£
<
33
O
\
&
O
¦z
LLi
CD
% ^
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Follow-Up Report:
EPA Improves Management
of Its Radiation
Monitoring System
Report No. 14-P-0321
July 22, 2014
Scan this mobile
code to learn more
about the EPA OIG.

-------
This is one of the U.S. Environmental Protection Agency Office of Inspector General's
products associated with issues related to the EPA's radiation monitoring system. For details
on related reports, go to:
http://www.epa.gov/oig/reports/2012/20120419-12-P-Q417.pdf
http://www.epa.gOv/oig/reports/2009/20090127-09-P-0087 glance.pdf
http://www.epa.gOv/oig/reports/2006/20060426-2006-P-00022 glance.pdf
Report Contributors:
Eric Lewis
Dwayne Crawford
Christine Baughman
Andre von Hoyer II
Rodney Rice
Abbreviations
EPA
U.S. Environmental Protection Agency
MATS
Management Audit Tracking System
NAREL
National Analytical Radiation Environmental Laboratory
OAR
Office of Air and Radiation
OARM
Office of Administration and Resources Management
OIG
Office of Inspector General
RadNet
Radiation monitoring system
Cover photo: A stationary air monitor located in Montgomery, Alabama. (EPA OIG photo)
Hotline

To report fraud, waste or abuse, contact us
through one of the following methods:
email:
OIG Hotline(a)eoa.oov
phone:
1-888-546-8740
fax:
1-202-566-2599
online:
http://www.epa.qov/oiq/hotline.htm
write:
EPA Inspector General Hotline

1200 Pennsylvania Avenue, NW

Mailcode 2431T

Washington, DC 20460
Suggestions for Audits or Evaluations
To make suggestions for audits or evaluations,
contact us through one of the following methods:
email:
OIG WEBCOMMENTS®eoa.oov
phone:
1-202-566-2391
fax:
1-202-566-2599
online:
http://www.epa.qov/oiq/contact.html#Full Info
write:
EPA Inspector General

1200 Pennsylvania Avenue, NW

Mailcode 241OT

Washington, DC 20460

-------
^EDSX
* A \
1®|
VPR0^°
U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
14-P-0321
July 22, 2014
Why We Did This Review
We performed this follow-up
review to assess actions taken by
the U.S. Environmental Protection
Agency (EPA) to address the
recommendations in the Office of
Inspector General (OIG) Report
No. 12-P-0417, Weaknesses in
EPA's Management of the
Radiation Network System
Demand Attention, issued April 19,
2012. Our work focused on
actions that the EPA said were
completed as of January 10, 2014.
Specifically, the EPA reported that
it had completed seven of the
eight OIG recommendations from
our 2012 report.
The EPA's nationwide radiation
monitoring system (RadNet) is
designed to measure ambient
levels of radiation in the
environment and large-scale
atmospheric releases of radiation.
The RadNet includes, among
other things, a network of
stationary air monitors that send
near-real-time measurements of
radiation to an EPA national
laboratory.
This report addresses the
following EPA goal or
cross-agency strategy:
• Addressing climate change
and improving air quality.
Follow-Up Report: EPA Improves Management
of Its Radiation Monitoring System
What We Found
Responsible EPA offices completed corrective
actions on all seven recommendations we
reviewed. As a result of the completed corrective
actions to date, the stationary air-monitoring
network increased in both coverage and
effectiveness.
RadNet improvements
have increased the
EPA's ability to assess
radioactive threats to
the public and the
environment.
Through its actions, the EPA increased the number of air monitors installed
from 124 to 132, and the agency has eight additional monitors available for
installation. Based on recent weekly status reports, an average of
92.9 percent of installed monitors are operating. This is an improvement from
the 80 percent of installed monitors operating in March 2011.
As of the date we started our review, not all of the corrective actions
completed by the EPA were recorded in its official system for tracking
corrective actions. However, as of April 22, 2014, the EPA completed all
required actions and properly entered the data into its official tracking system.
We were told that the completion of corrective actions for the remaining
recommendation (recommendation 8), involving the tracking of the installation
of RadNet monitors, is scheduled for September 2014.
EPA officials reviewed a draft of this report and informed the OIG that they
had no issues with the findings and thus no comments.
For further information,
contact our public affairs office
at (202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2014/
20140722-14-P-0321.pdf

