I VMfS ? U.S. ENVIRONMENTAL PROTECTION AGENCY
\OFFICE OF INSPECTOR GENERAL
Briefing Report:
Improvements Needed in EPA's
Information Security Program
Report No. 13-P-0257
May 13, 2013

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Report Contributors:
Rudolph M. Brevard
Cheryl Reid
Vincent Campbell
Neven Soliman
Albert E. Schmidt
Rodney Allison
Nii-Lantei Lamptey
Kyle Denning
Abbreviations
CERT
Computer Emergency Response Team
EPA
U.S. Environmental Protection Agency
FDCC
Federal Desktop Core Configurations
FISMA
Federal Information Security Management Act
OCSPP
Office of Chemical Safety and Pollution Prevention
OEI
Office of Environmental Information
POA&M
Plan of Action and Milestones
TSCA
Toxic Substances Control Act
USGCB
U.S. Government Configuration Baseline
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
email:	OIG Hotline@epa.gov	write: EPA Inspector General Hotline
phone:	1-888-546-8740	1200 Pennsylvania Avenue, NW
fax:	202-566-2599	Mailcode 2431T
online:	http://www.epa.gov/oiq/hotline.htm	Washington, DC 20460

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tfED ST*.
*.	U.S. Environmental Protection Agency	13-P-0257
f ftJL \	Office of Inspector General	May 13 2013
iSjSl
^	At a Glance
Why We Did This Review
The U.S. Environmental
Protection Agency's (EPA's)
Office of Inspector General
(OIG) prepared this
supplemental report to
document the details, and
make recommendations, for
weaknesses the OIG identified
during its review of the
Agency's information security
program and practices. That
review was conducted as
required by the Federal
Information Security
Management Act (FISMA),
which requires inspectors
general to prepare an annual
evaluation of their agencies'
information security programs
and practices. The Department
of Homeland Security issued
reporting guidelines
documenting 11 FISMA
reporting metrics to be
evaluated as part of the fiscal
year 2012 FISMA audit.
This report addresses the
following EPA Goal or
Cross-Cutting Strategy:
 Strengthen EPA's
Workforce and Capabilities.
Briefing Report: Improvements Needed in
EPA's Information Security Program
What We Found
We found weaknesses in the following Agency programs regarding its
information security program and practices:
	Continuous monitoring management
	Configuration management
	Risk management
	Plan of action and milestones
	Contractor systems
This supplemental report to our previously issued report, Fiscal Year 2012
Federal Information Security Management Act Report: Status of EPA's Computer
Security Program (Report No. 13-P-0032), issued October 26, 2012, provides
additional detailed information for the above weaknesses.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Environmental Information
implement the continuous monitoring activities as specified in the Agency's
Continuous Monitoring Strategic Plan, document the remediation of
configuration-related vulnerabilities, and implement a strategic plan for EPA's risk
management framework.
The Agency concurred with the report's recommendations and provided high-
level planned corrective actions with completion dates. The Agency needs to
provide a completion date for one planned corrective action and additional
information on how the EPA will verify that offices remediate identified
weaknesses.
Noteworthy Achievements
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The Office of Environmental Information has developed a strategic plan for
continuous monitoring, approved the risk management framework, and created a
Risk Executive Group tasked with developing an Agency-wide risk management
strategy.
The full report is at:
www.epa.qov/oiq/reports/2013/
20130513-13-P-0257.pdf

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
May 13, 2013
MEMORANDUM
SUBJECT: Briefing Report: Improvements Needed in EPA's Information Security Program
Report No. 13-P-0257
This is our report on the subject evaluation 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 the OIG recommends. This report represents the opinion
of the OIG and does not necessarily represent the EPA position. The Agency concurred with the
report's recommendations and provided high-level planned corrective actions with completion dates.
However, the Agency needs to provide a completion date for one planned corrective action and revise
another planned corrective action to fully address the report's recommendation. Therefore, the
responses to those two recommendations are considered unresolved. Final determinations on matters in
this report will be made by EPA managers in accordance with established audit resolution procedures.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this report
within 60 calendar days. You should include planned corrective actions and completion dates for all
unresolved recommendations. Your response 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. We have no objections to the further release of this report to the public.
