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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Compendium of
Unimplemented
Recommendations
as of September 30, 2013
Report No. 14-N-0016
November 15, 2013
Scan this mobile
code to learn more
about the EPA OIG.

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Abbreviations
CAA	Clean Air Act
CFR	Code of Federal Regulations
CHP	Contractor-held property
CSB	U.S. Chemical Safety and Hazard Investigation Board
CTS	Customer Technology Solutions
CWA	Clean Water Act
ECHO	Enforcement Compliance and History Online
EMP	Emergency Management Portal
EPA	U.S. Environmental Protection Agency
F AR	F ederal Acqui siti on Regul ati on
FY	Fiscal Year
HPV	High Priority Violation
MATS	Management Audit Tracking System
NCP	National Contingency Plan
NPDES	National Pollutant Discharge Elimination System
OA	Office of the Administrator
OAM	Office of Acquisition Management
OAR	Office of Air and Radiation
OARM	Office of Administration and Resources Management
OCFO	Office of the Chief Financial Officer
OCSPP	Office of Chemical Safety and Pollution Prevention
OECA	Office of Enforcement and Compliance Assurance
OEI	Office of Environmental Information
OEM	Office of Emergency Management
OIG	Office of Inspector General
OMB	Office of Management and Budget
ORD	Office of Research and Development
OSWER	Office of Solid Waste and Emergency Response
OW	Office of Water
TRIM	Total Records and Information Management
Suggestions for Audits or Evaluations
To make suggestions for audits or evaluations,
contact us through one of the following methods:
email:	OIG WEBCOMMENTS@epa.gov.
phone:	1-202-566-2391
fax:	1-202-566-2599
online:	http://www.epa.aov/oia/contact.html#Full Info
write: EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW
Mailcode 2431T
Washington, DC 20460
Hotline
To report fraud, waste or abuse, contact
us through one of the following methods:
email:	OIG Hotline@epa.qov
phone:	1-888-546-8740
fax:	1-202-566-2599
online:	http://www.epa.aov/oia/hotline.htm
write: EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW
Mailcode 2431T
Washington, DC 20460

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
November 15, 2013
MEMORANDUM
SUBJECT: Compendium of Unimplemented Recommendations as of September 30, 2013
Report No. 14-N-0016
Deputy Administrator
Assistant Administrators
General Counsel
Chief Financial Officer
Associate Administrators
Regional Administrators
Attached is the semiannual Compendium of Unimplemented Recommendations as of September 30,
2013, prepared by the Office of Inspector General (OIG) of the U.S. Environmental Protection Agency
(EPA). By statute, the OIG serves as the Inspector General for the U.S. Chemical Safety and Hazard
Investigation Board (CSB) as well as the EPA. As such, this report includes information pertaining to
the EPA and the CSB. This Compendium fulfills the requirement of the Inspector General Act of 1978,
as amended, to prepare semiannual reports summarizing the activities of the OIG that include an
identification of each significant recommendation described in previous semiannual reports on which
corrective action has not been completed. The information included in part 1 of the report identifies
those significant recommendations with corrective actions that have not been implemented 1 year or
more past the agreed-to completion date and are past due. The information in part 2 identifies those
recommendations with corrective actions that have not been completed less than 1 year past the
agreed-to date or have agreed-to dates that are in the future. Corrective actions are being reported as
past due if they have not been completed within 1 year of the original agreed-to date or the extended
plan date established by September 30, 2011.
This Compendium is issued in conjunction with the Semiannual Report to Congress
April 1, 2013-September 30, 2013, and as a separate report to the EPA's leadership. As part of the
OIG's results-oriented culture, we perform follow-up assessments to determine whether planned actions
by the EPA in response to OIG recommendations were taken. Follow-up is done in collaboration with
the EPA's Office of the Chief Financial Officer and the EPA's audit follow-up coordinators. The goal is
to improve overall audit management by increasing the EPA's managers' awareness of outstanding
agreed-to commitments for action on OIG report recommendations. Implementing these
recommendations will correct weaknesses, reduce vulnerabilities to risk, and leverage opportunities for
improved performance.
FROM: Arthur A. Elkins Jr.
TO:
Administrator

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The significance of audit follow-up, as described by the Office of Management and Budget (OMB)
Circular A-50, is enhanced by the public's expectation for greater transparency and a heightened interest
by Congress in realizing potential opportunities for improvement in the federal government. The OIG's
previous Compendium reports appear to be increasing agency awareness of and action on
unimplemented OIG recommendations.
The OIG identified the unimplemented recommendations listed in this Compendium based on their
significance, material impact, and status in the EPA's Management Audit Tracking System, as well as
others identified through OIG review. Omission of an unimplemented recommendation from this report
does not lessen its value or the importance of completing the corrective action, and still warrants the full
attention of the EPA.
According to OMB Circular A-50, audit follow-up is a shared responsibility between the agencies and
the OIG. We will continue to identify unimplemented recommendations for attention and action, as well
as remove the previously reported unimplemented recommendations when appropriate information of
completion is provided. We hope that you find this tool useful in identifying ways to further improve
agency operations.
If you or your staff have any questions, please contact Crystal Barrett at (202) 566-2060 or
barrett.crystal@epa.gov, or Aracely Nunez-Mattocks at (202) 566-0840 or
nunez-mattocks.aracelv@epa.gov.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
November 15, 2013
The Honorable Rafael Moure-Eraso, Ph.D.
Chairperson and Chief Executive Officer
U.S. Chemical Safety and Hazard Investigation Board
2175 K Street, NW, Suite 400
Washington, D.C. 20037-1809
Dear Dr. Moure-Eraso:
Enclosed is the semiannual Compendium of UnimplementedRecommendations as of
September 30, 2013, prepared by the Office of Inspector General (OIG) of the U.S. Environmental
Protection Agency (EPA). By statute, the OIG serves as the Inspector General for the U.S. Chemical
Safety and Hazard Investigation Board (CSB) as well as the EPA. As such, this report includes
information pertaining to the EPA and the CSB. This Compendium fulfills the requirement of the
Inspector General Act of 1978, as amended, to prepare semiannual reports summarizing the activities of
the OIG that include an identification of each significant recommendation described in previous
semiannual reports on which corrective action has not been completed. The information included in
part 3 of the report identifies those significant CSB recommendations with corrective actions that have
not been implemented 1 year or more past the agreed-to completion date and are past due. The
information in part 4 identifies those CSB recommendations with corrective actions that have not been
completed less than 1 year past the agreed-to date or have agreed-to dates that are in the future.
Corrective actions are being reported as past due if they have not been completed within 1 year of the
original agreed-to completion date.
This Compendium is issued in conjunction with the Semiannual Report to Congress
April 1, 2013-September 30, 2013, and as a separate report to the CSB's leadership. As part of the
OIG's results-oriented culture, we perform follow-up assessments to determine whether planned actions
by the CSB in response to OIG recommendations were taken. Follow-up is done in collaboration with
the CSB managing director. The goal is to improve overall audit management by increasing the CSB
managers' awareness of outstanding agreed-to commitments for action on OIG report recommendations.
Implementing these recommendations will correct weaknesses, reduce vulnerabilities to risk, and
leverage opportunities for improved performance.
The significance of audit follow-up, as described by the Office of Management and Budget (OMB)
Circular A-50, is enhanced by the public's expectation for greater transparency and a heightened interest
by Congress in realizing potential opportunities for improvement in the federal government. This
Compendium report should help increase the CSB's awareness of and action on unimplemented OIG
recommendations.

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The OIG identified the unimplemented recommendations listed in this Compendium based on their
significance, material impact, and status as reported on the spreadsheet received from the CSB on
September 27, 2013, as well as others identified through OIG review. Omission of an unimplemented
recommendation from this report does not lessen its value or the importance of completing the
corrective action, and still warrants the full attention of the CSB.
According to OMB Circular A-50, audit follow-up is a shared responsibility between the CSB and the
OIG. We will continue to identify unimplemented recommendations for attention and action, as well as
remove the previously reported unimplemented recommendations when appropriate information of
completion is provided. We hope that you find this tool useful in identifying ways to further improve the
CSB's operations.
If you or your staff have any questions, please contact Crystal Barrett at (202) 566-2060 or
barrett.crvstal@epa.gov, or Aracely Nunez-Mattocks at (202) 566-0840 or
nunez-mattocks.aracelv@epa.gov.
Sincerely,
' >' ¦ *
Arthur A. Elkins Jr.

