for indirect costs in excess of
recorded expenses, and drew funds that exceeded its cash needs. As a result, we questioned $275,650. The
foundation did not document its procurement selection process or provide documentation to support any cost or price
analysis performed on its project management subcontract as required by the Code of Federal Regulations. The
foundation did not determine the reasonableness of costs for two subgrants as required by conditions of the award. In
addition, the foundation's written procurement policy lacked procedures to ensure compliance with the Code of
Federal Regulations. As a result, we questioned $295,976. The OIG also identified an unresolved issue pertaining to
potentially unallowable costs of $118,324 drawn under a prior EPA award. The costs, recorded as a refundable
advance, represent funds received as of year end but not yet earned.
Agency Explanation: The Office of Grants and Debarment continues to evaluate documents provided by the
foundation and has requested additional documents from the foundation to develop the agency management decision
for the audit. The forecast date to issue the management decision for the audit is June 30, 2015.
OIG Follow-Up Status: The OIG is reviewing the Office of Grants and Debarment's draft decision.
Office of Solid Waste and Emergency Response
Report No. 14-P-0364, EPA Needs to Improve its Process for Accurately Designating Land as Clean and
Protective for Reuse, September 29, 2014
Summary: This review was conducted to determine whether the EPA designation of sites that have achieved the
"protective for people" and/or "ready for anticipated use" performance measures include effective controls to ensure
long-term protection to human health and the environment. The OIG found that the EPA has limited controls for
verifying or testing the accuracy of Cross Program Revitalization Measures information that states and grantees
provide to show sites are not protective for people and ready for anticipated use. This review also found that the EPA
does not have adequate controls to verify that these designations continue to be valid and the sites remain protective
in the long-term. The OIG recommended that EPA improve controls over its guidance, review and reporting of the
Cross Program Revitalization Measures.
Agency Explanation: Four out of five recommendations have been resolved, with one recommendation still
outstanding. The agency and the OIG are working to resolve the final recommendation, yet no expected resolution
date is available.
OIG Follow-Up Status: None provided.
53
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Region 6—Regional Administrator
Report No. 13-4-0296, Labor-Charging Practices at the New Mexico Environment Department, June 17, 2013
Summary: This review found that three of the four New Mexico Environment Department bureaus did not always
comply with requirements found in the Code of Federal Regulations. The Air Quality Bureau and Drinking Water
Bureau charged labor, fringe benefits and indirect costs to federal grants based upon budget allocations instead of
actual activities performed. Personnel activity reports received from the Surface Water Quality Bureau to support
charges for labor costs incurred prior to July 2006 did not meet requirements. New Mexico personnel stated that they
charged labor based upon budget allocations because they thought the practice was acceptable. EPA OIG
questioned $298,159 in labor, fringe benefits and related indirect costs claimed by the Air Quality Bureau; $2,974,318
claimed by Drinking Water Bureau; and $2,733,798 claimed by Surface Water Quality Bureau. The OIG also
identified an additional $486,305 charged to a Drinking Water Bureau-administered grant which has not yet been
reported to the EPA.
Agency Explanation: The management decision letter to the New Mexico Environment Department was issued on
February 7, 2014. However, OIG acceptance has been delayed until questioned costs can be confirmed. The
expected resolution date is December 31, 2015.
OIG Follow-Up Status: None needed.
Region 7—Regional Administrator
Report No. 13-R-0367, American Recovery and Reinvestment Act Award to Grace Hill Settlement House,
August 30, 2013
Summary: This review found that Grace Hill's financial management system did not meet federal standards. In
particular, procurements did not meet the competition or cost and price analysis requirements of the Code of Federal
Regulations. The contract administration system also did not meet the code's requirements. Unallowable costs were
not segregated and financial management data were not properly supported, labor charges did not comply with
requirements, and cash draws did not meet the immediate cash needs requirements and were not properly
documented. As a result of the issues noted, the OIG questioned $1,615,353 of the $2,250,031 claimed under the
cooperative agreement. In addition, due to a lack of adequate documentation from Grace Hill, we were unable to
determine whether Grace Hill accomplished the objective of the cooperative agreement or met the job reporting
requirements of the American Recovery and Reinvestment Act's Section 1512.
Agency Explanation: Region 7 evaluated and consolidated the deviation request and supplemental documentation
provided by Grace Hill and submitted the deviation request to the Office of Grants and Debarment, National Policy,
Training and Compliance Division, on February 25, 2015. Region 7 is awaiting a determination from the Office of
Grants and Debarment before moving forward.
OIG Follow-Up Status: None needed.
Region 8—Regional Administrator
Report No. 2007-4-00078, Cheyenne River Sioux Tribe, September 24, 2007
Summary: The tribe did not comply with the financial and program management standards under the Code of Federal
Regulations and OMB Circular A-87. We questioned $3,101,827 of the $3,736,560 in outlays reported. The tribe's
internal controls were not sufficient to ensure that outlays reported complied with federal cost principles, regulations
and grant conditions. In some instances, the tribe also was not able to demonstrate that it had completed all work
under the agreements and had achieved the intended results.
Agency Explanation: Region 8 is working with the recipient on draft policies and procedures as part of a multi-federal
partnership with the tribe. In addition, the Office of Grants and Debarment and the region are discussing the contents
of the proposed final determination letter. Projected completion date is June 30, 2015.
OIG Follow-Up Status: No response received.
54
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Report No. 14-R-0032, The State of Colorado Did Not Fully Assure that Funds Intended to Treat Mining
Wastes and Remove Contaminants from Water Were Effectively Spent, November 19, 2013
Summary: The Colorado Department of Public Health and Environment generally complied with Colorado's state
procurement policies and procedures as required by Code of Federal Regulations. However, the department did not
always comply with the cost or price analysis requirements and did not include language in bid proposals designating
the date, time and place of bid openings, as required by State of Colorado Procurement Rule R-24-103-202a-08(b).
In addition, the department did not always ensure required federal language was included in bid proposals and
contracts. As a result, we questioned $2,593,495 claimed under the cooperative agreement.
Agency Explanation: Region 8 sent a draft management decision letter to the OIG for concurrence. Region 8 also has
had regular check-ins with the OIG on the ongoing efforts toward resolution with the state of Colorado. The region
and OIG are sharing detailed information about the audit resolution process. Region 8 sent a waiver request to the
Office of Grants and Debarment related to findings in the audit report after discussion with the OIG about the draft
management decision letter.
OIG Follow-Up Status: None needed.
Region 9—Regional Administrator
Report No. 13-3-0159, Summit Lake Paiute Tribe, Nevada - FY 2010, February 19, 2013
Summary: The tribe did not file or maintain documentation of compliance for annual reports. Also, the required
SF 425 report did not cover the correct period. A similar finding was noted in the prior year audit report. The tribe
recorded deferred revenues in the amount of $804,104 and only $150,416 in available cash. The single auditor
questioned $653,688. A similar finding was noted in the prior year audit report. The tribe's operating practices did not
reflect the processes described in the approved policies and procedures manual. The tribe did not properly reconcile
its SF 425 report to the general ledger for certain awards and the single auditor questioned $20,556. The single
auditor also questioned $76,216 involving amounts paid to the General Assistance Program Director.
Agency Explanation: Per request from the tribe, an EPA team went onsite at the end of FY 2014 to assist the tribe in
reviewing additional documentation for Agreed Upon Procedures #12-3-0072. The team completed the review and
briefed management on the outcome of the visit. In January 2015, the Deputy Assistant Regional Administrator and
Grants Management Office visited the tribe. Currently waiting for tribe to decide if it wants to repeal its appeal and ask
for debt forgiveness.
OIG Follow-Up Status: Under appeal.
Report No. 13-3-0160, Summit Lake Paiute Tribe, Nevada- FY2011, February 19, 2013
Summary: The tribe did not file the quarterly narratives for the General Assistance Program. Furthermore, the tribe
was unable to locate documentation for two quarterly SF 425 reports. There were no formalized controls regarding
the security of the payroll stamp. Also, the single auditor noted issues related to pay rates. A similar finding was noted
in the prior year audit report. Budgets prepared excluded the carry-forward amounts from prior periods. Several
transactions were not supported by a purchase order or other type of approval prior to the expenditure being made.
One transaction charged to travel in the amount of $2,877 did not appear to be valid and appropriate for the granting
requirements, and the single auditors questioned that amount.
Agency Explanation: Per request from the tribe, an EPA team went onsite at the end of FY 2014 to assist the tribe in
reviewing additional documentation for Agreed Upon Procedures #12-3-0072. The team completed the review and
briefed management on the outcome of the visit. In January 2015, the Deputy Assistant Regional Administrator and
Grants Management Office visited the tribe. Currently waiting for tribe to decide if it wants to repeal its appeal and ask
for debt forgiveness.
OIG Follow-Up Status: Under appeal.
Report No. 13-3-0350, Wells Band Council, Nevada - FYs 2008, 2011 and 2012, August 21, 2013
Summary: This review found numerous financial statement and major program compliance findings. As a result of
significant cash management issues, we questioned as unsupported $361,027 and recommended that the council be
considered high risk, in accordance with the Code of Federal Regulations.