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
July 22, 2014
MEMORANDUM
SUBJECT: Follow-Up Report: EPA Improves Management of Its Radiation Monitoring System
Report No. 14-P-0321
This is our report on the subject review conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems
the OIG has identified and corrective actions taken by the EPA. This report represents the opinion of the
OIG and does not necessarily represent the final EPA position. However, EPA officials reviewed a draft
of this report and informed the OIG that they had no issues with the findings and thus no comments.
Because this report contains no recommendations, you are not required to respond to this report and it
will be closed upon issuance. However, if you submit a response, it will be posted on the OIG's public
website, along with our memorandum commenting on your response. Your response should be provided
as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the
Rehabilitation Act of 1973, as amended. The final response should not contain data that you do not want
to be released to the public; if your response contains such data, you should identify the data for
redaction or removal along with corresponding justification.
FROM: Arthur A. Elkins Jr.
TO:
Janet McCabe, Acting Assistant Administrator
Office of Air and Radiation
Craig E. Hooks, Assistant Administrator
Office of Administration and Resources Management
We will post this report to our website at http://www.epa.gov/oig.

-------
Follow-Up Report: EPA Improves	14-P-0321
Management of Its Radiation Monitoring System
		Table of C	
Purpose		1
Background 		1
Scope and Methodology		3
Results of Review		3
Corrective Actions Are Now Completed and Recorded in the
Official Agency Tracking System		3
EPA Actions on OIG Recommendations Resulted in Expanded
and Increased RadNet Operational Readiness		5
Conclusion		6
Agency Response and OIG Evaluation		6
Appendix
A Distribution 	 7

-------
Purpose
We reviewed actions taken by the U.S. Environmental Protection Agency (EPA)
to address the recommendations in the Office of Inspector General (OIG) Report
No. 12-P-0417, Weaknesses in EPA's Management of the Radiation Network
System Demand Attention, issued April 19, 2012. We reviewed the status of the
corrective actions for seven recommendations for which corrective actions were
listed as completed in the EPA's Management Audit Tracking System (MATS) as
of January 10, 2014. The Assistant Administrator for the Office of Air and
Radiation (OAR) and the Assistant Administrator for the Office of Administration
and Resources Management (OARM) were the action officials for these
recomm endati ons.
Background
The EPA's nationwide radiation monitoring system (RadNet) is designed to
measure ambient levels of radiation in the environment. The RadNet also
measures large-scale atmospheric releases of radiation impacting large parts of the
country and major population centers due to: large nuclear facility incidents or
accidents, large foreign radiological incidents or accidents, radiological dispersion
devices resulting in widely impacted areas (e.g., multi-county or larger), and
nuclear weapon detonations. The RadNet regularly samples the nation's air,
precipitation, drinking water and pasteurized milk for a variety of radionuclides
and radiation types.
The RadNet system is managed by the National Analytical Radiation
Environmental Laboratory (NAREL). The NAREL is part of the EPA's Office of
Radiation and Indoor Air, which is within the OAR. According to its website, the
NAREL is a comprehensive environmental laboratory committed to developing
and applying the most advanced methods for measuring environmental
radioactivity and evaluating the risk to the public.
This report, like its April 2012 predecessor, addresses the air-monitoring portion
of the RadNet. To sample the air, the NAREL established a network that currently
has 132 stationary air monitors. The EPA's December 2004 "Critical
Infrastructure and Key Resources Protection Plan" identified the RadNet monitors
as critical infrastructure. Air monitors are located in the District of Columbia,
Puerto Rico, and every state except South Carolina. Some states have more than
one monitor. Figure 1 shows the locations of these monitors. Every hour each
stationary monitor sends near-real-time measurements of beta and gamma
radiation to the NAREL. Filters on the air monitors capture particles from the air
(airborne particulates). Monitor operators collect the filters and send them to the
NAREL for testing.
14-P-0321
1