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Compendium of Unimplemented Recommendations
as of September 30, 2013
14-N-0016
Table of Contents
Introduction		1
Purpose		1
Background 		1
Scope and Methodology 		2
Part One: Unimplemented EPA Recommendations With
Past Due Completion Dates		4
12-P-0388 (OARM) 		4
12-P-0125 (OA) 		6
12-P-0113 (OECA) 		7
12-1-0073 (OARM)		8
12-2-0072	(Region 9) 		9
11-P-0708 (OA) 		10
11-P-0705 (OARM) 		11
11-P-0687 (OARM) 		12
11-P-0630 (OCFO)		13
11-P-0616 (OARM) 		15
11-P-0534 (OSWER) 		16
11-P-0386 (ORD) 		19
11-P-0315 (OECA) 		20
11-R-0179 (OAR) 		22
11-P-0171 (OSWER) 		24
11-P-0136 (OARM) 		26
11-P-0031 (OCFO)		27
10-P-0230 (OECA) 		28
10-P-0154 (OAR) 		29
10-P-0066 (OCSPP) 		31
10-1-0029 (OCFO) 		32
10-P-0007 (OECA) 		34
10-P-0002 (OARM) 		35
09-P-0087 (OARM) 		37
2007-P-00016 (Region 2)		38
2007-P-00002 (OSWER) 		39
2006-P-00013 (OCFO)		40
2005-P-00024 (OECA) 		41
2005-P-00010 (OAR) 		42
2001-P-00013 (OECA) 		44
Part Two: Unimplemented EPA Recommendations With
Future Planned Completion Dates		45
13-P-0208	(OARM and OSWER)		45
13-P-0207 (Region 7)		47
13-R-0206 (Region 10) 		48
13-P-0201 (OA) 		49

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Compendium of Unimplemented Recommendations
as of September 30, 2013
14-N-0016
13-P-0200 (OARM) 		52
13-P-0178 (OARM and OSWER)		54
13-P-0176 (OSWER) 		55
13-P-0175 (OCFO and OW) 		56
13-P-0163 (OCSPP and OCFO) 		57
13-P-0162 (OARM) 		58
13-P-0161 (ORD and OAR) 		60
13-P-0152 (OSWER) 		63
13-1-0054 (OCFO and OECA) 		64
13-P-0028 (OCFO and OARM) 		65
12-P-0900 (OEI) 		66
12-P-0899 (OEI) 		67
12-P-0879 (OEI) 		68
12-P-0836 (OARM and OEI) 		70
12-P-0747 (OAR) 		71
12-P-0600 (OCSPP)		72
12-P-0508 (OSWER) 		73
12-P-0453 (OW) 		74
12-P-0427 (OEI) 		75
12-P-0417 (OAR) 		76
12-P-0388 (OARM) 		77
12-P-0289 (OSWER) 		79
12-P-0253 (OSWER) 		80
12-P-0220 (Region 10)		81
12-P-0113 (OECA) 		82
11-P-0725 (Region 9)		83
11-P-0701 (OAR) 		84
11-P-0534 (OSWER) 		85
11-P-0430 (Region 8)		86
11-P-0333 (ORD) 		87
11-P-0277 (OEI) 		88
11-P-0223 (OCFO)		89
11-P-0173 (OSWER) 		90
11-P-0010	(OAR) 		91
10-P-0224 (OECA and OW)		92
10-P-0177 (OARM, OCFO and OEI)		93
10-P-0066 (OCSPP) 		94
10-P-0042 (OSWER) 		95
10-P-0007 (OECA) 		96
10-P-0002	(OARM) 		97
09-P-0223 (OW) 		98
09-P-0151 (OAR) 		99
08-P-0196 (Region 9)		100
2007-P-00002 (OSWER) 		101
2001-P-00013 (OECA) 		102
Part Three: Unimplemented CSB Recommendations With
Past Due Completion Dates		103
12-P-036	3		103
11-P-011	5		104
ii

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Compendium of Unimplemented Recommendations
as of September 30, 2013
14-N-0016
Part Four: Unimplemented CSB Recommendations With
Future Planned Completion Dates	 108
13-P-0128	 108
12-P-0724	 109
12-P-0363	 111
Appendix A: EPA OIG Reports With Unimplemented
Recommendations by Program Office
as of September 30, 2013	 112
Appendix B: Unimplemented Recommendations:
Current EPA Compendium (Past Due Recommendations)
Compared to 04/30/13 Compendium	 119

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Introduction
Purpose
Section 5(a) of the Inspector General Act of 1978, as amended (5 U.S.C. App. 3), requires each
Inspector General to issue semiannual reports to Congress and include "an identification of each
significant recommendation described in previous semiannual reports on which corrective action
has not been completed." The Office of Inspector General (OIG) prepares the Compendium of
Unimplemented Recommendations to satisfy this requirement. The Compendium highlights for
the U.S. Environmental Protection Agency (EPA) and the U.S. Chemical Safety and Hazard
Investigation Board (CSB) management those significant recommendations that are
unimplemented 1 year or more past the date agreed upon by the EPA or the CSB and the OIG. It
also provides a listing of all of the other significant recommendations with corrective actions that
are less than 1 year past the agreed-to completion date or have completion dates that are in the
future. This Compendium is being issued in conjunction with the OIG Semiannual Report to
Congress for the reporting period April 1, 2013, through September 30, 2013. The Compendium
helps agency management stay informed about the EPA's or the CSB's outstanding
commitments, and its progress in taking agreed-upon corrective actions on OIG
recommendations to improve programs and operations.
Background
Recommendations are issued by the EPA's OIG to improve the economy, efficiency,
effectiveness, or integrity of the EPA's and the CSB's programs and operations. Office of
Management and Budget (OMB) Circular A-50, Audit Followup, dated September 29, 1982,
affirms that corrective action taken by management on resolved findings and recommendations is
essential for improving the effectiveness and efficiency of government operations. It also states
that audit follow-up is a shared responsibility of agency management officials and auditors.
OMB Circular A-50 requires each agency to ensure that systems are in place for the prompt and
proper resolution and implementation of audit recommendations. EPA Manual 2750, based in
part on OMB Circular A-50, details the EPA's audit management procedures. The Chief
Financial Officer is the EPA audit follow-up official who has responsibility for ensuring
agencywide audit resolution and implementation of corrective actions by action officials. The
EPA uses the Management Audit Tracking System (MATS) to track information on the agency's
implementation of OIG recommendations. The Office of the Chief Financial Officer (OCFO)
maintains and operates MATS. Report data, such as the title, issue date and recommendations,
are downloaded into MATS from the Inspector General Enterprise Management System.
The Office of the Administrator, Office of General Counsel, OCFO, and each Assistant
Administrator and Regional Administrator designate an audit follow-up coordinator for their
respective office. Audit follow-up coordinators are responsible for quality assurance and analysis
of data in the tracking system. When all corrective actions in response to recommendations in an
audit report are completed and certified, the agency may inactivate that report's MATS file, and
it is no longer tracked by the audit follow-up coordinator. The agency self certifies that
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corrective actions are completed. Section 5(b)(4) of the Inspector General Act of 1978, as
amended (5 U.S.C. App. 3), also requires the agency to report audit reports for which final
corrective action has not been taken 1 year or more after the agency's management decision
(agreement with the OIG on planned corrective actions).
The CSB's managing director tracks information on the CSB's implementation of the OIG's
recommendations in a spreadsheet. The CSB updates and provides the spreadsheet to the OIG on
a semiannual basis. When all corrective actions for recommendations in a report have been
completed, the CSB removes it from the spreadsheet.
Scope and Methodology
The work performed in this review does not constitute an audit conducted in accordance with
generally accepted government auditing standards issued by the Comptroller General of the
United States. Although MATS and the spreadsheet provided by the CSB were our primary
sources for identifying unimplemented recommendations, we did perform additional steps to
search for unimplemented recommendations that may not have been identified in MATS or the
spreadsheet. We analyzed the MATS data in the system as of October 23, 2013. We did not
verify the accuracy of the information reported in MATS.
We reviewed selected audit and evaluation reports issued to the EPA by the OIG from
October 1, 2000, through March 31, 2013, to identify significant unimplemented
recommendations for inclusion in the Compendium. However, we did not identify any significant
unimplemented recommendations from fiscal years (FYs) 2002, 2003 and 2004. We reviewed
reports issued to the CSB by the OIG from October 1, 2010, to March 31, 2013. We did not
review recommendations from reports without an OIG agreement on the agency's proposed
corrective actions. A list of the reports without a management decision can be found in Appendix
2 of the Semiannual Report to Congress.