55
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Semiannual Report to Congress October 1, 2014—March 31, 2015
Agency Explanation: The tribe had a tribal election but was unclear on the outcome, and hired a Certified Public
Accountant to assist them in resolving the audit findings. They will resubmit a corrective action plan by end of
March 2015. The region will issue a management decision letter upon receipt and review of the corrective action plan.
Concurrently, there is an OIG review No. 14-2-0316 that we hope will be resolved in one management decision letter.
O/G Follow-Up Status: None needed.
Report No. 14-2-0316, Wells Band Council Nevada - FY 2008, 2011 and 2012, August 21, 2013
Summary: EPA Region 9 requested assistance from the OIG due to concerns about the financial practices and
internal controls of the Wells Band Council. The financial practices and internal controls involved equipment and
travel costs, and timekeeping methods and procedures. The OIG found that the council did not timely submit federal
financial reports to support draws of $390,000 made by the Council under EPA grant OOT39801. By not submitting
federal financial reports within the period reviewed under this engagement, the council had not claimed any costs;
therefore, the OIG could not evaluate travel and equipment costs incurred under their EPA grant. Additionally, the
OIG found that council timekeeping methods and procedures were not in compliance with federal regulations.
Personnel activity reports or equivalent documents were not maintained. Also, the council's financial management
system did not meet the standards established under federal regulations.
Agency Explanation: The tribe had a tribal election but was unclear on the outcome, and hired a Certified Public
Accountant to assist them in resolving the audit findings. They will resubmit a corrective action plan by end of
March 2015. The region will issue a management decision letter upon receipt and review of the corrective action plan.
O/G Follow-Up Status: None needed.
Report No. 14-3-0248, Richmond, California, City of-2012, May 8, 2014
Summary: This review found that the city of Richmond did not report expenditures of federal awards for the
Brownfield Assessment and Cleanup Cooperative Agreements for FYs 2010 and 2011. The city made four
drawdowns totaling $600,000 after the budget and project end dates. The OIG questioned the $600,000 as
unsupported costs.
Agency Explanation: Management decision is delayed due to an ongoing OIG investigation involving the audit
recipient.
OIG Follow-Up Status: Pending further investigation from the OIG.
Total reports issued before reporting period for which
no management decision had been made as of March 31, 2015 =14
56
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Appendix 3—Reports With Corrective Action Not Completed
In compliance with reporting requirements of Section 5(a)(3) of the Inspector General Act of 1978, as amended, we
are to identify each significant recommendation described in previous semiannual reports on which corrective action
has not been completed.
On February 4, 2015, the EPA's acting Chief Financial Officer noted in a memorandum to senior agency staff that
"While reaching management decision with the Office of Inspector General continues to improve, I urge you to pay
attention to the increasing number of significantly late corrective actions." He noted that he was "concerned ...
about the increasing number of corrective actions that remain incomplete 365 days or more beyond the due date
established in the agency's agreed-to corrective action plans." In July 2012, the OIG changed its policy to allow the
agency an additional 365 days beyond the agreed due date before designating a corrective action as late. The acting
Chief Financial Officer stated that "even with this 1 -year 'grace' period for completion, the number of late corrective
actions continue to increase." He said that although only seven corrective actions were 365 or more days late at the
end of the second quarter of FY 2012, that number rose to 53 at the end of the first quarter of FY 2015. The acting
Chief Financial Officer urged agency senior staff to "monitor audit follow-up activities closely and try to anticipate and
address issues that may potentially delay the timely completion of corrective actions."
Several examples of why recommendations remained unimplemented follow:
• In a report on contingency planning for oil and hazardous substance response, we recommended that the Office
of Solid Waste and Emergency Response assess the resources—including On-Scene Coordinators—necessary
to develop and maintain contingency plans, and use the results of the analysis to develop a workforce plan to
distribute contingency planning resources. The EPA agreed to continue evaluation of resources, but has placed
management action on hold until the spring of 2015 because of numerous staffing changes and shifts in
responsibilities that may make the recommendation unwarranted. (Report No. 13-P-0152)
• In a report on controls over state underground storage tank inspection programs in EPA regions, we
recommended that the Office of Solid Waste and Emergency Response require the EPA and states to enter into
Memorandums of Agreement that reflect program changes and address oversight of municipalities conducting
inspections. The EPA agreed that regulations will be finalized, but additional processes and steps have
contributed to delays in completing the publications. (Report No. 12-P-0289)
• In a report on the need for the EPA to update its fees rule to recover more Motor Vehicle and Engine Compliance
Program Costs, we recommended that the Office of Air and Radiation update the 2004 fees rule to increase the
amount of costs it can recover. The EPA noted that it was to begin planning for the new rule in 2013 and formal
work would begin in 2014, but projected that the rule will not be completed until 2018. (Report No. 11-P-0701)
Tables listing all recommendations for which corrective action has not been completed, by report, follow starting on
the next page; there are separate tables for the EPA and CSB. Below is a listing of the responsible EPA offices.
Many of the recommendations have completion dates in the future due to the complexity or challenging nature of the
recommendations. While a recommendation may be listed as unimplemented, the agency may be on track to
complete agreed-upon corrective actions by the planned due date. A reason for delay is only shown for those
recommendations that are past their original planned completion date. The information regarding reason for delay
was provided by the agency and was not verified by the OIG.
Responsible Agency Offices:
of Air and Radiation
of Administration and Resources Management
of the Chief Financial Officer
of Chemical Safety and Pollution Prevention
of Enforcement and Compliance Assurance
of Environmental Information
of Research and Development
of Solid Waste and Emergency Response
of Water
OAR
OARM
OCFO
OCSPP
OECA
OEI
ORD
OSWER
OW
Region 2
Region 6
Region 8
Region 9
Region 10
Office
Office
Office
Office
Office
Office
Office
Office
Office
57
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
EPA Reports With Unimplemented Recommendations
Report Title/No.
More Action is Needed to Protect Water
Resources from Unmonitored
Hazardous Chemicals (14-P-0363)
Report
Date
09/29/14
Office
OW
Unimplemented Recommendation
1 : Develop, in coordination with the Office of
Environmental Information, a usable format for
sharing Toxics Release Inventory data on
discharges sent to sewage treatment plants,
with OW developing materials to explain the
utility of Toxics Release Inventory data to
National Pollutant Discharge Elimination System
permit writers and pretreatment program
personnel. This will include exploring options for
an online search tool to more easily identify
Toxics Release Inventory discharges to specific
sewage treatment plants.
2: Develop, in coordination with EPA regions, a
list of chemicals beyond the priority pollutants
appropriate for inclusion among the chemicals
subject to discharge permits. This may include:
a. Review of Toxics Release Inventory-
reported discharges to sewage treatment
plants. Initial review could focus on Resource
Conservation and Recovery Act hazardous
chemicals reported in the Toxics Release
Inventory.
b. Review of chemicals monitored nationwide
in sewage treatment plant discharge permits,
especially chemicals monitored by Region 9.
c. Review of chemical monitoring data
already collected by sewage treatment plants
but not included in discharge permits.
d. Discussion with the Office of Resource
Conservation and Recovery for suggested
hazardous chemicals.
e. Development of mechanisms that ensure
discharge and pretreatment programs
coordinate during discharge permit writing.
3: Confirm, in coordination with OECA and EPA
regions, that sewage treatment plants and their
industrial users are aware of and comply with
the 40 CFR 403. 1 2(p) requirement that industrial
users submit hazardous waste notifications.
4: Develop, in coordination with OECA,
mechanisms to:
a. Improve sewage treatment plant
compliance with permit terms that require
submission of Whole Effluent Toxicity
monitoring results to the permitting authority.
b. Facilitate the use of monitoring data to
track facilities that have violated chemical or
Whole Effluent Toxicity permit exceedance
requirements.
Planned
Completion
Date
09/30/15
09/30/15
09/30/15
09/30/15
Reason for Delay
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
58
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
EPA's Risk Assessment Division Has
Not Fully Adhered to Its Quality
Management Plan (14-P-0350)
EPA Can Help Consumers Identify
Household and Other Products with
Safer Chemicals by Strengthening It's
"Design for the Environment" Program
(14-P-0349)
EPA Needs to Work With States to
Develop Strategies for Monitoring the
Impact of State Activities (14-P-0348)
EPA Needs to Improve Contract
Management Assessment Program
Implementation to Mitigate Contracting
Vulnerabilities (14-P-0347)
Report
Date
09/10/14
09/09/14
09/03/14
09/02/14
Office
OCSPP
OCSPP
ow
OARM
Unimplemented Recommendation
2: Direct Risk Assessment Division's Quality
Assurance Coordinator to conduct annual
internal quality assurance audits in accordance
with Risk Assessment Division's Quality
Management Plan.
3: Direct Risk Assessment Division to identify
and document individual staff training needs to
ensure that Risk Assessment Division
addresses quality assurance-related training
gaps.
4: Ensure that Risk Assessment Division's
Quality Management Plan and/or Office of
Pollution Prevention and Toxics' quality
assurance annual report and work plan are
updated accordingly when minor and major
changes to Risk Assessment Division's quality
assurance activities are made.
6: Conduct a quality assurance analysis of the
Office of Pollution Prevention and Toxics to
determine whether all divisions have fully
implemented their Quality Management Plans.