We will post this report to our website at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Richard Eyermann,
Acting Assistant Inspector General for Audit, at (202) 566-0565 or evermann.rich@epa.gov: or
Rudolph M. Brevard, Director, Information Resources Management Audits, at (202) 566-0893 or
brevard.rudv@epa. gov.
FROM:
Arthur A. Elkins Jr.
TO:
Malcolm D. Jackson, Assistant Administrator and Chief Information Officer
Office of Environmental Information

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Improvements Needed in EPA's
Information Security Program
Results of Review
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Purpose
The Federal Information Security Management Act (FISMA)
requires inspectors general to perform an annual evaluation of their
agencies' information security programs and practices. We found
information security weaknesses during our fiscal year 2012 FISMA
audit of the U.S. Environmental Protection Agency (EPA). This
briefing report provides the details for the weaknesses found during
the FISMA audit.
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Scope and Methodology
This is a supplemental draft report based on the fiscal year 2012
FISMA audit. We conducted the FISMA audit work at EPA
headquarters in Washington, D.C.; the National Computer Center,
Research Triangle Park, North Carolina; and all 10 regions. This
audit was conducted from February 2012 through November 2012.
We conducted this 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 andconc lusions
based on our review objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and
conclusions.
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Scope and Methodology (Cont.)
We reviewed federal regulations and EPA policies and procedures.
Our audit procedures included inquiries of appropriate personnel,
inspections of documents and records, and observations of EPA's
operations. We also conducted limited tests of selected information
system security controls.
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Scope and Methodology (Cont.)
For fiscal year 2012, we conducted an overall assessment for the
following 11 FISMA metrics:
1.
Continuous monitoring management
2.
Configuration management
3.
ldentityancj access mana gernent
4.
Incident response and reporting
5.
Risk management
6.
Security training
7.
Plan of action and milestones
8.
Remote access management
9.
Contingency planning
10.
Contractor systems
11.
Security capital planning
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Continuous Monitoring
Management
In June 2012 EPA developed the Continuous Monitoring Strategic
Plan. However, the Agency continues working toward implementing
the plan's continuous monitoring that includes ongoing assessments
of security controls.
Recommendations
We recommend that the Assistant Administrator for Environmental
Information:
1. Implement the continuous monitoring activities as specified in
the Agency's Continuous Monitoring Strategic Plan.
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Continuous Monitoring
Management (Cont.)
Agency Response and OIG Evaluation
The Agency concurs with the recommendation and provided a
planned corrective action, but the Agency did not provide a planned
completion date. The OIG considers the Agency's response
unresolved until a completion date has been established.
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Configuration Management
~	EPA is not assessing baseline compliance for EPA's firewalls,
routers, and Web server software.
~	EPA did not have a process for timely remediation of
configuration compliance scans.
~	EPA did not fully implement Federal Desktop Core
Configurations/U.S. Government Configuration Baseline
(FDCC/USGCB) secure configuration settings for 4 out of 15
workstations selected for testing.
~	EPA does not have a specified, documented timeline to correct
deviations from baseline configurations.
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Configuration Management (Cont.)
~	EPA did not ensure that unauthorized firewall rule modifications
occurred.
~	EPA has configuration management policies and procedures.
However, the procedures did not provide guidance as to what the
program offices and regions should classify as configuration items
(i.e., hardware, software, firmware) for information systems, and
did not provide a timeline of the system's development life cycle.
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Recommendations
We recommend that the Assistant Administrator for Environmental
Information:
2.	Assess baseline compliance for EPA's firewalls, routers, and
Web servers software.
3.	Update the configuration management process to verify
program offices remediate FDCC/USGCB deviations in a timely
manner.
4.	Perform regular reviews of firewall rules to ensure no
unauthorized changes were made.
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Recommendations (Cont.)
5. Update configuration management procedures to define what
the program offices and regions should classify as configuration
items for information systems, and define when during the
system development life cycle the configurable items are to be
placed under configuration management.
Agency Response and OIG Evaluation
The Agency concurs with the recommendations and provided
planned corrective actions and completion dates, but the
planned action does not fully address recommendation 3. The
planned action does not include a verification procedure to confirm
that program offices actually remediate FDCC/USGCB deviations in
a timely manner.