We limited the consideration of unimplemented recommendations to those we believe were
significant because they could have a material impact on the economy, efficiency, effectiveness
or integrity of the EPA's and the CSB's programs and operations. For this purpose, we define
significant recommendations in the following terms:
•	Economy: Opportunity to save, prevent loss or recover at least $500,000 in monetary
costs or value.
•	Efficiency: Improvement in the process, capacity, accessibility or delivery of program
objectives and the elimination of unnecessary or unproductive actions or expenses.
•	Effectiveness: Improvement in the quality of, or reduction in the risk to, public health
and the environment.
•	Integrity: Improvement in operational accountability, enforcement of and compliance
with laws and regulations, and security of resources for public confidence.
The Compendium consists of four sections: (1) unimplemented recommendations for the EPA
with past due completion dates; (2) unimplemented recommendations for the EPA with future
planned completion dates; (3) unimplemented recommendations for the CSB with past due
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completion dates; and (4) unimplemented recommendations for the CSB with future planned
completion dates. The OIG considers a recommendation past due if the associated corrective
action was not completed within 1 year of the original agreed-to date or the extended date the
EPA established by September 30, 2011.
The EPA offices that have unimplemented recommendations with past due dates listed in this
Compendium are:
Office of the Administrator (OA)
Office of Administration and Resources Management (OARM)
Office of Air and Radiation (OAR)
Office of the Chief Financial Officer (OCFO)
Office of Chemical Safety and Pollution Prevention (OCSPP)
Office of Enforcement and Compliance Assurance (OECA)
Office of Research and Development (ORD)
Office of Solid Waste and Emergency Response (OSWER)
Region 2
Region 9
The EPA offices that have unimplemented recommendations with future planned completion
dates in this Compendium are:
Office of the Administrator (OA)
Office of Administration and Resources Management (OARM)
Office of Air and Radiation (OAR)
Office of the Chief Financial Officer (OCFO)
Office of Chemical Safety and Pollution Prevention (OCSPP)
Office of Enforcement and Compliance Assurance (OECA)
Office of Environmental Information (OEI)
Office of Research and Development (ORD)
Office of Solid Waste and Emergency Response (OSWER)
Office of Water (OW)
Region 7
Region 8
Region 9
Region 10
We anticipate that the EPA will provide updates in MATS on the status of each unimplemented
recommendation to include a description of progress and an explanation of the delay in
completing an agreed-to action.
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Part One:
Unimplemented EPA Recommendations With
Past Due Completion Dates
Action Office:
OARM
Report Title:
EPA Should Improve Controls for Managing Contractor-Held Property
Report No.:
12-P-0388
Date Issued:
04/03/2012
Report Summary
The EPA does not have effective oversight of contractor-held property (CHP), did not accurately
report CHP in its FY 2010 financial statements, and did not fully implement corrective actions
from an Office of Inspector General 2006 audit report. The EPA does not have effective
oversight of CHP in terms of property administration, policies and procedures over the CHP
management program, and modifications to contracts with CHP. Further, the EPA incorrectly
recorded CHP and reported property in the wrong funding appropriation. As a result, the EPA
overstated CHP by $34.6 million in the FY 2010 financial statements. The EPA did not fully
implement corrective actions to address recommendations from our FY 2006 report, EPA Needs
to Strengthen Oversight of Government Furnished Property. The EPA provided corrective
actions, but only implemented one of two recommendations. Without accurate CHP records and
proper property administration at contractor sites, the agency has no safeguards over property
and could inaccurately report CHP in the financial statements. In FY 2011, the EPA addressed
the accuracy of CHP and adjusted its FY 2011 financial statements for the overstatements.
Unimplemented Recommendations
Recommendation 1: We recommend that the Assistant Administrator for Administration and
Resources Management quantify the universe of CHP and assign more resources to the property
administration function or contract the function to ensure proper oversight and management of
CHP.
Recommendation 3: We recommend that the Assistant Administrator for Administration and
Resources Management develop and implement policies and procedures for the property staff
that:
a.	Address how the EPA should maintain documentation to support acquisition values
reported by contractors on annual property reports.
b.	Require project management officers to have knowledge of CHP in their accountable
areas to ensure it is identified properly in the Fixed Assets Subsystem.
c.	Define CHP responsibilities in locations where contractors and the EPA's staff are co-
located.
d.	Explain the required exchange between property and contract staffs to ensure the EPA's
records property accurately in the financial statements.
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Status: OARM's Office of Acquisition Management (OAM) has implemented a balanced
scorecard performance measurement and management program where CHP
administration will be highlighted under additional narratives beyond the quarterly
assessment and management certification. This includes a self-assessment review on
CHP and adding CHP as an area of increased review under the self-assessment and peer
review components of the Quality Assurance Program. OAM is currently developing
required performance goals against which procurement quality may be measured and
tracked. It is intended that this initiative will aid in the development of approaches to
create process improvements, and training as needed, based upon Quality Assurance
Program review results. Corrective actions are now expected to be completed by
November 30, 2013, to align with the completion of the development for required
performance goals. OARM agreed to initiate the corrective actions by September 30,
2011. (These corrective actions apply to both recommendations 1 (corrective action 5)
and 3 (corrective action 11).)
Recommendation 6: We recommend that the Assistant Administrator for Administration and
Resources Management revise or update the milestone dates and the corrective action plan in
MATS for the 2006 audit report and reference any corrective actions, and submit changes to the
OIG for tracking.
Status: OARM agreed to update the corrective actions from the 2006 audit in MATS.
The original agreed-to completion date was May 31, 2012.
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Action Office: OA
Report Title: Early Warning Report: Use of Unapproved Asbestos Demolition Methods May
Threaten Public Health
Report No.:	12-P-0125
Date Issued: 12/14/2011
Report Summary
Our preliminary research indicates that unapproved methods are currently being used or
considered at multiple asbestos sites. The Hanford Superfund Site, near Richland, Washington, is
one location where the use of Alternative Asbestos Control Method-like methods has been
allowed by the EPA under conditions that are less restrictive than those required by the Asbestos
National Emission Standards for Hazardous Air Pollutants. The EPA is also considering other
unapproved methods for demolition at a gaseous diffusion plant in Paducah, Kentucky. The use
of unapproved methods is counter to the EPA's regulations. The current and proposed use of
unapproved methods may jeopardize the health and safety of the public.
Unimplemented Recommendations
Recommendation 5: We recommend that the EPA identify the workers that were present during
the Alternative Asbestos Control Method demolition experiments and notify them according to
Occupational Safety and Health Administration regulations.
Status: The Deputy Administrator assembled a team from OCSPP and OAR to review
the documents with information regarding workers who were present. OA received the
report from the Occupational Safety and Health Administration and it asked ORD's
National Risk Management Research Lab to draft a letter notifying Alternative Asbestos
Control Method participants regarding their exposure to asbestos. OA expected the
review to be done by November 23, 2012. Once it is complete, OA will brief the Deputy
Administrator and then send the notifications. The original agreed-to completion date was
March 15, 2012.1
1 Subsequent to the close of our review period, October 22, 2013, OA notified us that this action was completed
prior to September 30, 2013. However, this was not reflected in MATS prior to October 22, 2013.
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Action Office:
OECA
Report Title: EPA Must Improve Oversight of State Enforcement
Report No.:	12-P-0113
Date Issued: 12/09/2011
Report Summary
The EPA does not administer a consistent national enforcement program. Despite efforts by
OECA and the EPA regions to improve state enforcement performance, state enforcement
programs frequently do not meet national goals and states do not always take necessary
enforcement actions. State enforcement programs are underperforming: the EPA data indicate
that noncompliance is high and the level of enforcement is low. The EPA does not consistently
hold states accountable for meeting enforcement standards, has not set clear and consistent
national benchmarks, and does not act effectively to curtail weak and inconsistent enforcement
by states.
OECA has made efforts to improve state performance and oversight consistency, but the EPA
does not manage or allocate enforcement resources nationally to allow it to intervene in states
where practices result in significantly unequal enforcement. As a result, state performance
remains inconsistent across the country, providing unequal environmental benefits to the public
and an unlevel playing field for regulated industries. By establishing stronger organizational
structures, the EPA can directly implement a national enforcement strategy that ensures all
citizens have, and industries adhere to, a baseline level of environmental protection. The EPA
could make more effective use of its $372 million in regional enforcement full-time equivalents
by directing a single national workforce instead of 10 inconsistent regional enforcement
programs.