-------
Figure 1: Map showing the current location of RadNet air monitors
Source: OIG analysis based on monitor locations provided by NAREL staff.
The EPA OIG's April 2012 audit report sought to determine whether the agency
effectively implemented corrective actions to address the findings and
recommendations from the previous EPA OIG Report No. 09-P-0087, EPA Plans
for Managing Counter Terrorism/Emergency Response Equipment and Protecting
Critical Assets Not Fully Implemented, issued January 27, 2009. The EPA OIG's
April 2012 report found that broken RadNet monitors and delayed filter changes
impaired this critical infrastructure asset.
The EPA's management of the RadNet as a low priority, parts shortages, and
insufficient contract oversight contributed to extensive delays fixing broken
monitors. On March 11, 2011, at the time of the Fukushima, Japan, nuclear
incident, 25 of the 124 RadNet monitors installed (20 percent) were out of service
an average of 130 days. The service contractor completed repairs on all monitors
by April 8, 2011. In addition, broken RadNet monitors and relaxed quality
controls led to untimely filter changes. Six of the 12 RadNet monitors that the
OIG sampled for its 2012 report had gone over 8 weeks in a 1-year period without
a filter change. This is significant since out-of-service monitors and unchanged
filters may reduce the quality and availability of critical data needed to assess
radioactive threats to the public and the environment.
According to EPA Manual 2750, Audit Management Procedures, EPA staff
(i.e., the responsible office audit follow-up coordinator) tracks agency progress on
the corrective actions resulting from OIG recommendations and updates the
agency's official audit-tracking system, or MATS, accordingly. When the
responsible EPA action official completes corrective actions, the action official
prepares a certification memorandum certifying that the actions were completed.
Based on the certification memorandum, the audit follow-up coordinator from the
responsible office enters the final action date in the MATS.
14-P-0321
2

-------
Scope and Methodology
We performed our review from January through June 2014. We conducted this
performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objectives.
We interviewed EPA staff in the NAREL, OAR and OARM's Office of
Acquisition Management who were involved in implementing corrective actions
for the seven recommendations we reviewed. We also reviewed various guidance
documents, including EPA Manual 2750. In addition, we visited the NAREL in
Montgomery, Alabama, to observe air monitors and other facility operations.
We did not review corrective actions for one recommendation (recommendation 8)
made in the EPA OIG's April 2012 report because the corrective actions were not
completed when we started our review. This recommendation involved tracking the
installation of RadNet monitors against a revised schedule. We were told in
May 2014 by the OAR Audit Follow-Up Coordinator that the completion of
corrective actions for recommendation 8 is scheduled for September 2014.
Results of Review
The OAR and the OARM completed and recorded corrective actions on seven
recommendations made in the EPA OIG's April 2012 report. Through these
actions, the EPA increased the number of the RadNet fixed air monitors installed,
which expanded system coverage. These actions also increased the RadNet
system's operational readiness.
Corrective Actions Are Now Completed and Recorded in the
Official Agency Tracking System
Both the OAR and OARM completed corrective actions for the seven
recommendations we reviewed, as summarized in table 1. Not all of the actions
were reflected in the MATS as of January 10, 2014. However, during the course
of our follow-up review EPA staff revised the MATS to include the most recent
actions.
With two exceptions, as of January 10, 2014, the MATS properly reflected the
corrective actions taken at that time. As shown in table 1, the MATS was not
current for actions taken on OIG recommendations 3 and 7. Regarding
recommendation 3, the MATS did not reflect that the NAREL established a
metric of 200 hours for changing the filters in the air monitors. To prevent blower
motor damage, the RadNet air monitors are typically programmed to stop after
14-P-0321
3

-------
200 hours of operation should the blower not be able to maintain air flow.
Maintaining a set flow rate during sampling is a desirable operating goal. If a set
air flow is not maintained, less material is collected during the sampling interval.
Air flow issues may adversely affect the collection efficiency of the filter. At our
request, the NAREL documented the 200-hour limit in a quality assurance project
plan for the RadNet. Staff from the OAR revised the MATS in April 2014 to
reflect the 200-hour limit.
Regarding recommendation 7, the MATS incorrectly identified May 2012 as
the date for the performance evaluation of delivery order three under contract
EP-W-07-076. The OARM certification that this recommendation was complete
was also incorrect, since the April 2013 date it cited was for an evaluation that
was withdrawn shortly afterwards. The correct date for completing the
performance evaluation of delivery order three is April 2014. Staff from the
OARM revised the MATS in April 2014 to reflect recent corrective actions.
Table 1: Summary of actions completed and reported


Did the action officials
Were corrective actions

Recommendation
complete appropriate
corrective actions?
properly reported in
MATS?
1.
Establish and enforce written
expectations for RadNet operational
readiness commensurate with its role in
and importance to EPA's mission.
Yes
Yes
2.
Implement metrics for RadNet operational
readiness to be reviewed daily by NAREL,
and periodically by OAR (at least monthly)
and by the Deputy Administrator (as
needed).
Yes
Yes
3.
Direct that NAREL improve planning and
management for RadNet.
Yes
No
4.
Require follow-on RadNet contracts to
include incentives/disincentives and a
requirement for monthly progress reports.
Yes
Yes
5.
Require the contracting officer and
contracting officer representative to
formally evaluate RadNet contractors'
performance on an annual basis and
enter information into Past Performance
Information Retrieval System through
Contractor Performance Assessment
Reporting System.
Yes
Yes
6.
Determine whether domestic contract
options are available for crucial repair
parts that are identified as only being
available from a foreign subcontractor.
Yes
Yes
7.
Review the information in MATS for the
prior audit and ensure it is accurate and
current.
Yes
No
Source: OIG analysis.
14-P-0321