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Risk Management
~	Senior EPA officials throughout the Agency are currently not
briefed on:
Mission/business-specific risks and organizational level
(strategic) risks.
Threat activity described in U.S. Computer Emergency
Response Team's (CERT's) cyber-security threat reports.
~	Although the risk management framework has been approved,
the strategic plan needs to be implemented (e.g., the strategic
plan cites "security controls need to be implemented and
verified").
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Risk Management (Cont.)
~ EPA has recently approved the establishment of a Risk
Executive Group. However, the group needs to:
Define the core mission and business processes for the
organization (including any derivative or related missions and
business processes carried out by subordinate organizations).
Define both the types of information that the organization
needs in order to successfully execute the stated missions
and business processes and the internal and external
information flows.
Specify the degree of autonomy for subordinate organizations
(i.e., organizations within the parent organization) that the
parent organization permits for assessing, evaluating,
mitigating, accepting, and monitoring risk.
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Risk Management (Cont.)
Specify the types and extent of risk mitigation measures the
organization plans to employ to address identified risks.
Specify how the organization plans to monitor risk on an
ongoing basis given the inevitable changes to organizational
information systems and their environments of operation.
Specify the degree and type of oversight the organization
plans to use to ensure that the risk management strategyjS
being effectively carried out.
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Recommendations
We recommend that the Assistant Administrator for Environmental
Information:
6.	Brief senior EPA officials throughout the Agency on information
system specific risks (tactical), mission/business specific risks
and organizational level (strategic) risks, and threat activity
described in U.S. CERT cyber-security threat reports.
7.	Implement a strategic plan for EPA's risk management
framework.
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Recommendations (Cont.)
8. Work with the Risk Executive Group to:
a.	Define the core mission and business processes for the
organization (including any derivative or related missions and
business processes carried out by subordinate
organizations).
b.	Identify the types of information that the organization needs
in order to successfully execute the stated missions and
business processes.
c.	Specify the degree of autonomy for subordinate
organizations that the parent organization permits for
assessing, evaluating, mitigating, accepting, and monitoring
risk.
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Recommendations (Cont.)
d.	Specify the types and extent of risk mitigation measures the
organization plans to employ to address identified risks.
e.	Specify how the organization plans to monitor risk on an
ongoing basis given the inevitable changes to organizational
information systems and their environments of operation.
Agency Response and OIG Evaluation
The Agency concurs with the recommendations and provided
planned corrective action with completion dates for each
recommendation. The OIG concurs with the planned actions.
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Plan of Action and Milestones
EPA does not have plan of action and milestones (POA&M)
procedures or processes that provide assurance that the
weaknesses identified have been corrected by the planned
remediation.
Recommendation
We recommend that the Assistant Administrator for Environmental
Information:
9. Implement POA&M procedures to verify that weaknesses
identified in POA&Ms are corrected by the planned remediation.
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Plan of Action and Milestones
(Cont.)
Agency Response and OIG Evaluation
The Agency concurs with the recommendation and provided a
planned corrective action with a completion date. The OIG
concurs with the planned action.
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Contractor Systems
The Office of Chemical Safety and Pollution Prevention (OCSPP)
did not complete the required annual assessment of security
controls for the Toxic Substances Control Act (TSCA) Online
system. As of August 2012, OCSPP had assessed only 1.35% of
the security controls.
OCSPP personnel stated that in August 2010 they submitted a
request to the Office of Environmental Information (OEI) to have the
system removed from Office of Management and Budget reporting.
OCSPP personnel stated that even though the OEI did not provide
a formal response, they were under the impression that their
request was granted when advised to add tasks in the EPA's
Automated System Security Evaluation and Remediation Tracking
system to close out the system.
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Contractor Systems (Cont.)
OCSPP personnel stated that they have not completed an
assessment of security controls on the system since August 2010.
OCSPP personnel stated that in March 2012 OEI informed them
that the system could not be removed. OCSPP informed the OIG
that contractor services have been obtained to perform a risk
assessment and certification and accreditation for the system.
Recommendation
We recommend that the Assistant Administrator for Environmental
Information:
10. Verify that OCSPP completed an assessment of security
controls for the TSCA Online system.
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Contractor Systems (Cont.)