Unimplemented Recommendation
Recommendation 4: We recommend that the Assistant Administrator for Enforcement and
Compliance Assurance establish a clear and credible escalation policy for the EPA's intervention
in states that provides steps that EPA will take when states do not act to ensure that the Clean Air
Act (CAA), Clean Water Act (CWA), and Resource Conservation and Recovery Act are enforced.
Status: OECA is developing an escalation strategy to address state enforcement
performance issues. The original agreed-to completion date was September 30, 2012.
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Action Office:
Report Title:
Report No:
Date Issued:
OARM
Audit of EPA's Fiscal 2011 and 2010 Consolidated Financial Statements
12-1-0073
11/15/2011
Report Summary
We performed this audit to determine whether the EPA's consolidated financial statements were
fairly stated in all material respects; the EPA's internal controls over financial reporting were in
place; and the EPA management complied with applicable laws and regulations. We noted the
following significant deficiencies:
•	Regions and headquarters did not timely provide accounts receivable supporting
documentation.
•	The EPA did not timely bill other federal agencies for reimbursable costs.
•	The EPA did not properly close general ledger accounts in its canceling Treasury
symbols.
•	The EPA double counted contractor-held property.
•	The EPA's headquarters could not account for 1,284 personal property items.
•	The EPA needs to better secure marketable securities.
•	The EPA recorded earned revenue without recognizing corresponding expenses.
•	The EPA is withholding payments related to the Deepwater Horizon oil spill.
We also noted a noncompliance issue involving the EPA's Oil Spill Response Account in
relation to the Deepwater Horizon oil spill response. The EPA violated the Antideficiency Act in
November 2010 because it made expenditures in excess of funds available.
Unimplemented Recommendation
Recommendation 9: We recommend that the Assistant Administrator for Administration and
Resources Management develop and implement policies and procedures to address responsibility
for the removal of the EPA property from the agency financial system when the EPA property is
transferred to contractors.
Status: OARM will revise the Property Management Manual to contain clarification of
the roles and responsibilities for the removal of the EPA property from the agency
financial system when the EPA property is transferred to contractors by December 31,
2013. The original agreed-to completion date was June 30, 2012.
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Action Office: Region 9
Report Title: Agreed-Upon Procedures Applied to EPA Grants Awarded to Summit Lake
Paiute Tribe, Sparks, Nevada
Report No.:	12-2-0072
Date Issued: 11/10/2011
Report Summary
Although our transaction tests showed that labor costs claimed by the Summit Lake Paiute Tribe
under the EPA grants were generally supported by timesheets, the following timekeeping issues
warrant attention:
•	The timekeeping process for the Indian Environmental General Assistance Program
grants did not comply with Code of Federal Regulations (CFR) requirements in 2 CFR
Part 225.
•	A third party did not consistently verify the chairman's consent to use his signature stamp
for timesheet approval.
•	The tribe charged indirect labor costs as direct costs, contrary to its accounting policy.
•	The tribe did not have policies and procedures for leave allocation.
As a result of the above issues, we questioned labor costs of $96,615.
We found that the tribe was addressing some of the issues raised in the 2008 and 2009 single
audits. However, additional work remains to be done on issues relating to deferred revenues and
updating policies and procedures.
Unimplemented Recommendation
Recommendation 2: We recommend that the Regional Administrator, EPA Region 9, 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.
Status: The tribe established a current timesheet that documents all hours worked and
implemented a new procedure on the use of the chairman's signature stamp.
The tribe plans to use the Micro-Information Processing payroll computerized system for
a labor allocation feature that will comply with 2 CFR Part 225 requirements. As of
September 18, 2013, the tribe's financial officer and consultant had developed a process
in which leave will post to the right program/grant. It is still in the finalizing stage. The
original agreed-to completion date was July 31, 2012.
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Action Office:
OA
Report Title: EPA Progress on the 2007 Methamphetamine Remediation Research Act
Report No.:	11-P-0708
Date Issued: 09/27/2011
Report Summary
The EPA has met some, but not all, of its requirements under the Meth Act. While the EPA did
publish an initial set of guidelines, Voluntary Guidelines for Methamphetamine Laboratory
Cleanup, in August 2009, it has not yet developed plans to periodically update the guidelines as
required. The EPA developed a draft multiyear research plan, but has delayed its
implementation. The EPA also has no plans to convene the technology transfer conference
within the required timeframe. Finally, although the EPA satisfied the requirement to conduct a
study of residual effects by performing a literature review of the health impacts of chemicals
remaining in meth labs, it did not transmit the required report to Congress.
According to EPA staff, the EPA has not been able to fully implement the Meth Act
requirements because EPA's authorized Meth Act funding of $3.5 million was never
appropriated. As a result, the EPA's work to meet the Meth Act's requirements has been funded
by resources redirected from other programs. From 2008 through January 2011, the EPA's
estimated total expenditures to address the Meth Act requirements, including personnel and
contract costs, were more than $1.1 million.
The EPA has no controls in place to track legislative requirements agencywide. The EPA relies
on its program offices to do so, but these program offices also do not have controls in place to
track all legislative requirements.
Unimplemented Recommendation
Recommendation 3: We recommend that the Associate Administrator for Congressional and
Intergovernmental Relations and the Associate Administrator for Policy develop internal controls
to ensure that legislative requirements are identified and tracked, and that their status is reported
to Congress as required.
Status: The EPA continues to work on developing a system to track Reports to Congress.
The Office of Congressional and Intergovernmental Relations is reviewing all bills
passed, and for any bill that has a report requirement, is providing a written notification
from the Deputy Assistant Administrator to the lead program office, with copies to the
Office of Policy and any other office that would have input on the preparation of the
report. The notification also reminds the lead program to enter each report into the Action
Development Process Tracker database, from which data will flow into the new Report
Congress view in the Scout database. The EPA's migration to Office 365 has delayed the
last step of entering the report due dates into the EPA's tracking system. This is due in
part to the Office of Policy's limited information technology resources being used to
manage and facilitate the migration to Office 365. The EPA's goal is for the data to be
entered into a single view in the Scout database. It anticipates completing the actions by
November 13, 2013. The original agreed-to completion date was September 30, 2012.
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Action Office:
OARM
Report Title: EPA's Contract Oversight and Controls Over Personal Computers Need
Improvement
Report No:	11-P-0705
Date Issued: 09/26/2011
Report Summary
The EPA paid the Customer Technology Solutions (CTS) contractor a total of $489,734 over an
11-month period for 3,343 seats—a standard seat includes a leased computer with accessories
and technical support—not ordered by the agency during the period. In addition, EPA did not
accept the contractor's monthly asset management performance self-rating for over a year
because of its nonperformance in properly accounting for and tracking assets. As a result, the
EPA should take action to reduce the minimum number of seats requirement in the CTS contract.
If the EPA does not make changes to the CTS contract, the EPA may pay as much as
$1.4 million more through September 2012 for personal computer standard seats that it did not
order, for a total potential payment of $1.9 million for seats not ordered.
Because the EPA did not safeguard and track personal computers to ensure proper replacement
and disposal in accordance with property regulations, it cannot account for 638 personal
computers valued at over $1 million. The EPA did not know the status of these personal
computers, some of which may have been replaced under the CTS contract. EPA's Personal
Property Policy and Procedures Manual outlines requirements for property staff to ensure the
effective accountability, utilization and disposal of personal property. The EPA should improve
controls for updating data in the fixed assets database, and should retain property acquisition
documentation in accordance with retention requirements. In addition, the agency should have a
separation of duties in its property staff positions and consider assigning permanent property
positions.
Unimplemented Recommendation
Recommendation 2: We recommend the Assistant Administrator for Administration and
Resources Management update the property manual to require the separation of duties in
property staff positions and consider assigning permanent property positions throughout the
agency to ensure that there are safeguards over the EPA's assets.
Status: OARM made the requested revisions to the property manual. The draft manual is
under agency review. It anticipates the manual will be signed by senior management
before December 31, 2013. The original agreed-to completion date was February 29,
2012.