3: Develop and implement controls for
accomplishing removal of the Design for the
Environment logo from the websites of partners
who leave the program.
4: Take appropriate action to address
noncompliance with Design for the Environment
partnership agreements discovered as a result
of this review.
6: Develop robust, transparent and adequately
supported performance measures that capture
the Design for the Environment program's
results.
1 : Work with state and federal Task Force
members in the Mississippi River Watershed to
develop and enhance monitoring and
assessment systems that will track the
environmental results of state nutrient reduction
activities, including their contribution to reducing
the size of the Gulf of Mexico hypoxic zone.
2: Ensure the organizational changes currently
being considered for the contracting function at
the EPA provide 0AM (Office of Acquisition
Management) with greater authority and
oversight over regional contracting organizations
are implemented, to allow for more effective
Contract Management Assessment Program
implementation.
Planned
Completion
Date
09/30/15
09/30/15
09/30/15
09/30/15
06/30/15
06/30/15
09/30/15
06/30/15
09/15/15
Reason for Delay
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
59
-------
Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
Increased Emphasis on Strategic
Sourcing Can Result in Substantial
Savings (14-P-0338)
EPA Met or Exceeded Most Internal
Climate Change Goals, But Data
Quality and Records Management
Procedures Need Improvement
(14-P-0325)
Impact of EPA's Conventional Reduced
Risk Pesticide Program is Declining
(14-P-0322)
Report
Date
08/26/14
07/29/14
07/24/14
Office
OARM
OARM
OCSPP
Unimplemented Recommendation
1 : Develop a plan of action to strategically
source wireless services and print management.
If the plan is to source these commodities
internally because it is not practicable under the
Federal Strategic Sourcing Initiative, perform a
price comparison with established pricing under
the FSSI solution(s) to ensure the best possible
pricing is negotiated.
3: Develop and implement policies and
procedures to ensure that controls are in place
so that all strategically sourced vehicles are
utilized unless a valid exception is justified.
2: Develop and implement procedures for
maintaining and securing records associated
with production of annual Strategic Sustainability
Performance Plan data, in accordance with the
EPA's Records Management Policy.
Specifically, assure that:
a. Fleet data reported in the Strategic
Sustainability Performance Plan are
documented and accessible, and can be
reproduced using either the current fleet
database or by maintaining copies of
historical data reports.
b. Strategic Sustainability Performance Plan
waste diversion data are documented for all
facilities that can provide it, and specify in
future Strategic Sustainability Performance
Plan reports whether the waste diversion
rates are estimates or only represent specific
facilities.
c. Findings and results associated with the
acquisitions information in the Strategic
Sustainability Performance Plan report can
be reproduced, including records of the data
and methodology used. These records
should be properly maintained, and should
be accessible for the time period required by
the EPA's Records Management Policy.
1 : Reduce participation barriers for the
Conventional Reduced Risk Pesticide Program
by seeking statutory authority from Congress to
reduce application fees for approved
Conventional Reduced Risk Pesticide
registrations.
2: Develop and implement measures for non-
agricultural uses of Conventional Reduced Risk
Pesticide products so that Office of Pesticide
Pollution's data are representative of the
Conventional Reduced Risk Pesticide Program's
entire effort.
Planned
Completion
Date
11/30/14
12/31/14
10/31/14
06/30/17
06/30/15
Reason for Delay
OAM/OEI continue to
collaborate on developing a
memorandum that reflects
all aspects of this initiative.
0AM has prepared the
strategic sourcing policy
and is currently conducting
its final review. Completion
is expected by 06/30/1 5.
0AM prepared the draft
Standard Operating
Procedure and routed it for
approval on 03/1 3/1 5. 0AM
anticipates final approval
and posting of the
Standard Operating
Procedure by 04/30/1 5.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
60
-------
Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
No Indications of Bias Found in a
Sample of Freedom of Information Act
Fee Waiver Decisions But the EPA
Could Improve its Process (14-P-0319)
Unliquidated Obligations Resulted in
Missed Opportunities to Improve
Drinking Water Infrastructure
(14-P-0318)
EPA Should Improve Oversight and
Assure the Environmental Results of
Puget Sound Cooperative Agreements
(14-P-0317)
EPA Has Made Progress in Assessing
Historical Lead Smelter Sites but Needs
to Strengthen Procedures
(14-P-0302)
Report
Date
07/16/14
07/16/14
07/15/14
09/30/14
Office
OEI
OW
Region
10
OARM
OSWER
Unimplemented Recommendation
1 : Examine and address the reasons for
variability in response times for Freedom of
Information Act fee waiver decisions and
appeals.
2: Clarify what requesters must demonstrate
under each factor to receive a fee waiver.
3: Inform the public of enhancements to the
agency's Freedom of Information Act website
and other efforts to clarify what must be
demonstrated under each factor.
1b: Reduce unliquidated obligations by quarterly
providing to the regions a summary of states
that have attended the cash flow analysis
training and compare that with states not
achieving the goals of the 2014 strategy to
identify states that may need additional
assistance.
3: Require that EPA regions, when reviewing the
capitalization grant application for states with
high unliquidated obligations balances, ensure
states have adopted the EPA's guidance on the
definition of "Ready to proceed" and use that
definition in developing the fundable list.
4: Evaluate whether the resources allocated to
overseeing Puget Sound cooperative
agreements are sufficient to effectively achieve
the Puget Sound Program's needed
environmental results.
5: Review existing grants policies to determine
whether policies need to be updated to clarify
project officer and grant specialist
responsibilities with sub-awards, as well as
recipient responsibilities for sub-award
monitoring.
3: Assess existing EPA guidance for addressing
lead contamination in soil within the Superfund
site assessment process and obtain input from
the regions to determine whether any updates
are needed and revise as appropriate.
5: Following completion of the 2012 Strategy,
create and post as summary of the results of the
EPA's efforts to address sites included in the
strategy and, as applicable, any findings and
recommendations on the EPA's website.
Planned
Completion
Date
03/31/15
09/30/16
09/30/15
04/30/15
09/30/15
09/30/16
12/31/15
Reason for Delay
Due to the increased
workload of Freedom of
Information Act staff and
staff reductions, OEI is
extending completion of
the corrective actions for
Recommendations 1 -3 for
6 months. Completion is
expected by 09/30/1 5.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
61
-------
Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
New Jersey Department of
Environmental Protection Needs to
Meet Cooperative Agreement
Objectives and Davis-Bacon Act
Requirements to fully Achieve Leaking
Underground Storage Tank Goals
(14-R-0278)
EPA Has Not Implemented Adequate
Management Procedures to Address
Potential Fraudulent Environmental
Data(14-P-0270)
Briefing Report: Review of EPA's
Process to Release Information Under
the Freedom of Information Act
(14-P-0262)
Report
Date
06/04/14
05/29/14
05/16/14
Office
Region 2
OEI
OECA
OSWER
OEI
Unimplemented Recommendation
1 : Require New Jersey Department of
Environmental Protection to establish internal
controls to ensure that modifications to the
cooperative agreement work plan are in
accordance with the requirements of 40 CFR
31 .30 and 31 .40.
3: Require New Jersey Department of
Environmental Protection to provide
documentation to demonstrate that it has
verified that all laborers and mechanics who
worked on the projects subject to the Davis-
Bacon Act requirements per programmatic
condition 5 of the cooperative agreement were
paid in accordance with Davis-Bacon
requirements.
1 : Incorporate a "Notification Process" similar to
that found in Chief Information Officer Procedure
2106 into Chief Information Officer Procedure
2105 until the revised Chief Information Officer
Policy 21 06 is reissued.
2: Include in the revised Chief Information
Officer Procedure 2106 specific due diligence
steps for laboratory fraud that provide
procedural details on communication and
coordination efforts between program and
enforcement staff, review and analysis of data
for any impacts to human health and the
environment, communication of any impact
information to data users, and amendment of
past environmental decisions impacted by
fraudulent data.
3: Provide training on the "Notification Process"
and the revised Chief Information Officer
Procedure 2106 to the EPA staff working with
laboratory data.
4: Develop guidelines outlining response steps
when fraudulent laboratory data is discovered in
ongoing criminal investigations.
5: Update the Contract Laboratory Program
Roles and Regulations Guidance Document.
6: Provide training to Contract Laboratory
Program staff on the updated Contract
Laboratory Program Roles and Regulations
Guidance Document.
2: Require that Senior Information Officials at
each region and program office certify that their
local Freedom of Information Act procedures are
consistent with the agency's final procedures by
March 31, 201 5.
Planned
Completion
Date
09/30/15
09/30/15
12/30/16
12/30/16
03/31/17
09/30/14
12/31/15
12/31/15
03/31/15
Reason for Delay
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
OECA continues to work to
complete the corrective
action. The additional time
needed is still being
determined.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
Waiting for certifications
from Senior Information
Officials.
62
-------
Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
EPA Employees Did Not Act Consistent
With Agency Policy in Assisting an EPA
Grantee (14-P-0247)
EPA Compliance With Retention
Incentive Regulations and Policies
(14-P-0245)
EPA Needs to Improve Management of
the Cross-Media Electronic Reporting
Regulation Program in Order to
Strengthen Protection of Human Health
and the Environment
(14-P-0143)
Report
Date
05/9/14
05/02/14
03/21/14
Office
ORD
OARM
OEI
Unimplemented Recommendation
1 : Develop standard operating procedures that
detail how staff are to comply with the EPA
Scientific Integrity Policy requirement to provide
timely responses to requests for information by
the media, the public and the scientific
community.