Agency Response and OIG Evaluation
The Agency concurs with the recommendation and provided a
planned corrective action with a completion date. The OIG
concurs with the planned action.
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No.
6
10
10
10
11
15
15
16
16
16
16
17
Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Subject
Status1
Action Official
Planned
Completion
Date
Claimed
Amount
Ag reed-To
Amount
Implement the continuous monitoring activities as
specified in the Agency's Continuous Monitoring
Strategic Plan.
Assess baseline compliance for EPA's firewalls,
routers, and Web servers software.
Update the configuration management process to
verify program offices remediate FDCC/USGCB
deviations in a timely manner.
Perform regular reviews of firewall rules to ensure
no unauthorized changes were made.
Update configuration management procedures to
define what the program offices and regions should
classify as configuration items for information
systems, and define when during the system
development life cycle the configurable items are to
be placed under configuration management.
Brief senior EPA officials throughout the Agency on
information system specific risks (tactical),
mission/business specific risks and organizational
level (strategic) risks, and threat activity described
in U.S. CERT cyber-security threat reports.
Implement a strategic plan for EPA's risk
management framework.
Work with the Risk Executive Group to:
Define the core mission and business
processes for the organization (including any
derivative or related missions and business
processes carried out by subordinate
organizations).
Identify the types of information that the
organization needs in order to successfully
execute the stated missions and business
processes.
Specify the degree of autonomy for
subordinate organizations that the parent
organization permits for assessing,
evaluating, mitigating, accepting, and
monitoring risk.
Specify the types and extent of risk mitigation
measures the organization plans to employ
to address identified risks.
Assistant Administrator for
Environmental Information
Assistant Administrator for 09/30/2013
Environmental Information
Assistant Administrator for
Environmental Information
Assistant Administrator for 09/30/2013
Environmental Information
Assistant Administrator for 06/28/2013
Environmental Information
Assistant Administrator for 06/30/2103
Environmental Information
Assistant Administrator for 12/31/2013
Environmental Information
Assistant Administrator for 12/31/2013
Environmental Information
23

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POTENTIAL MONETARY
RECOMMENDATIONS	BENEFITS (In $000s)
Planned
Rec. Page	Completion Claimed Agreed-To
No. No.	Subject	Status1 Action Official	Date	Amount Amount
17 e. Specify how the organization plans to
monitor risk on an ongoing basis given the
inevitable changes to organizational
information systems and their environments
of operation.
9	18 Implement POA&M procedures to verify that	0 Assistant Administrator for 06/30/2013
weaknesses identified in POA&Ms are corrected by	Environmental Information
the planned remediation.
10	21 Verify that OCSPP personnel complete an	0 Assistant Administrator for 09/06/2013
assessment of security controls for the TSCA	Environmental Information
Online system.
1 O = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is unresolved with resolution efforts in progress
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Appendix A
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION V
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EPA defines 'Senior Officials' as the Deputy Administrator, Chief Information Officer (CIO),
and Deputy CIO. These roles receive threat briefs at a level appropriate for senior officials
that enable them to manage strategic risks. EPA Authorizing Officials - those roles accepting
risk at the system and mission level - receive appropriate mission and system level risk briefs
through the system authorization process. Information Security Officers (ISOs) periodically
receive U.S. CERT threat briefs as well as threat briefs from the EPA CSIRC. The ISOs and
others in EPA also have available to them daily threat reports provided by a U.S. CERT
source provider. Given the defined scopes of senior officials and threat briefs above, the
SAISO believes the agency is complying with recommendations 6 through 10.
Office of Environmental Information. Office of Technology Operations and Planning Response
The Office of Technology Operations and Planning (OTOP) agrees with the Office of
Inspector General's (OIG) recommendations affecting resources under OTOP's purview and
have provided high-level intended corrective actions and estimated completion dates for
recommendations 1 through 5.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated
Completion by
Quarter and FY
1
Implement the continuous
monitoring activities as specified in
the Agency's Continues Strategic
Plan.
OTOP is responsible
for implementing the
Continuous
Monitoring (CM)
activities in the
Agency's CM
Strategic Plan. A high
level gap analysis has
been performed and
OTOP management is
reviewing the findings
for further action to
include task
designation among the
TBD
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2
Assess baseline compliance for
EPA's firewalls, routers, and web
server's software.