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Action Office:
OARM
Report Title: EPA Should Improve Timeliness for Resolving Audits Under Appeal
Report No.:	11-P-0687
Date Issued: 09/21/2011
Report Summary
The EPA's efforts to resolve over $55 million for audits under appeal in Regions 2 and 5 are not
efficient, effective or timely. During our audit, we found that:
•	Inadequate communications between audit follow-up coordinators and the EPA
personnel responsible for resolving audits under appeal have resulted in inaccurate
information in MATS.
•	Policies and procedures for addressing audits under appeal are not complete and
relevant; many of the policies for resolving audits under appeal are inconsistent.
•	The EPA does not adhere to its policies for timely resolution of audits under appeal; as of
September 2010, 17 of 30 audits under appeal had been in resolution for 10 to 21 years.
EPA Manual 2750 and the CFR, through 40 CFR 31.70, require that appeals be fully and fairly
considered and resolved in the earliest practicable timeframe, at the lowest level possible.
Because appeals are not being resolved timely, at least $17.3 million is not available to the
government. These funds could potentially be used to protect public health and the environment.
Unimplemented Recommendation
Recommendation 2: We recommend that the Assistant Administrator for Administration and
Resources Management ensure that the in-process revisions to the agency's Assistance
Administration Manual include:
a.	An update to the Office of Grants and Debarment "Closeout Policies Topics" webpage,
adding EPA Order 5700.6A2 and labeling the Closeout Policy for Grants and
Cooperative Agreements as "rescinded," "superseded," or "expired"
b.	A reference to the procedures in EPA Manual 2750 that are outlined in recommendation 1
c.	Uniform procedures for resolving recipient disputes arising from the agency's assistance
agreement audit determinations.
Status: The Office of Grants and Debarment will issue an Assistance Administration
Manual chapter incorporating the uniform procedures for resolving recipient disputes
arising from the agency's assistance agreement audit determinations and will post the
chapter, including the link to the revised Manual 2750, on its Intranet page. The office
has transitioned from using the Assistance Administration Manual and has replaced it
with the Assistance Agreement Almanac that went live on its Intranet site on June 25,
2013. The Almanac references the new audit appeals rule in Section 4.7.3 and hyperlinks
to the 2750 Audit Management Procedures Manual. The audit appeals rule will be issued
in first quarter of FY 2014. The original agreed-to completion date was June 30, 2012.
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Action Office:
OCFO
Report Title: EPA Needs Workload Data to Better Justify Future Workforce Levels
Report No.:	11-P-0630
Date Issued: 09/14/2011
Report Summary
The EPA has not collected comprehensive workload data or conducted workload analysis in
about 20 years. The EPA does not require program offices to collect and maintain workload data,
and the programs do not have databases or cost accounting systems in place to collect data on
time spent on specific mission-related outputs. Federal guidance and standards emphasize the
importance of planning work to determine staffing needs. OMB guidance states that agencies
should identify their workloads to help determine the proper workforce size, and federal
accounting standards require that agencies establish cost accounting systems to allow them to
determine resources consumed for work performed. Without sufficient workload data, program
offices are limited in their ability to analyze their workloads and justify resource needs, and the
EPA's Office of Budget must base budget decisions primarily on subjective justifications at a
time when budgets continue to tighten and data-driven decisions are needed.
Organizations of varying sizes and missions have used workload models for years to justify
resource needs. During our audit, we identified some basic concepts of workload modeling from
which the EPA could benefit. The EPA would need to tailor such concepts to its own mission,
structure and culture.
Unimplemented Recommendations
Recommendation 1: We recommend that the Chief Financial Officer conduct a pilot project
requiring EPA organizations to collect and analyze workload data on key project activities.
Status: OCFO is working closely with EPA's air and water programs and their lead
regions to refine and expand on FY 2011 pilot projects. OCFO is working to determine
the specifics of how the EPA organizations should collect and analyze workload data on
key project activities. OCFO created a workload analysis model for air and water
permitting programs and is conducting analyses of grant and Superfund cost recovery.
Action is delayed due to travel funding constraints and the government shutdown.
OCFO's plans to complete the actions by December 31, 2013. The original agreed-to
completion date was September 30, 2012.
Recommendation 2: We recommend that the Chief Financial Officer use information learned
from the pilot and the ongoing contracted workload study to issue guidance 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.
Status: OCFO is revising Resource Management Directive 2520, Administrative Control
of Appropriated Funds, to incorporate workload planning guidance. Due to continued
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staff turnover and other work priorities, the update to Resource Management Directive
2520 is expected to be completed by March 31, 2014. The original agreed-to completion
date was September 30, 2012.
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Action Office:
OARM
Report Title: EPA Has Not Fully Implemented a National Emergency Equipment Tracking
System
Report No.:	11-P-0616
Date Issued: 09/13/2011
Report Summary
Although the EPA spent $2.8 million as of October 2010 to develop and implement an
Emergency Management Portal (EMP) emergency equipment tracking module, the EPA has not
fully implemented the module, and the module suffers from operational issues. Our review of
allegations in a Hotline complaint found that:
•	The EPA does not fully use the EMP equipment tracking module because no EPA
office with overall authority has mandated its use.
•	The EPA has made no formal effort to assess functionality and cost effectiveness due
to its decision to perform such assessments only after fully implementing the EMP
equipment module.
•	The EMP equipment module is cumbersome and slow, and may not be the most
efficient and effective emergency equipment tracking alternative.
The EPA has guidance and policies that require the agency to develop and implement a plan for
a national equipment tracking system. Both the OMB and EPA require performance
measurement of such systems. However, the EPA has not fulfilled this requirement. In addition
to the $2.8 million it has already spent, the EPA plans to spend another $5.5 million over the
next 15 years on the EMP equipment module's maintenance. Further, the regions that are using
the module continue to maintain their own tracking systems, resulting in wasted resources.
Because the EPA has not fully implemented the EMP equipment module and the module is
cumbersome and slow, the EPA's ability to protect public health and the environment in the
event of a nationally significant incident may be impaired.
Unimplemented Recommendation
Recommendation 3: We recommend that the Deputy Administrator mandate that regions and
response teams employ the national tracking system the EPA decides to use for emergency
response equipment.
Status: The new system has been developed but it is not yet fully implemented. OARM
has been actively working toward acquiring an agency asset management system to
achieve the federal government "industry" standard since June 2010. A commercial off-
the-shelf software package with asset management functionality was purchased in
February 2012, with the intention of hosting it on the local Office of Administration
Services Information System. As a result of shifting priorities and reduced funding, the
corrective action completion date committed to in the previous audit response is no
longer achievable. OARM continues to be fully committed to implementing the
developed property system, but will not achieve deployment of the system until
January 31, 2015. The original agreed to completion date was May 31, 2012.
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Action Office:
OSWER
Report Title: Revisions Needed to National Contingency Plan Based on Deepwater Horizon
Oil Spill
Report No.:	11-P-0534
Date Issued: 08/25/2011
Report Summary
We received two Hotline complaints on the use of dispersants in response to the Deepwater
Horizon oil spill in the Gulf of Mexico. We reviewed the steps EPA took to analyze the
dispersant Corexit for inclusion on the National Contingency Plan (NCP) Product Schedule. We
also determined the EPA's role in the decision to use Corexit in the response. The OIG Office of
Counsel addressed a perjury allegation in one complaint.
We found that the EPA and the manufacturer of Corexit completed required steps to include
Corexit products on the NCP Product Schedule. However, the EPA has not updated the Product
Schedule since 1994 to include the most appropriate efficacy testing protocol. Subpart J of the
NCP identifies requirements a manufacturer must meet to include a product on the Product
Schedule, including efficacy results using the Swirling Flask Test. The EPA has considered
revising Subpart J to change efficacy testing procedures to the more reproducible Baffled Flask
Test. However, the EPA had not finalized the rulemaking before the Deepwater Horizon oil spill
occurred because of competing priorities and changes in management. If the EPA had updated
Subpart J, more reliable efficacy data may have been available during the oil spill.
Responders to the Deepwater Horizon oil spill could have used other dispersants, but not within
the applicable window of time designated by Addendum 2 to a directive issued by the EPA and
the Coast Guard. The EPA's involvement in the response included issuing Joint Directives to BP,
making operational decisions, and conducting additional dispersant testing. The EPA involved
senior officials in the response because (a) the agency was not prepared for the unprecedented
volume and duration of dispersant use and subsea application, and (b) additional clarity was
needed on roles and responsibilities in responding to a Spill of National Significance. The
involvement of senior EPA officials created confusion as to who at the EPA led response efforts
for dispersant use.