2: Pursue action to recover the unauthorized
retention incentive amounts paid to the EPA
employees who received retention incentive pay
beyond their promotion date or authorized end
date.
1 . Update written Cross-Media Electronic
Reporting Regulation Program (CROMERR)
business practices and remove references to the
Exchange Network Policy and Planning
Workgroup and Quality Information Counsel-
Exchange Network Subcommittee since they no
longer participate in the CROMERR program.
Those written practices should include:
a. EPA Procedure for Approval of State,
Tribal, or Local Government Authorized or
Delegated Program Applications for
Implementing CROMERR;
b. EPA Procedure for Implementation of
CROMERR for EPA Systems;
c. Technical Review Committee Charter; and
d. CROMERR authorized program review for
approval flowchart.
6. Create a process to regularly follow up with
applicants with approved CROMERR
applications in order to confirm that no changes
were made to the approved CROMERR
application.
Planned
Completion
Date
12/31/14
04/01/15
03/31/17
12/31/14
Reason for Delay
The Scientific Integrity
Official submitted a draft
proposal to the Office of
General Counsel in
November 2014.
No Delay - Future planned
completion date
No Delay - Future planned
completion date.
Loss of key personnel
working on CROMERR and
the extended leave of
another person on the
CROMERR team has led
to delays. Revised
expected completion date
is 6/30/1 5.
63
-------
Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
EPA's Information Systems and Data
Are at Risk Due to Insufficient Training
of Personnel with Significant
Information Security Responsibilities
(14-P-0142)
EPA Did Not Conduct Thorough
Biennial User Fee Reviews
(14-P-0129)
Report
Date
03/21/14
03/04/14
Office
OEI
OW
Unimplemented Recommendation
1 : Define key information security aspects and
duties for each security role. This includes
identifying, where appropriate, broadly similar
characteristics within each role to allow for more
precise alignment of roles to applicable training
requirements. This also includes ensuring that
existing EPA policies, procedures, and guidance
fully and consistently define all information
security roles and responsibilities currently
implemented across the organization.
2: Provide additional training options specific to
the federal information security environment and
EPA information security roles, such as the
processes and controls outlined in National
Institute of Standards and Technology Special
Publication 800-53. Training should be specific
to supporting EPA professionals in executing
and performing assigned information security
roles and responsibilities in accordance with
EPA policies and procedures. For example,
vendor training may be warranted for hands-on
information security roles, but general
orientation training may be suitable for
executives.
4: Standardize the terminology and definition of
responsibilities for key information technology
security management and oversight roles across
all EPA organizations and within the EPA
information security policy.
5: Provide a more clear delineation of which
EPA organizations should be responsible for
delivering specific elements of information
security role training, and how collectively and
cooperatively the training needs of each
significant role (including technical and
executive-level roles) are to be met.
5: Apply federal user fee policy in determining
whether to (a) charge fees for issuing federal
National Pollutant Discharge Elimination System
permits in which the EPA is the permitting
authority, or (b) request an exception from OMB
to charging fees.
Planned
Completion
Date
09/30/15
12/31/16
09/30/15
12/31/14
12/31/14
Reason for Delay
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
OW is working with OCFO
to request an exception
from a National Pollutant
Discharge Elimination
System user fee from
OMB.
64
-------
Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
EPA Needs to Improve Safeguards for
Personally Identifiable Information
(14-P-0122)
Internal Controls Needed to Control Costs
of Emergency and Rapid Response
Service Contracts, as Exemplified in
Region 6 (14-P-0109)
Report
Date
02/24/14
02/04/14
Office
OEI
Region 6
Unimplemented Recommendation
1 : Develop an implementing procedure for rules
of behavior and consequences.
2: Develop and implement updated agency
matching program procedures that:
a. Define roles and responsibilities for
communicating matching activities to the
Privacy Office and the Data Integrity Board.
b. Require a writing matching agreements
before the agency engages in a matching
program.
c. Define the agency Privacy Officer's
oversight responsibilities.
d. Convene the Data Integrity Board for
matching programs, as needed.
e. Obtain a written agreement for the current
matching program, as needed.
4: Develop and implement a process for
maintaining an accurate, up-to-date listing of
systems that contain sensitive personally
identifiable information.
5: Establish and implement a process to train all
individuals who access Personally Identifiable
Information based on their roles and
responsibilities. This process should include
training on all Personally Identifiable Information
topics as prescribed by the National Institute of
Standards and Technology.
7: Develop and implement an oversight process
to monitor that Liaison Privacy Officials and all
individuals who access Personally Identifiable
Information are trained on their responsibilities for
protecting Personally Identifiable Information. The
oversight process should include a method to
inform senior agency officials on the status of
their office's completion of training.
3: Direct Contracting Officers to require that the
contractor adjust all its billings to reflect the
application of the correct rate to team
subcontract other direct costs.
5: Require that proposals for future Emergency
and Rapid Response Services contracts include
subcontractor rates as required by the amended
Federal Acquisition Regulations.
Planned
Completion
Date
09/30/14
06/30/14
06/30/14
09/30/14
09/30/14
09/30/24
09/30/15
Reason for Delay
Corrective action is much
more complex than
anticipated and required
greater collaboration with
other offices having
responsibilities related to
privacy and security.
Expected completion date
is 9/30/1 5.
Contractor support
transition. Expected
completion date is 6/30/15.
Contractor support
transition. Expected
completion date is 6/30/15.
Corrective action is much
more complex than
anticipated and required
greater collaboration with
other offices having
responsibilities related to
privacy and security.
Expected completion date
is 9/30/1 5.
Corrective action is much
more complex than
anticipated and required
greater collaboration with
other offices having
responsibilities related to
privacy and security.
Expected completion date
is 9/30/1 5.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
65
-------
Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
Audit of EPA's Fiscal 2013 and 201 2
Consolidated Financial Statements
(14-1-0039)
EPA Needs to Update Its Pesticide and
Chemical Enforcement Penalty Policies
and Practices (13-P-0431)
The EPA Should Improve Monitoring of
Controls in the Renewable Fuel
Standard Program (13-P-0373)
The EPA Needs to Improve Timeliness
and Documentation of Workforce and
Workload Management Corrective
Actions (13-P-0366)
Controls Over EPA's Compass
Financial System Need to Be Improved
(13-P-0359)
Report
Date
12/16/13
09/26/13
09/05/13
08/30/13
08/23/13
Office
OEI
OECA
OAR
OCFO
OCFO
Unimplemented Recommendation
12: Conduct training for staff in charge of
receiving and analyzing monthly vulnerability
management reports to ensure they are
knowledgeable of the agency's remediation
process for vulnerabilities. This training should
include specific information on how to review the
provided vulnerability management report and
what actions offices must take regarding the
identified vulnerabilities.
3: Update the existing Lead-Based Paint
Disclosure Enforcement Response and Penalty
Policy to include guidance on:
a. How to evaluate ability to pay claims for
individuals, and
b. When and how to apply alternatives such
as payment plans and public service to ability
to pay cases.
4: Evaluate the Individual Ability to Pay
economic model to determine whether revisions
would improve applicability to lead paint
disclosure cases with individual violators.
5: Provide regional staff with updated training for
case development, including evaluation of ability
to pay claims.
1 : Modify existing electronic systems to track the
submission of reporting requirements to ensure
that all participants comply with applicable
Renewable Fuel Standard program regulations.
3: Track reporting submissions to determine
whether potential conflicts of interest exist from
allowing the same third party to complete
multiple reporting requirements and monitor the
potential conflicts to determine whether they
negatively impact Renewable Fuel Standard
program integrity. Based on that determination,
revise regulations as appropriate to include
specificity on whether the same third party can
conduct multiple reviews or reporting
requirements for the same producer or importer.
1 : Notify all the EPA's action officials that when
they extend planned completion dates for
corrective actions by more than 6 months they
must provide the DIG with written notification
that includes the new milestone dates.
3: Finalize the revised Quality Assurance Plan
that includes the revised service level
requirements to accurately assess service
provider performance.
Planned
Completion
Date
09/30/17
06/30/14
06/30/14
09/30/14
06/30/15
06/30/15
09/30/15
12/31/13
Reason for Delay
No Delay - Future planned
completion date.
Additional coordination
needed among staff, senior
management and external
partners. Expected
completion date 6/29/1 5.
Additional coordination
needed among staff, senior
management and external
partners. Expected
completion date 6/29/1 5.
Additional coordination
needed among staff, senior
management and external
partners. Expected
completion date 9/30/1 5.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
Contractor negotiations will
require more time to
complete. Expected
completion 01/31/16.