OTOP/NCC will:
Procure 3rd
party
independent
assessment to
formally review
baseline.
Add NIST 800-
53 control, CM-
02 as point of
emphasis during
future risk
assessments.
FY13 QTR4
(September 30, 2013)
3
Update the configuration
management process to verify
program offices remediate
FDCC/USGCB deviations in a
timely manner.
OTOP/EDSD, with
input from the SAISO,
will provide training
and procedures for the
Tivoli Endpoint
Administrators to run
compliance reports that
will show
FDCC/USGCB
deviations for their
respective program or
regional office.
FY13 QTR4
(September 6, 2013)
4
Perform regular reviews of firewall
rules to ensure no unauthorized
changes were made.
OTOP/NCC will
review and recommend
a practical solution for
firewall rule reviews
and integrity
correlations. The
implementation
schedule will be
assessed and
determined based on
approved solution and
resource constraints.
FY13 QTR4
(September 30, 2013)
5
Update configuration management
procedures to define what the
program offices and regions should
classify as configuration items for
information systems, and define
when during the system
development life cycle the
configurable items are to be placed
under configuration management.
OTOP will:
Identify standard
guidance for
identifying IT
configuration
items based on
best practices.
OTOP will update
the Configuration
Management
procedure.
FY13 QTR3 (April 15,
2013)
FY13 QTR 3 (June 28,
2013)
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6
Brief senior EPA officials
throughout the Agency on
information system specific risks
(tactical), mission/business specific
risks and organizational level
(strategic) risks, and threat activity
described in U.S. CERT cyber-
security threat reports.
The SAISO concurs
with the following
recommendations
and plans to take
stated actions
FY13 QTR 3 (June 30,
2013)
7
Implement a strategic plan for
EPA's risk management framework.
The CIO's office will
finalize and begin
implementing a
Risk Managment
Strategic Plan by
the end of Q1FY14
FY14 QTR 1
(December 31, 2013)
8
Work with the Risk Executive
Group to:
a.	Define the core mission and
business processes for the
organization (including any
derivative or related missions
and business processes carried
out by subordinate
organizations).
b.	Identify the types of information
that the organization needs in
order to successfully execute the
stated missions and business
processes.
c. Specify the degree of
autonomy for subordinate
organizations that the parent
organization permits for
assessing, evaluating, mitigating,
accepting, and monitoring risk.
d.	Specify the types and extent of
risk mitigation measures the
organization plans to employ to
address identified risks.
e.	Specify how the organization
plans to monitor risk on an
ongoing basis given the
inevitable changes to
organizational information
systems and their environments
of operation.
The CIO's office will
finalize and begin
implementing a Risk
Managment Strategic
Plan by the end of
Q1FY14. This work
will be accomplished
in the development
and implementation
of the Risk
Management
Strategic Plan.
FY14 QTR 1
(December 31, 2013)
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9
Implement POA&M procedures to
verify that weaknesses identified in
POA&Ms are corrected by the
planned remediation.
The SAISO will
implement a Plans of
Actions and
Milestones
(POA&M) validation
and monitoring
process in Q3FY13.
FY13 QTR 3 (June 30,
2013)
10
Verify that OCSPP completed an
assessment of security controls for
the TSCA Online system.
The SAISO will verify
OCSSP has completed
security controls
assessment on TSCA
Online by the end of
Q4FY13.
FY13 QTR 4
(September 6, 2013)
If you have any questions or concerns about this response, please feel free to contact
Tom Tracy, Acting Director of the Policy, Outreach and Communications Staff, at
(202) 564-6518 or Scott Dockum the OEI Audit Follow-up Coordinator at (202) 566-1914.
cc:
Robert McKinney
Anne Mangiafico
Brenda Young
Thomas Tracy
Scott Dockum
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator for Environmental Information and Chief Information Officer
Agency Follow-Up Official (CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Senior Agency Information Security Officer
Director, Office of Technology Operations and Planning, Office of Environmental Information
Audit Follow-Up Coordinator, Office of Environmental Information
Audit Follow-Up Coordinator, Office of Technology Operations and Planning,
Office of Environmental Information
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