The OIG Office of Counsel did not find evidence supporting the perjury allegation.
We noted that EPA took proactive actions to make health and environmental data available on
the agency's website throughout the spill response. Also, EPA demonstrated proactive efforts to
improve emergency response plans.
Unimplemented Recommendations
Recommendation 1: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response develop appropriate NCP Subpart J testing revisions, including proceeding
with plans in place before the Deepwater Horizon oil spill, to incorporate the most appropriate
efficacy testing protocol. Develop an action plan with milestones for these and any other
necessary revisions and take steps to propose NCP Subpart J revisions.
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Status: The EPA is proposing regulatory revisions to the NCP's Subpart J testing
requirements. The Subpart J rule is currently awaiting transmittal to OMB. The proposed
rule incorporating NCP testing requirements is expected to appear in the Federal
Register. The original agreed-to completion date was August 30, 2012.
Recommendation 3: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response modify the NCP Product Schedule and contingency plans to include
additional information (such as testing on crude oil, subsurface dispersants application, volume
and duration limits, etc.) learned from the Deepwater Horizon oil spill response and use such
information to revise and update Area and Regional Contingency Plans.
Status: The EPA is proposing regulatory revisions to the Subpart J requirements for the
NCP Product Schedule and contingency planning elements. The revisions will address
chemical agent tests (such as dispersants) using crude oil; subsurface use of dispersants;
and quantity, location and duration of chemical agent use criteria. The Subpart J rule is
currently awaiting transmittal to OMB. The proposed rule incorporating NCP testing
requirements is expected to appear in the Federal Register. The original agreed-to
completion date was August 30, 2012.
Recommendation 6: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response review and analyze NCP Subpart J toxicity testing protocols to ensure that
emergency responders have the information necessary for appropriate subsurface dispersant use
for future oil spills.
Status: This issue is currently being addressed as part of the action to revise the
requirements for Subpart J toxicity testing and criteria for listing dispersants on the NCP
Product Schedule. When revisions to the Product Schedule requirements are complete,
the Office of Emergency Management (OEM) will work on revisions to the Selection
Guide and Technical Notebooks, which are made available to emergency responders, to
ensure the necessary information is available for subsurface dispersant use on future oil
spills. The Subpart J rule is currently awaiting transmittal to OMB. The proposed rule
incorporating NCP testing requirements is expected to appear in the Federal Register.
The original agreed-to completion date was August 30, 2012.
Recommendation 7: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response, as part of the action to review NCP Subpart J requirements, address the
need to capture and maintain dispersant manufacturer production capacities, equipment
requirements, and other necessary information to better prepare for future oil spills. Make this
information widely available to the response community.
Status: OEM is in the process of developing amendments to the requirements in
Subpart J of the NCP associated with the testing, listing and use of chemical agents,
including dispersants, on oil spills on the waters of the United States. The proposed
rulemaking containing the amendments has cleared Options Selection and is in the
workgroup package development state under the agency's Action Develop Process, in
compliance with the Administrative Procedures Act.
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One set of elements under development in the package is proposed regulatory language
that would require product manufacturers to include information on their production
capabilities and equipment requirements, with their submittal to the EPA to have their
product listed on the Product Schedule under Subpart J of the NCP.
OEM is also examining options on the frequency of updating this information and
mechanisms for making it readily available to the response community. The preferred
regulatory approach and options for collection and dissemination of the information, as
recommended by the OIG, will be clearly described in the proposed regulatory text and
preamble. OEM will seek public comment on the approach and options and will welcome
well-supported alternatives. The Subpart J rule is currently awaiting transmittal to OMB.
The proposed rule incorporating NCP testing requirements is expected to appear in the
Federal Register. The original agreed-to completion date was August 30, 2012.
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Action Office:
ORD
Report Title: Office of Research and Development Should Increase Awareness of Scientific
Integrity Policies
Report No.:	11-P-0386
Date Issued: 07/22/2011
Report Summary
We conducted this review to determine the process the EPA uses to address scientific/research
misconduct. Specifically, we sought to determine whether the EPA's ORD has controls to
address scientific integrity and research misconduct, and whether those controls are effective.
We found that ORD has internal controls that include policies, procedures, training and peer
review. However, ORD should improve how it evaluates the effectiveness of its policies and
procedures for scientific integrity and research misconduct. Currently, ORD does not test its
policies and procedures because ORD asserts that few reported instances of misconduct means
that it generally does not occur. However, few identified instances of research misconduct could
signal that staff lacks awareness of key criteria and reporting requirements necessary to identify
and report misconduct.
Unimplemented Recommendation
Recommendation 3: We recommend that the Assistant Administrator for Research and
Development continue working with the unions to update and implement the Principles of
Scientific Integrity E-Training. Changes to the course should include:
a.	Making the e-training mandatory for all ORD staff.
b.	Ensuring that the updated course contains real-life examples.
c.	Creating a system for linking to current contact information for reporting instances of
scientific integrity and research misconduct.
Status: The EPA's Scientific Integrity Committee is continuing efforts with unions to
standardize, update and implement the Principles of Scientific Integrity E-training. ORD
is working with the Office of the Science Advisor and the unions to name members of a
joint work group to design, develop and deliver an agency wide training course. The
original agreed-to completion date was September 30, 2012.2
2 Subsequent to the close of our review period, October 22, 2013, ORD notified us that this action was completed
prior to September 30, 2013. However, this was not reflected in MATS prior to October 22, 2013.
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Action Office:
OECA
Report Title: Agency-Wide Application of Region 7 NPDES Program Process Improvements
Could Increase EPA Efficiency
Report No.:	11-P-0315
Date Issued: 06/06/2011
Report Summary
Although Region 7 National Pollutant Discharge Elimination System (NPDES) Kaizen event
participants continued to follow up on the commitments and action items identified, no single
authority was responsible for tracking the process improvement outcomes. Also, the EPA did not
have a process to develop and track quantifiable results and outcomes from the event. Further,
the EPA encountered barriers involving scope, performance measures, implementation and
accountability when planning the Kaizen event. While the states and the EPA collaborated to
create guidance for Kaizen events, such as the lean starter kit and primer, the EPA did not, nor
was it required to, use them to assure that barriers were overcome in the execution of the Region
7 event.
The Administrator's January 2010 memorandum, "Our Top Priorities," as well as the EPA's
other recent and state initiatives, discusses the need to improve internal operations and/or
conduct more Kaizen events with the states to more efficiently protect the environment and
public health. The Region 7 Kaizen event for the NPDES program identified three process
improvements (resolution of technical issues and communication, permitting and enforcement
oversight reviews of states, and annual strategic planning) and one implementation action (data
collection and reporting) that can potentially be implemented in other regions. Agencywide
permitting process changes could result in better communication; time and cost savings in the
states; and avoidance of duplicate inspections, reviews and data reporting. Using lessons learned
from the Region 7 Kaizen event can increase the potential benefits achieved in future process
improvement efforts.
Unimplemented Recommendation
Recommendation 1: We recommend that the Deputy Administrator direct the Office of Water
and the Office of Enforcement and Compliance Assurance 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 NPDES
program, including consideration of the new approaches under the CWA of 1972 action
plan; and
d.	Fully implementing burden reduction initiatives identified during the event.
Status: OECA published the proposed NPDES electronic reporting rule in the Federal
Register on July 30, 2013. A 90-day public comment period began with the publication of
the rule. During this time period, OECA has been engaging in outreach presentations and
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webinars for interested parties. Should there be significant comments on the rule, OECA
is committed to issuing a supplemental notice, which will require additional OMB review
and a subsequent public comment period. Should a supplemental rule be required, OECA
anticipates the final rule would be published in May 2015. The original agreed-to
completion date was September 30, 2012.
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Action Office: OAR
Report Title: EPA Needs to Better Document Project Delays for Recovery Act Diesel
Emissions Reduction Act Grants
Report No:	11-R-0179
Date Issued: 03/28/2011
Report Summary
While the Diesel Emission Reduction Act project officers were aware of Recovery Act grant
project delays, they did not always document delays in the EPA's grants management system or,
in some cases, take action to reduce the impact of project delays. To prompt quicker action from
recipients on Recovery Act grants, the EPA had stated to OMB in March 2009 that all grants
would have an initial project period through September 30, 2010. The EPA's goal was to have
40 percent of the Recovery Act grant funds expended by September 30, 2010, which was met.