66
-------
Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
Improved Information Could Better
Enable EPA to Manage Electronic
Waste and Enforce Regulations
(13-P-0298)
Improved Internal Controls Needed in
the Gulf of Mexico Program Office
(13-P-0271)
Opportunities for EPA-Wide
Improvements Identified During Review
of a Regional Time and Materials
Contract (13-P-0209)
EPA Should Increase Fixed-Price
Contracting for Remedial Actions
(13-P-0208)
Report
Date
06/21/13
05/30/13
04/04/13
03/28/13
Office
OSWER
OW
OARM
OARM
OARM
and
OSWER
OARM
and
OSWER
OARM
and
OSWER
Unimplemented Recommendation
3: Evaluate the implementation of currently used
electronics certification programs as detailed in
the National Strategy. If necessary, conduct
Resource Conservation and Recovery Act
inspections (for federal regulations only) of
certified recyclers accordingly.
2: Evaluate the results of the Gulf of Mexico
Program Office's risk assessment and work with
Gulf of Mexico Program Office management to
make the necessary changes to its objectives
and measures, so the Gulf of Mexico Program
Office can accurately measure performance.
5: Ensure that 0AM conducts and documents
the results of the review prompted from this
evaluation of all remedial action contracts to:
a. Determine the best method for paying the
remedial action contractors for all subcontract
management costs.
b. Consistently apply this method for all
remedial action contracts Agency-wide.
1b: For current cost reimbursement Remedial
Action Contracts, at the end of the base period,
require written acquisition plans be prepared
and approved by the Head of the Contracting
Activity.
2: Develop performance measures for each
region for the use of fixed-price contracts and
task orders for remedial actions. The
performance measures should be implemented
in a way that holds the regions accountable
(both the Superfund program staff and
contracting staff) for decreasing the use of high
risk contracts and task orders.
3: As part of the implementation of the Contracts
2010 Strategy, provide training to both
Superfund program and contracting staff on how
and when less risky contracts and task orders
should be used in the Superfund remedial
program.
4: Determine whether staffing changes are
needed in each region to ensure that staff have
the skills to manage the increased use of fixed-
price contracts and task orders, and develop a
plan for addressing the staffing needs.
Planned
Completion
Date
07/31/14
06/30/14
10/20/14
03/31/14
09/30/14
11/30/13
09/30/14
Reason for Delay
Additional fieldwork was
needed to ensure that
current U.S. electronics
certification programs are
being implemented
transparently, consistently
and are achieving the
desired results. EPA relies
on facilities to volunteer to
be in the study and has
recently obtained
agreements for the
additional needed
observations. The date for
the release of the final
report has been revised to
June 30, 2015.
Loss of subject matter
expertise working on
corrective action has
delayed completion.
Expected completion date
TBD until expertise can be
obtained.
This corrective action is
dependent upon the
Remedial Acquisition
Framework which is not yet
completed. A revision date
for this corrective action will
be obtained shortly.
OARM has an email in the
management chain
addressing the need to
revise the completion dates
of corrective actions for all
four of these recommend-
dationstoMarch31,2016.
Once approved, it will be
sent to the DIG.
Meaningful training
cannot be provided until
the Remedial Action
Framework is finalized.
EPA did not align the date
with fmalization of the
framework.
67
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
Audit of American Recovery and
Reinvestment Act-Funded Cooperative
Agreement 2S-96099601 Awarded to
the Idaho Department of Environmental
Quality (13-R-0206)
Improvements Needed in EPA's
Smartcard Program to Ensure
Consistent Physical Access Procedures
and Cost Reasonableness (13-P-0200)
Improvements Needed in EPA Training
and Oversight for Risk Management
Program Inspections (13-P-0178)
Results and Benefits Information is
Needed to Support Impacts of EPA's
Superfund Removal Program
(13-P-0176)
Report
Date
03/28/13
03/27/13
03/21/13
03/11/13
Office
Region
10
OARM
OSWER
OSWER
Unimplemented Recommendation
3: Require Idaho Department of Environmental
Quality to ensure that current and future
contractors are covered by accident and
catastrophic loss insurance as required by
Title 40 CFR 35.6590 (b).
4: Require Idaho Department of Environmental
Quality to update its policies and procedures to
ensure that they address:
c. Accident and catastrophic loss insurance as
required by Title 40 CFR 35.6590 (b).
1 : Re-prioritize the remaining facility upgrades
by security level from highest to lowest,
complete all remaining upgrades according to
security level, and require the Security
Management Division Director to provide written
justification for upgrading Level 1 facilities.
7: Coordinate with the OECA to revise
inspection guidance to recommend minimum
inspection scope for the various types of
facilities covered under the program and provide
more detailed examples of minimum reporting.
8: Coordinate with the OECA to develop and
implement an inspection monitoring and
oversight program to better manage and assess
the quality of program inspections, reports,
supervisory oversight, and compliance with
inspection guidance
2: Implement system controls to:
a. Ensure required Comprehensive
Environmental Response, Compensation,
and Liability Information System data are
entered and completed.
b. Synchronize data between the Pollution
Reports and Comprehensive Environmental
Response, Compensation, and Liability
Information System.
Planned
Completion
Date
12/31/13
12/31/13
06/30/14
07/31/14
09/30/14
09/30/13
Reason for Delay
R10's Legal Counsel is
reviewing this matter to
determine if the type of
insurance that the
contractor currently has
meets the intent of Subpart
"0".
The agency's
implementation schedule
has changed. OARM
anticipates initiating the
remaining Physical Access
Control System upgrades
as follows: Facility Security
Level 4 facilities by Q2 FY
201 5; Facility Security
Level 3 facilities by Q3 FY
201 5; and Facility Security
Level 2 facilities by Q4 FY
2016.
These corrective actions
have been overtaken by
actions and deadlines
associated with
implementation of
Executive Order 13650,
Improving Chemical
Facility Safety and
Security, which lays out a
comprehensive set of
actions to advance
chemical facility safety and
security, including federal
coordination on
inspections.
OSWER is working with
the regions and its partner
offices to address
proposed system changes
and enhancements to the
Superfund Enterprise
Management System.
OSWER is working closely
with the regions to conduct
quality assurance on the
removal data being
migrated from
Comprehensive
Environmental Response,
Compensation, and
Liability Information
System. Completion
expected by 03/31/1 6.
68
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
EPA Is Not Recovering All Its Costs of
the Lead-Based Paint Fees Program
(13-P-0163)
EPA Needs to Improve Air Emissions
Data for the Oil and Natural Gas
Production Sector (13-P-0161)
EPA Could Improve Contingency for Oil
and Hazardous Substance Response
(13-P-0152)
Audit of EPA Fiscal 201 2 and 2011
Financial Statements (13-1-0054)
Review of Hotline Complaint
Concerning Cost and Benefit Estimates
for EPA's Lead-Based Paint Rule
(12-P-0600)
EPA Inaction in Identifying Hazardous
Waste Pharmaceuticals May Result in
Unsafe Disposal (12-P-0508)
Report
Date
02/20/13
02/20/13
02/15/13
11/15/12
07/25/12
04/19/12
Office
OCSPP
OAR
OSWER
OCFO
OCSPP
OSWER
Unimplemented Recommendation
3: Update the March 20, 2009, fees rule to
reflect the amount of fees necessary for the
program to recover the costs of implementing
and enforcing the program.
2: Prioritize and update existing oil and gas
production emission factors that are in greatest
need of improvement and develop emission
factors for key oil and gas production processes
that do not currently have emission factors.
2: Require regions to keep critical planning
information up to date using the most effective
method available and avoid unnecessary
duplication.
4: Assess the resources, including On-Scene
Coordinators, necessary to develop and
maintain contingency plans. Use the results of
this analysis to develop a workforce plan to
distribute contingency planning resources.
6: Update EPA's policy for recognizing year-end
accruals to require reconciliations of accruals
and accrual reversals.
1 : Reexamine the estimated costs and benefits
of the 2008 Lead Rule and the 2010 amendment
to determine whether the rule should be
modified, streamlined, expanded, or repealed.
CA2: After OMB clearance on the Information
Collection Request is received, OCSPP will
conduct information gathering and analysis.
CAS: OCSPP will draft the information and
analysis submitted to OMB for interagency
review as part of the Action Development
Process.
CA4: OCSPP will publish the work practice
and cost information as part of the proposed
rule.
3: Develop a nationally consistent outreach and
compliance assistance plan to help states
address challenges that health care facilities,
and others as needed, have in complying with
Resource Conservation and Recovery Act
regulations for managing hazardous waste
Pharmaceuticals.
Planned
Completion
Date
01/31/17
09/30/19
09/30/16
09/30/13
03/31/13
09/30/14
03/31/15
09/30/15
08/31/13
Reason for Delay
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
Due to staff reductions
caused by staff departures,
hiring restrictions and other
initiatives, OSWER is
pursuing re-assessing the
recommendation in 1 8
months (by 08/31/1 5) to
determine if the corrective
action is still warranted.
Decision to expand the
scope of the update and
resource constraints;
expected completion date
12/31/15.
As of 03/30/1 5, the
Information Collection
Request is still awaiting
OMB approval. EPA will
not issue the proposed
Public & Commercial
Buildings rule unless it is
determined that
renovations to public and
commercial buildings
create hazards.
OSWER is developing a
proposed rule to facilitate
proper management of
hazardous waste
Pharmaceuticals in the
health care industry.
OSWER discovered
additional complexities in
both the regulated universe
and in the economic
analysis, which delayed the
rulemaking proposal from
August 201 3.