-------
EPA Actions on OIG Recommendations Resulted in Expanded and
Increased RadNet Operational Readiness
Corrective actions taken by the EPA in response to our recommendations have
increased the availability of critical data needed to assess radioactive threats to the
public and the environment. There are more air monitors in the network now and
a greater percentage of the total monitors are operating properly. Table 2
compares some key operational factors from the prior report to the current
situation.
Table 2: Comparison of RadNet operational factors before and after corrective actions
Operational factor
EPA OIG
April 2012 report
After corrective actions on
2012 recommendations
Number of stationary air
monitors in RadNet.
124 monitors
132 monitors
Percent of stationary monitors
operating (i.e., operational
readiness).
80%
(on 3/11/2011)
92.9%
(average of weekly reports for a
73-week period)
Number of stationary monitors
not operating for at least
14 days.
24 monitors
(on 3/11/2011)
4.1 monitors
(average of weekly reports for a
73-week period)
For 12 randomly selected
stationary monitors, number of
filters analyzed during a 1-year
period.
728
(5/1/2010-4/30/2011)
929
(1/1/2013-12/31/2013)
For 12 randomly selected
stationary monitors, longest
number of days between filter
changes.
339 days
(5/1/2010-4/30/2011)
46 days
(1/1/2013- 12/31/2013)
Source: OIG analysis.
Since the EPA OIG's April 2012 report, there are a larger number of installed
monitors in the network—132 monitors instead of 124. In addition, the NAREL
has eight more air monitors available for installation, which will bring the
network total up to 140 monitors. Locations in Paducah, Kentucky, and
Columbia, South Carolina, have been selected for two of the eight additional
monitors; the locations for the other six have not yet been decided.
Furthermore, the NAREL has increased the RadNet's operational readiness. Our
analysis of weekly status reports provided by the NAREL covering a 73-week
period ending with the week of February 17, 2014, showed that an average of
92.9 percent of the air monitors were operational, up from 80 percent in
March 2011. For selected monitors over a 1-year period, the length of time that
individual monitors were not operating had been reduced, as evidenced by the
reduction in the longest number of days between filter changes. Similarly, the
operators sent more air filters from these monitors to be analyzed by the NAREL.
14-P-0321
5

-------
Conclusion
The OAR and the OARM completed corrective actions on the recommendations
reviewed from EPA OIG Report No. 12-P-0417, and have now properly recorded
their efforts in the MATS. As a result of these efforts, the stationary air-
monitoring network increased its coverage and effectiveness. In addition,
completing the corrective actions increased the EPA's ability to assess radioactive
threats to the public and the environment.
Agency Response and OIG Evaluation
On June 24, 2014, the OAR and OARM responded that they appreciated the
OIG's efforts to assess whether the EPA is successfully addressing the
recommendations in the OIG Report No. 12-P-0417 issued in April 2012. The
OAR and OARM stated that they reviewed the draft report and had no further
comment. Since the OAR and OARM completed corrective actions on the
recommendations we reviewed and have now properly recorded their efforts in
MATS, this final report is closed upon issuance.
14-P-0321
6

-------
Appendix A
Distribution
Office of the Administrator
Assistant Administrator for Air and Radiation
Assistant Administrator for Administration and Resources Management
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Deputy Assistant Administrator for Air and Radiation
Principal Deputy Assistant Administrator for Administration and Resources Management
Director, Office of Radiation and Indoor Air, Office of Air and Radiation
Director, National Analytical Radiation Environmental Laboratory, Office of Air and Radiation
Director, Office of Acquisition Management, Office of Administration and
Resources Management
Director, Office of Policy and Resource Management, Office of Administration and
Resources Management
Deputy Director, Office of Policy and Resource Management, Office of Administration and
Resources Management
Director, Office of Regional Operations
Audit Follow-Up Coordinator, Office of Air and Radiation
Audit Follow-Up Coordinator, Office of Administration and Resources Management
Audit Follow-Up Coordinator, Office of Acquisition Management, Office of Administration and
Resources Management
14-P-0321
7

-------