However, as of June 30, 2010, 49 grants, with a value of $101,437,442, had less than 10 percent
of the funds expended. Eighty-five percent of the grantees did not finish projects by the
completion date, and the EPA granted no-cost time extensions for all those grantees. In granting
the extensions, 3 of 15 grants we reviewed did not contain new timeframes for completing the
projects. The EPA guidance requires timeframes to be established, and timeframes can be used to
assess progress and reduce the impact of project delays.
Even though grant recipients reported project delays to the EPA in progress reports, in 10 of 15
cases reviewed, project officers did not document these delays in programmatic baseline
monitoring reports. Diesel Emission Reduction Act staff believed the delays were outside the
control of the recipients and that no-cost time extensions were the appropriate corrective action.
However, the EPA did not take sufficient action in some cases by establishing new milestone
dates and instituting corrective actions when approving grant extensions. Delayed projects may
result in recipients not completing projects within specified timeframes and delayed achievement
of Recovery Act objectives.
Unimplemented Recommendations
Recommendation 3: We recommend that the Assistant Administrator for Air and Radiation
ensure that project officers continuously document delays in baseline and advanced monitoring
reports for Recovery Act EPA Diesel Emissions Reduction Program grants. Update milestones
and institute corrective action plans when delays occur.
Status: Once the baseline monitoring programmatic report has been revised by OARM,
OAR will train project officers and grant specialists to use the form correctly to document
delays. OAR will work with the regions to update milestones when delays occur; plans
for corrective action will be used when avoidable delays occur. OAR is continuing to
perform baseline and advance monitoring for Recovery Act EPA Diesel Emissions
Reduction Program grants and documenting those activities in project officer files and
grants databases. As necessary, OAR is initiating corrective action plans through
consultation and coordination between the Office of Grants and Debarment, the Office of
General Counsel and OAR's regional partners. The anticipated completion date for these
actions is September 30, 2014. The original agreed-to completion date was December 31,
2011.
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Recommendation 5: We recommend that the Assistant Administrator for Air and Radiation
ensure that project officers, using the information in the recipient monitoring database, regularly
provide reports to management on progress of projects, and status of corrective action plans
until the Recovery Act grants are completed.
Status: OAR will oversee the monitoring database and the status of corrective action
plans. OAR will regularly collect information on the status of Recovery Act grants,
including the status of baseline monitoring and progress toward completion of projects.
This information will be provided to management on a regular basis until the Recovery
Act grants are completed. The anticipated completion date for these actions is
September 30, 2014. The original agreed-to completion date was December 31, 2011.
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Action Office:
OSWER
Report Title: EPA Needs an Agency-Wide Plan to Provide Tribal Solid Waste Management
Capacity Assistance
Report No.:	11-P-0171
Date Issued: 03/21/2011
Report Summary
This evaluation found that the EPA could not determine whether its efforts are assisting tribal
governments in developing the capacity to manage solid waste or reduce the risks of open
dumps in Indian country. The EPA's performance measures do not assess whether the
agency's efforts are effective in building solid waste management capacity in Indian country.
The EPA also lacks internal data controls to track the status of open dumps.
Further, the EPA does not have an agencywide plan that defines the roles and responsibilities of
the EPA program offices and regions. The EPA also lacks internal controls that hold these
offices accountable for providing consistent solid waste management assistance to tribes. The
lack of a single, agencywide plan results in poor coordination and limited oversight, and may
lead to an ineffective use of resources. As a result, the EPA cannot (1) ensure that consistent
solid waste management assistance is provided, (2) accurately determine the risks of open
dumps, or (3) determine whether efforts are effective nationwide.
Unimplemented Recommendations
Recommendation 1: We recommend that the Deputy Administrator develop and implement an
agencywide plan for providing consistent and effective tribal solid waste management capacity
assistance that is within the scope of the EPA's authority and responsibility.
Recommendation 2: We recommend that the Deputy Administrator require the agency-specific
plan include:
a.	Descriptions of the roles and responsibilities for the EPA program offices and the EPA
regions conducting solid waste management capacity assistance activities in Indian
country;
b.	Identification of the agency resources required for providing solid waste management
assistance activities;
c.	Performance measures, including both output and outcome measures, to track whether its
assistance is consistent and effective in developing solid waste management capacity and
reducing risks from open dumps in Indian country;
d.	Internal controls to ensure consistent data collection and consistent provision of waste
management capacity assistance to tribal clients nationwide;
e.	A process to ensure coordination between the EPA program offices and regions; and
f.	A timeline specifying when the activities and outcomes outlined in the plan are expected
to be accomplished.
Status: OSWER is in the process of finalizing the agencywide plan and is now
incorporating recent policy decisions made. It expects the plan to be finalized by
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November 15, 2013. The original agreed-to completion date was April 30, 2012.
(The corrective action applies to recommendations 1 and 2.)
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Action Office:
OARM
Report Title: EPA Needs Better Agency-Wide Controls Over Staff Resources
Report No.:	11-P-0136
Date Issued: 02/22/2011
Report Summary
The EPA does not enforce a coherent program of position management to assure the efficient
and effective use of its workforce. While some organizational elements have independently
established programs to control their resources, there is no agencywide effort to ensure that
personnel are put to the best use. Prior to April 2010, the EPA had the Position Management and
Control Manual, which required an agencywide program. However this manual was not enforced
and in April 2010 it was cancelled without replacement. According to the cancellation
memorandum, the manual was eliminated because OARM officials believed the EPA had other
mechanisms in place to appropriately manage and control its positions. However, the other
mechanisms do not provide similar effects, controls, or documentation. Without an agencywide
position management program, the EPA leadership lacks reasonable assurance that it is using
personnel in an effective and efficient manner to achieve mission results.
Unimplemented Recommendation
Recommendation 1: We recommend that the Assistant Administrator for Administration and
Resources Management establish an agencywide workforce program that includes controls to
ensure regular reviews of positions for efficiency, effectiveness, and mission accomplishment.
Status: OARM will submit the directive for final approval by September 30, 2013. The
original agreed-to completion date was September 15, 2012. Also, OARM will issue the
position management directive by September 30, 2013. The original agreed-to
completion date was September 30, 2012.
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Action Office:
OCFO
Report Title: EPA Needs to Strengthen Internal Controls for Determining Workforce Levels
Report No.:	11-P-0031
Date Issued: 12/20/2010
Report Summary
The EPA's policies and procedures do not include a process for determining employment levels
based on workload as prescribed by the OMB. Further, the EPA does not determine the number
of positions needed per mission-critical occupation using workforce analysis as required by the
Office of Personnel Management. These conditions occurred because the EPA has not developed
a workload assessment methodology and has not developed policies and procedures that require
identifying and reporting on the number of positions needed per mission-critical occupation. As a
result, the EPA cannot demonstrate that it has the right number of resources to accomplish its
mission. The Government Accountability Office and the EPA OIG have reported instances in
which personnel resources were not adequately considered and, consequently, offices
encountered delays or did not meet mission requirements.
The Office of Personnel Management noted that EPA's Human Capital Management Report
shows evidence that EPA's work is guided by human capital goals and objectives. However,
EPA's Office of Human Resources does not require that workforce planning results link to
EPA's strategic and performance goals. This condition occurred because the Office of Human
Resources has not clearly defined the reporting requirements needed. As a result, there is no
assurance that EPA's workforce levels are sufficient to meet the workload of the agency.
Unimplemented Recommendations
Recommendation 2-1: We recommend that the Chief Financial Officer amend the Resource
Management Directive 2520 and the annual planning and budget memoranda to require using
workload analysis to help determine employment levels needed to accomplish agency goals.
Status: OCFO is working to amend Resource Management Directive 2520 to fully
describe workload-planning needs. The revision of the directive has been delayed by
OCFO to March 14, 2014 due to continued staff turnover and increased workload
managing sequestered finances. The original agreed-to completion date was
September 30, 2012.
Recommendation 2-2: We recommend that the Chief Financial Officer require the agency to
complete a workload analysis for all critical functions to coincide with developing the strategic
plan.
Status: OCFO continues to update the OIG on the progress and scope changes of the
workload analysis. The last update was August 23, 2013. The original agreed-to
completion date was September 30, 2012.