69
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
Controls Over State Underground
Storage Tank Inspection Programs in
EPA Regions Generally Effective
(12-P-0289)
EPA Needs to Further Improve How It
Manages Its Oil Pollution Prevention
Program (12-P-0253)
Report
Date
02/15/12
02/06/12
Office
OSWER
OSWER
Unimplemented Recommendation
1 : Require the EPA and states to enter into
memoranda of agreement that reflect program
changes from the 2005 Energy Policy Act and
address oversight of municipalities conducting
inspections.
1 : Improve oversight of facilities regulated by the
EPA's oil pollution prevention program by:
a. Developing procedures for updating and
issuing new guidance to ensure the
regulated community has access to the
most current guidance.
b. Implementing a risk-based strategy toward
inspections that identifies unknown Spill
Prevention, Control, and Countermeasure
and Facility Response Plan facilities, and
directs inspection resources toward
facilities where the potential for spills poses
the greatest risks to human health and the
environment.
c. Consistently interpreting regulations and
the EPA's authority to enforce regulations.
d. Producing a biennial public assessment of
the quality and consistency of Spill
Prevention, Control, and Countermeasure
Plans and Facility Response Plans based
on inspected facilities.
CA 1 -2 . A summary of findings will be
developed by October, 2013. These
findings will help to identify areas where
additional guidance and outreach are
needed to improve the quality and
consistency of Spill Prevention, Control,
and Countermeasure Plans.
CA 1-3. The model developed for the Spill
Prevention, Control, and Countermeasure
program will then be used to develop a
review protocol for Facility Response Plans
by September, 2013, to examine Facility
Response Plan inspections conducted
during the FY 2013 inspection cycle.
CA 1 -4. A summary of findings will be
developed by October 2014. These
findings will help to identify areas where
additional guidance and external outreach
are needed to improve the quality and
consistency of Facility Response Plans.
Planned
Completion
Date
08/1/13
Completed
Completed
Completed
10/31/13
09/30/13
10/31/14
Reason for Delay
OMB initiated its review of
the final Underground
Storage Tank regulations
on 09/25/1 4 with a
projected 90-day review
period coming to close at
the end of December. As a
result, OSWER amended
its estimated publication
date to 04/30/1 5 to account
for this important process
and review step.
Reduced extramural
resources and available
personnel, program
implementation priorities
including inspections, and
new priority concerns for oil
spill response associated
with increased oil
transportation have
delayed efforts on this
milestone for at least a
year or more. In addition,
the recent Water
Resources Reform and
Development Act places
priority responsibilities on
the Spill Prevention,
Control, and
Countermeasure program
for the next 2 years.
Consequently, corrective
action cannot begin before
06/01/17.
70
-------
Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
Agreed-Upon Procedures Applied to
EPA Grants Awarded to Summit Lake
Paiute Tribe, Sparks, Nevada
(12-2-0072)
Region 9 Technical and Computer
Room Security Vulnerabilities Increase
Risk to EPA's Network (1 1 -P-0725)
EPA Should Update Its Fees Rule to
Recover More Motor Vehicle and
Engine Compliance Program Costs
(11-P-0701)
EPA Needs Workload Data to Better
Justify Future Workforce Levels
(11-P-0630)
An Overall Strategy Can Improve
Communication Efforts at Asbestos
Superfund Site in Libby, Montana
(11-P-0430)
Office of Research and Development
Needs to Improve its Method of
Measuring Administrative Savings
(11-P-0333)
Report
Date
11/10/11
09/30/11
09/23/11
09/14/11
08/03/11
07/14/11
Office
Region 9
Region 9
OAR
OCFO
Region 8
ORD
Unimplemented Recommendation
2: Require the tribe to implement internal
controls to ensure that:
a. Employees document all hours worked in
accordance with 2 CFR Part 225
requirements.
b. The chairman's consent to use his
signature stamp for timesheet approval is
independently verified.
c. Leave allocation complies with 2 CFR Part
225 requirements.
1 , 6, 8, and 10: These recommendations were
made to the senior information official, Region 9.
Detailed information for this report is not being
included due to the sensitive nature of the
report's security findings.
1 : Update the 2004 fees rule to increase the
amount of the Motor Vehicle and Engine
Compliance Program costs it can recover.
1 : Conduct a pilot project requiring EPA
organizations to collect and analyze workload
data on key project activities.
2: Use information learned from the pilot and the
ongoing contracted workload study to issue guidar
to the EPA's program offices on:
a. How to collect and analyze workload data.
b. The benefits of workload analysis.
c. How this information should be used to
prepare budget requests.
2: Revise the Libby community engagement
plan to serve as the overall communication
strategy by including: a) key messages that
address specific public concerns and site
activities; b) timeliness for community
involvement activities and outreach projects;
c) measures for successful communications;
and d) mechanisms for identifying community
concerns and collecting feedback.
1 : Develop and establish a more timely and
accurate system to measure its effective use of
resources and to allow ORD to better manage
its initiatives to reduce administrative costs.
Planned
Completion
Date
07/31/12
03/31/14
12/31/17
09/30/12
09/30/12
12/31/15
12/31/15
Reason for Delay
Management Decision is
currently in appeal by audit
recipient. DDO Final
Decision on Appeal signed
and sent electronically to
Tribe. EPA is currently
awaiting decision from the
tribe to decide if they want
to repeal their appeal and
ask for debt forgiveness.
Due to the sensitive nature
of this report, this section is
not included.
No Delay - Future planned
completion date.
Delay in issuing Resource
Management Directive
System 2520,
Administrative Control of
Appropriated Funds;
expected issuance
06/30/15.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
71
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
Agency-Wide Application of Region 7
NPDES Program Process
Improvements Could Increase EPA
Efficiency (11-P-031 5)
EPA Promoted the Use of Coal Ash
Products With Incomplete Risk
Information (11-P-01 73)
EPA Needs Better Agency-Wide
Controls Over Staff Resources
(11-P-0136)
EPA Needs to Strengthen Internal
Controls for Determining Workforce
Levels (11-P-0031)
Report
Date
07/06/11
03/23/11
02/22/11
12/20/10
Office
OECA
OSWER
OARM
OSWER
Unimplemented Recommendation
1 : We recommend that the Deputy Administrator
direct OW and OECA to identify Region 7
process improvements that can be applied
elsewhere, considering the cost and benefit of
implementation. These actions include:
a. Earlier resolution of technical issues and
communication.
b. Combining permitting and enforcement
oversight reviews of the states.
c. Implementing coordinated and integrated
strategic planning nationwide for the
National Pollutant Discharge Elimination
System program, including consideration of
the new approaches under the Clean
Water Act of 1 972 action plan.
d. Fully implementing burden reduction
initiatives identified during the event.
1 : Define and implement risk evaluation
practices to determine the safety of the coal
combustion residual beneficial uses the EPA
promotes.
1 : Establish an agency-wide workforce program
that includes controls to ensure regular reviews
of positions for efficiency, effectiveness, and
mission accomplishment.
2-1 : Amend the Resource Management
Directive System 2520 and the annual planning
and budget memoranda to require using
workload analysis to help determine
employment levels needed to accomplish
agency goals.
Planned
Completion
Date
12/31/11
03/30/14
09/30/12
12/20/10
Reason for Delay
To address d, OECA
published the proposed
National Pollutant
Discharge Elimination
System Electronic
Reporting Rule in the
Federal Register on
07/03/1 3. A 90-day public
comment period began
with the publication of the
rule. An extension of
additional time for the
comment period was
granted. Should there be
significant comments on
the rule, the agency is
committed to issuing a
supplemental notice, which
will require additional OMB
review and a subsequent
public comment period.
Final rule expected by
05/31/15.
OSWER expects to
complete the development
of the conceptual model for
evaluating risks from
encapsulated uses of coal
combustion residuals by
Spring 201 5.
Once Human Resources
Line of Business is fully
operational, the agency
can work to issue and
implement the final policy.
The draft position
management policy has
been reviewed by the
Office of General Counsel
and was submitted to the
Office of Human
Resources in late
February. The policy has
not been finalized due to
more rounds of internal
review.
Delay in issuing Resource
Management Directive
System 2520; expected
issuance 06/30/1 5.
72
-------
Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
Audit of EPA's Fiscal 2010 and 2009
Consolidated Financial Statements
(11-1-0015)
ECHO Data Quality Audit - Phase II
Results: EPA Could Achieve Data
Quality Rate With Additional
Improvements (10-P-0230)
EPA Should Revised Outdated or
Inconsistent EPA-State Clean Water
Act Memoranda of Agreement
(10-P-0224)
EPA Needs a Coordinated Plan to
Oversee its Toxic Substances Control Act
Responsibilities (10-P-0066)
Lack of Final Guidance on Vapor
Intrusion Impedes Efforts to Address
Indoor Air Risks (10-P-0042)
Report
Date
11/15/10
09/22/10
09/14/10
02/17/10
12/14/09
Office
OARM
OECA
OW
OECA
OCSPP
OSWER
Unimplemented Recommendation
9: Adequately address and resolve the issue
and determine why personal property items are
missing.
5: Complete new rules that require states to
report minor facility data.
2-2: Develop a systematic approach to identify
which states have outdated or inconsistent
memoranda of agreement; renegotiate and
update those memoranda of agreement using
the memorandum of agreement template; and
secure the active involvement and final,
documented concurrence of headquarters to
ensure national consistency.
24: Establish criteria and procedures outlining what
chemicals or classes of chemicals will undergo risk
assessments for low-level and cumulative exposure.
Periodically update and revise risk assessment tools
and models with latest research and technology
developments.
2-5: Develop a more detailed Toxic Substances
Control Act confidential business information
classification guide that provides criteria for
approving confidential business information
coverage and establishes a time limit for all
confidential business information requests to allow
for eventual public access to health and safety data
for chemicals.
2: Issue final vapor intrusion guidance(s) that
incorporates information on:
a. Updated toxicity values.
b. A recommendation(s) to use multiple lines
of evidence in evaluating and making
decisions about risks from vapor intrusion.
c. How risks from petroleum hydrocarbon
vapors should be addressed.
d. How the guidance applies to Superfund
Five-Year Reviews.
e. When or whether preemptive mitigation is
appropriate.
f. Operations and maintenance, the
termination of the systems, and when
institutional controls and deed restrictions
are appropriate.
3: Train the EPA and state staff and managers
and other parties on the newly updated, revised
and finalized guidance document(s).
Planned
Completion
Date
05/30/12
09/30/12
09/30/17
02/28/13
01/31/12
11/30/12
05/31/13
Reason for Delay
The new property system
being developed will be
rolled out in conjunction
with the OCFO Compass
7.2 upgrades scheduled for
August 201 5. The
estimated completion date
will be October 30, 2015.
Delays in finalizing
National Pollutant
Discharge Elimination
System electronic reporting
rule. The rule is expected
to be published May 30,
2015.
No Delay - Future planned
completion date.
Delays in issuance of
agencywide guidance on
conducting cumulative risk
assessments and in
publication of data from the
U.S. Consumer Product
Safety Commission and
the U.S. Food and Drug
Administration on
Phthalates Alternatives.
OMB initiated its review on
09/25/14. The completion
date will depend on how
quickly the OMB-led inter
agency review can be
completed.
73
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
Audit of EPA's Fiscal 2009 and 2008
(Restated) Consolidated Financial
Statements (10-1 -0029)
EPA Oversight and Policy for High
Priority Violations of Clean Air Act Need
Improvement (10-P-0007)
Report
Date
11/16/09
10/14/09
Office
OCFO
OECA
Unimplemented Recommendation
27: Ensure that all new financial management
systems (including the Integrated Financial
Management System replacement system) and
those undergoing upgrades include a system
requirement that the fielded system include an
automated control to enforce separation of duties.
CA27: OCFO's Office of Technology Solutions
will modify Compass users profiles to create
specific security roles to allow Compass
Security Officers to better manage user access.
CA32: The Office of Technology Solutions will
enhance the Access Request Form application
with additional controls and automatic logic to
check for approved waivers on file to prevent
users from submitting security options that
violate the separation of duties policy.
1 : Direct the EPA regions to comply with the
High Priority Violations policy, and monitor and
report on regions' compliance.
3: Implement proper management controls over
High Priority Violations by (1) following the
watch list standard operating procedures,
including generating trend reports and
conducting national annual reviews; and
(2) ensuring that Air Facility System data is
accurate by documenting data inaccuracies and
their disposition in regular meeting notes.
Planned
Completion
Date
12/31/15
12/31/15
10/01/12
10/01/12
Reason for Delay
Difficulty coordinating
schedules, with limited
resources has delayed the
expected completion date.
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
A workgroup was
established to develop an
alternative approach to
identifying and tracking the
most important violations,
including High Priority
Violations. As part of the
effort to develop a new
High Priority Violations
/substantial noncompliance
tracking tool, the
workgroup will develop a
new High Priority Violations
Identification Report. The
workgroup is scheduled to
launch the High Priority
Violations /substantial
noncompliance tool and
High Priority Violations
Identification Report in
December 20 15.
74
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
Review of Hotline Complaint on Employee
Granted Full-Time Work-at-Home Privilege
(10-P-0002)
Making Better Use of Stringfellow
Superfund Special Accounts
(08-P-0196)
EPA Needs to Plan and Complete a
Toxicity Assessment for the Libby
Asbestos Cleanup (2007-P-00002)
EPA Can Better Manage Superfund
Resources (2006-P-0001 3)
Limited Knowledge of the Universe of
Regulated Entities Impedes EPA's
Ability to Demonstrate Changes in
Regulatory Compliance
(2005-P-00024)
Report
Date
10/07/09
07/09/08
12/05/06
02/28/06
09/19/05
Office
OARM
OARM
OARM
Region 9
OSWER
OCFO
OECA
Unimplemented Recommendation
1 : Assign responsibility for authorizing all
non-OARM geographically separate duty station
changes to the Assistant Administrator for
OARM.
2a: Establish and implement agency policy for
all of the EPA's employees, clearly articulating
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.
2b: Identify and review all existing arrangements
of full-time work-at-duty-station separate from
the position of record, including the situation that
was the subject of this review, and bring each of
these arrangements into compliance with
implemented EPA policy.
2: Reclassify or transfer to the Trust Fund, as
appropriate, up to $27.8 million (plus any earned
interest less oversight costs) of the Stringfellow
special accounts in annual reviews, and at other
milestones including the end of FY 2010, when
the record of decision is signed and the final
settlement is achieved.
1-2: Complete the National Health and
Environmental Effects Research Lab animal toxicity
studies.
2-3: Define costs in a manner that supports
management decision making and improve their
accounting of such resources to maximize
achieving program goals.
2-4: Develop an objective of having the most up-
to-date and reliable data on all entities that fall
under its regulatory responsibility. OECA should
adopt the goals of requiring States to track,
record, and report data for entities over which
States have regulatory responsibility. To achieve
this goal, OECA should develop a multi-State,
multi-program pilot program of collecting data
that States track, record, verify, and report.
Planned
Completion
Date
06/20/11
06/20/11
06/30/11
12/31/12
09/30/15
10/31/11
09/30/12
Reason for Delay
The American Federation
of Government Employees
and National Treasury
Employees Union insisted
that their telework
agreements be part of their
new Master Collective
Bargaining Agreements.
Negotiations are currently
ongoing.
In 201 2, a new area of
groundwater contamination
was identified that is
commingling and will
directly impact the cleanup
of the Stringfellow
contamination. Due to the
additional investigations,
the anticipated completion
date is 12/31/1 5.
No Delay - Future planned
completion date.
Agency delayed in issuing
Resource Management
Directive System 2520.
Delays in finalizing National
Pollutant Discharge
Elimination System
electronic reporting rule;
expected to be published
by 05/30/1 5.
75
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
EPA and States Not Making Sufficient
Progress in Reducing Ozone Precursor
Emissions in Some Major Metropolitan
Areas (2004-P-00033/1 3-1 -0434)
State Enforcement of Clean Water Act
Dischargers Can Be More Effective
(2001-P-00013)
Report
Date
09/29/04
08/14/01
Office
OAR
OECA
Unimplemented Recommendation
3-1 : Develop oversight procedures and guidance
that will expedite development, approval, and
implementation rate of progress plans and
related emission controls.
3-3: 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
emissions 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.
3-1 : Make modernizing the Permit Compliance
System a high priority. Further, ensure that future
systems:
• Require electronic submission and evaluation
of self-monitoring reports for all dischargers,
including minor facilities and storm water.
• Track storm water permits, inspections,
compliance rates, and enforcement actions.
3-2: Accelerate the development of the Interim Data
Exchange Format for the Permit Compliance
System. Also, before proceeding further into design
and development, work with the Office of Water to
ensure there is an up-to-date policy statement for
water system criteria.
Planned
Completion
Date
12/31/15
12/31/15
09/30/12
09/30/12
Reason for Delay
No Delay - Future planned
completion date.
No Delay - Future planned
completion date.
Delays in finalizing the
National Pollutant
Discharge Elimination
System electronic reporting
rule; expected to be
published by 05/30/1 5.
Applies to both
recommendations.
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
CSB Reports With Unimplemented Recommendations
Report Title/No.
U.S Chemical Safety and
Hazard Investigation Board
Needs to Complete More
Timely Investigations
(13-P-0337)
Audit Follow-Up Process
Needed for the U.S.
Chemical Safety and Hazard
Investigation Board
(13-P-0128)
Report
Date
07/30/13
02/01/13
Unimplemented Recommendation
1 . Develop and implement performance
indicators related to its first strategic
performance goal and objective to complete
timely investigations. Indicators should track and
measure the efficiency of key phases of the
investigation process and clarify the definition of
a "timely" completed investigation. Also, address
the indicators in the investigation protocol policy.
2. Revise and publish an annual action plan to
comply with GPRA 2010 and update related
individual performance plans to ensure that
performance indicators are addressed and
investigative staff are held accountable for
performing key phases in the investigation
process.
3. Review investigations open for more than
3 years and develop a plan to close out those
investigations.
7. Implement and update the records
management policy to ensure that the
classification of electronic investigation files
agrees with the investigation protocol policy and
staffs perform internal reviews of records as
required by the policy.
8. Update the investigation protocol policy for all
current investigation procedures to include
scoping documents and recommendation briefs.
Provide formal training to the investigative staff
on changes and updates to the investigative
process.
1 . Develop and implement a follow-up system as
required by OMB Circulars A-50 and A-123 that
include establishing a policy that identifies an
audit follow-up official, roles and responsibilities,
required documentation, and reporting
requirements, to allow for prompt resolution of
recommendations and implementation of
agreed-to corrective actions.
Planned
Completion
Date
12/31/13
12/31/13
12/31/13
12/31/13
12/31/13
04/30/13
Reason for Delay
Other work priorities have delayed the completion
of this recommendation.
CSB developed an annual action plan with specific
annual and quarterly milestones for investigations,
and these goals are being incorporated into
individual performance standards. The CSB
believes this recommendation should now be
closed.
CSB only has only two cases older than 3 years old
in its current dockets. In both instances, final
reports have been drafted and are in review. CSB
believes this recommendation is satisfied.
The CSB updated its Records Management policy
(Board Order 19) on June 30, 2014. Due to
uncertainty about obtaining Board approval for
changes to Board Orders, the guidance was
drafted as a Management Directive and has been
forwarded to the Office of General Counsel for
review.
This project was delayed by the retirement of the
Senior investigator who lead the project, and
departure of other members of the protocol team. A
new team was formed in August 2014. The
guidance will be drafted and issued as a
Management Directive.
Other work priorities have delayed the completion
of this recommendation. Comments currently
under review.
77
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Report Title/No.
U.S. Chemical Safety and
Hazard Board Should
Improve Its
Recommendations Process
to Further Its Goal of
Chemical Accident
Prevention (12-P-0724)
U.S. Chemical Safety and
Hazard Investigation Board
Did Not Take Effective
Corrective Actions on Prior
Audit Recommendations
(11-P-0115)
Report
Date
08/22/12
02/15/11
Unimplemented Recommendation
1 . Update board orders to ensure that CSB
achieve its mission of chemical accident
prevention through improved recommendations
processes, to include:
c. Board Order 040, Investigation Protocol, to
clearly outline roles and responsibilities of
the Office of Recommendations and Office
of Investigations with respect to the
recommendations process, including a
requirement that Office of
Recommendations staff participate in
accident investigations, and identification
of the office responsible for identifying
potential recommendation recipients.
1 . Develop and implement a management
control plan that documents and addresses the
five internal control standards in accordance
with OMB Circular A-1 23 and GAO's Standards
for Internal Controls in the Federal Government.
The plan should include an effective monitoring
system to track corrective actions to address
and implement audit recommendations. The
plan is to include:
a. A database to track all prior audit
recommendations, planned milestone
completion dates, and corrective actions
taken.
b. Procedures for conducting periodic internal
control reviews and properly documenting
those reviews, including verifying and
ensuring that audit recommendations are
resolved promptly.
2. Develop and publish a regulation requiring
persons to report chemical accidents, as
required by the Clean Air Act.
3. Follow up with Congress on the CSB request
for clarification of its statutory mandate. Upon
receipt of the response, develop a plan to
describe and address the investigative gap,
address prior audit recommendations and
request the necessary resources to meet CSB's
statutory mandate.
5. Develop and implement a system for periodic
reviews of Board Orders to ensure they remain
updated (i.e., effective date of the policy and
scheduled review date) and include the
requirement for such a system in the
management control plan.
Planned
Completion
Date
09/30/13
02/28/11
09/30/11
04/30/11
02/28/11
Reason for Delay
The Senior Investigator assigned to lead the
investigation protocol update retired during
FY 2014, which delayed this project. In addition,
the CSB's Office of Recommendations underwent
staffing changes and now has a new Deputy
Managing Director for Recommendations.
Other work priorities have delayed the completion
of this recommendation.
All Board Orders have been reviewed and updated
as needed. The Office of Administration has been
assigned the responsibility to periodically review
CSB Board Orders as needed. The CSB believes
with these actions, this recommendation should be
closed.
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Appendix 4—Peer Reviews Conducted
Audits/Evaluations
The Social Security Administration OIG is conducting an external peer review of the EPA OIG
audit organization (which includes the EPA OIG's Office of Audit and Office of Program
Evaluation) covering the period ending September 30, 2014. The entrance conference was held
on October 27, 2014, and field work was in process as of the end of this semiannual reporting
period. The review is being conducted in accordance with guidelines established by the Council
of the Inspectors General on Integrity and Efficiency. The most recent prior external peer review
of the EPA OIG audit organization had been conducted by the U.S. Department of Health and
Human Services OIG. That prior report, issued May 9, 2012, contained no deficiencies, and the
EPA OIG received a rating of pass.
The EPA OIG is conducting an external peer review of the system of quality control for the audit
organization of the U.S. Department of Education OIG. Our review covers the period April 1,
2012, through March 31, 2015. This review is being conducted in accordance with Government
Auditing Standards and guidelines established by the Council of the Inspectors General on
Integrity and Efficiency. The entrance conference with the U.S. Department of Education OIG was
held on March 11, 2015, and field work is currently in process.
Investigations
The Federal Deposit Insurance Corporation OIG completed its mandated Council of the
Inspectors General on Integrity and Efficiency quality assurance review of the EPA OIG Office of
Investigations and issued its report on December 2, 2014. The Federal Deposit Insurance
Corporation inspected headquarters and the Washington, Atlanta, Research Triangle Park,
Seattle and San Francisco Field Offices. The Federal Deposit Insurance Corporation identified no
deficiencies and found internal safeguards and management procedures compliant with quality
standards. No recommendations were made.
In November 2014, an EPA OIG inspection team began performing a quality assurance review of
the Department of Education OIG Investigation Services office per the Council of the Inspectors
General on Integrity and Efficiency. The quality assurance review team reviewed all policy and
procedure records, training and education certifications, case files, digital forensics records and
practices, and other pertinent records that aided in the management assessment process. In
February 2015 the team conducted onsite reviews at various Department of Education locations.
The inspection was completed in March 2015 and the draft report is forthcoming.
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Semiannual Report to Congress
October 1, 2014—March 31, 2015
Appendix 5—OIG Mailing Addresses and Telephone Numbers
Headquarters
U.S. Environmental Protection Agency
Office of Inspector General
1200 Pennsylvania Ave., NW (2410T)
Washington, DC 20460
(202) 566-0847
Atlanta
U.S. Environmental Protection Agency
Office of Inspector General
61 Forsyth Street, SW
Atlanta, GA 30303
Audit/Evaluation: (404) 562-9830
Investigations: (404) 562-9857
Boston
U.S. Environmental Protection Agency
Office of Inspector General
5 Post Office Square, Suite 100 (OIG15-1)
Boston, MA 02109-3912
Audit/Evaluation: (617) 918-1470
Investigations: (617) 918-1466
Chicago
U.S. Environmental Protection Agency
Office of Inspector General
77 West Jackson Boulevard
13th Floor (IA-13J)
Chicago, IL 60604
Audit/Evaluation: (312) 353-2486
Investigations: (312) 353-2507
Cincinnati
U.S. Environmental Protection Agency
Office of Inspector General
26 West Martin Luther King Drive
Cincinnati, OH 45268-7001
Audit/Evaluation: (513) 487-2363
Investigations: (513) 487-2364
Dallas
U.S. Environmental Protection Agency
Office of Inspector General (6OIG)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Audit/Evaluation: (214) 665-6621
Investigations: (214) 665-2249
Offices
Denver
U.S. Environmental Protection Agency
Office of Inspector General
1595 Wynkoop Street, 4th Floor
Denver, CO 80202
Audit/Evaluation: (303) 312-6969
Investigations: (303) 312-6868
Kansas City
U.S. Environmental Protection Agency
Office of Inspector General
11201 Renner Boulevard
Lenexa, KS66219
Audit/Evaluation: (913) 551-7878
Investigations: (312) 353-2507
New York
U.S. Environmental Protection Agency
Office of Inspector General
290 Broadway, Room 1520
New York, NY 10007
Audit/Evaluation: (212) 637-3049
Investigations: (212) 637-3041
Philadelphia
U.S. Environmental Protection Agency
Office of Inspector General
1650 Arch Street, 3rd Floor
Philadelphia, PA 19103-2029
Audit/Evaluation: (215) 814-5800
Investigations: (215) 814-2359
Research Triangle Park
U.S. Environmental Protection Agency
Office of Inspector General
Mail Drop N283-01
Research Triangle Park, NC 27711
Audit/Evaluation: (919) 541-2204
Investigations: (919) 541-1027
San Francisco
U.S. Environmental Protection Agency
Office of Inspector General
75 Hawthorne Street (IGA-1)
7th Floor
San Francisco, CA 94105
Audit/Evaluation: (415) 947-4521
Investigations: (415) 947-8711
Seattle
U.S. Environmental Protection Agency
Office of Inspector General
Mail Code OIG-173
1200 Sixth Avenue, Suite 900
Seattle, WA 98101
Audit/Evaluation: (206) 553-6906
Investigations: (206) 553-1273
Washington
U.S. Environmental Protection Agency
Office of Inspector General
Potomac Yard
2733 Crystal Drive
Arlington, VA 22202
Investigations: (703) 347-8740
Winchester
U.S. Environmental Protection Agency
Office of Inspector General
200 S. Jefferson Street, Room 314
P.O. Box 497
Winchester, TN 37398
Investigations: (423) 240-7735
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