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Action Office: OECA
Report Title: ECHO Data Quality Audit—Phase II Results: EPA Could Achieve Data Quality
Rate with Additional Improvements
Report No.:	10-P-0230
Date Issued: 09/22/2010
Report Summary
We sought to assess the quality of key data elements reported through the Enforcement
Compliance and History Online (ECHO) website. KPMG, LLP, performed the review. The EPA
mandates that data elements reported to the public through the ECHO Website have a 95 percent
accuracy rate. KPMG found a 91.5 percent data accuracy rate for key data elements entered into
two primary ECHO source systems: the legacy Permit Compliance System and the newer
Integrated Compliance Information System - NPDES. Although the 91.5 percent data quality
rate is close to the EPA's goal, the EPA and the state environmental offices could take additional
steps to increase the quality of data reported through the ECHO website.
Unimplemented Recommendation
Recommendation 5: We recommend that the Director, Office of Compliance, within the Office
of Enforcement and Compliance Assurance, complete new rules that require states to report
minor facility data.
Status: OECA agreed to publish the final NPDES electronic reporting rule. OECA
published the proposed NPDES electronic reporting rule in the Federal Register on
July 30, 2013. A 90-day public comment period began with the publication of rule.
During this time period, OECA has been engaging in outreach presentations and
webinars for interested parties. Should there be significant comments on the rule, OECA
is committed to issuing a supplemental notice, which will require additional OMB review
and a subsequent public comment period. Should a supplemental rule be required, OECA
anticipates the final rule would be published in May 2015. The original agreed-to
completion date was September 30, 2012.
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Action Office:
OAR
Report Title: Key Activities in EPA's Integrated Urban Air Toxics Strategy Remain
Unimplemented
Report No.:	10-P-0154
Date Issued: 06/23/2010
Report Summary
This report evaluated the public health risk from exposure to air toxics which is a concern in
many urban areas. Accordingly, we conducted this evaluation to assess how the EPA tracks
progress toward the goals of its 1999 Integrated Urban Air Toxics Strategy. The CAA
Amendments of 1990 required the EPA to develop this strategy to reduce public health risks
from air toxics emissions in urban areas.
We found that the EPA has not implemented key requirements of CAA Section 112(k), including
developing emission standards for all area (smaller) source categories and submitting a second
report to Congress (due in 2002) identifying urban areas that continue to experience significant
public health risks from air toxics exposures. In addition, 10 years after issuing the 1999
Integrated Urban Air Toxics Strategy, the EPA has still not implemented key activities outlined
in the Strategy. For example, the EPA has not established baseline risk data to measure progress
in reducing air toxics risks. As a result, the EPA has not tracked progress in meeting the
strategy's goals.
Further, although the EPA determined in 2001 that a risk-based program is necessary to meet
the goals of the strategy, the EPA has not yet determined whether it has the statutory authority
to require state and local agencies to implement such a program. Many state and local agencies
do not have their own risk-based programs, and about half of the states and several local
agencies have laws preventing them from implementing environmental regulations stricter than
the EPA's regulations. Without the establishment of a minimum, federally required risk-based
program, we do not believe that all state and local agencies will implement programs to
adequately address the health risks from urban air toxics.
The EPA's last risk assessment, based on 2002 data, estimated that 1 in every 28,000 people
could develop cancer from air toxics exposure, and that 2 million Americans live in areas with
lifetime cancer risks from air toxics in excess of 1 in 10,000. Given the length of time since the
Integrated Urban Air Toxics Strategy was developed and the problems the EPA has encountered
in its implementation, the EPA should reassess and update its approach to addressing urban air
toxics.
Unimplemented Recommendations
Recommendation 2-1: We recommend that the Assistant Administrator for Air and Radiation
develop and submit the required second Urban Air Toxics Report to Congress by the end of
FY 2010. This report should:
a. Disclose the current status and progress made in meeting Section 112(k) of the Clean Air
Act;
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b.	Identify the urban areas that continue to experience high or unacceptable health risks
from cancer and noncancer effects, and how the EPA plans to reduce risks in these areas;
c.	Address the major factors that have hindered implementation of the Integrated Urban Air
Toxics Strategy, and how the EPA plans to address these factors;
d.	Provide details on how the agency intends to meet the CAA Section 112(k) requirement
that at least 10 percent of Section 112 funds to go to state or local agencies to support
strategies to address air toxics emissions from area sources; and
e.	Disclose air toxics requirements that the agency is unable to meet through its current
authorities.
Status: OAR has developed the Urban Air Toxics report and is circulating it for review.
The review is expected to be completed by December 31, 2013. The original agreed-to
completion date was December 15, 2011.
Recommendation 2-2: We recommend that the Assistant Administrator for Air and Radiation
determine how the agency will measure progress in meeting the goals of the strategy. If the
Assistant Administrator determines that the development and maintenance of a 1990 or similar
baseline is not cost effective, the EPA should develop and inform Congress of the agency's
alternative measures for assessing its progress in meeting the intent of the statutory goals.
Status: OAR has developed the Urban Air Toxics report which also addresses this
recommendation. The report is circulating it for review. Review is expected to be
completed by December 31, 2013. The original agreed-to completion date was
September 15, 2011.
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Action Office:
OCSPP
Report Title: EPA Needs a Coordinated Plan to Oversee Its Toxic Substances Control Act
Responsibilities
Report No.:	10-P-0066
Date Issued: 02/17/2010
Report Summary
The EPA does not have integrated procedures and measures in place to ensure that new
chemicals entering commerce do not pose an unreasonable risk to human health and the
environment. We found that the EPA's New Chemicals Program had limitations in three
processes intended to identify and mitigate new risks - assessment, oversight and transparency.
The program is limited by an absence of test data and a reliance on modeling because the Toxic
Substances Control Act does not require upfront testing as part of a Premanufacture Notice
submission. Premanufacture Notice submitters are required to submit health and safety data in
their possession and a description of data known to or reasonably ascertainable by the submitter
at the time of its submission. Nonetheless, the majority of Premanufacture Notice submissions do
not include chemical toxicity or environmental fate data. Oversight of regulatory actions
designed to reduce known risks is a low priority, and the resources allocated by the EPA is not
commensurate with the scope of monitoring and oversight work. In addition, the EPA's
procedures for handling confidential business information requests are predisposed to protect
industry information rather than to provide public access to health and safety studies.
The EPA's Office of Pollution Prevention and Toxics and OECA's respective performance
measures for managing risks from new chemicals do not accurately reflect program performance
in preventing risk, nor do they assure compliance. In cases where full information does not exist
or analyses are limited, the Office of Pollution Prevention and Toxics reports the new chemicals
as not having risk, while the limitations in the measure are not disclosed. OECA's performance
measure is not outcome based; rather, the measure tracks program activities.
Unimplemented Recommendation
Recommendation 2-5: We recommend that the Assistant Administrator for Chemical Safety
and Pollution Prevention 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.
Status: OCSPP will propose regulation(s) to establish sunsetting provisions for
confidential business information claims. On January 15, 2013, OCSPP informed the
OIG of the delay in completing this corrective action due to further senior management
discussions leading to a decision to develop a more complex and comprehensive rule.
OCSPP expects the publication of the proposed rule by January 31, 2015. The original
agreed-to completion date was January 31, 2012.
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Action Office:
OCFO
Report Title: Audit of EPA's Fiscal 2009 and 2008 (Restated) Consolidated Financial
Statements
Report No.:	10-1-0029
Date Issued: 11/16/2009
Report Summary
We rendered an unqualified opinion on the EPA's consolidated financial statements for
FYs 2009 and 2008 (restated), meaning that they were fairly presented and free of material
misstatement. The OIG noted the following three material weaknesses:
•	The EPA understated accounts receivable for FY 2008.
•	The EPA understated unearned revenue.
•	Improvement is needed in billing costs and reconciling unearned revenue for Superfund
state contract costs.
We also noted the following eight significant deficiencies:
•	The EPA misstated uncollectible debt and other related accounts.
•	The EPA needs to improve billing and accounting for accounts receivable.
•	Headquarters property items were not inventoried.
•	The EPA should improve its financial statement preparation process.
•	Unneeded funds were not deobligated timely.
•	Improvement is needed in managing data system user accounts.
•	Las Vegas Finance Center needs improved physical access controls.
•	CTS equipment needs improved planning.
We noted one noncompliance issue, involving the EPA's need to continue efforts to reconcile
intra-governmental transactions.
Unimplemented Recommendations
Recommendation 27: We recommend that the Office of the Chief Financial Officer 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.
Status: The Office of Financial Management's Financial Policy and Planning staff and
Office of Technology Solutions (with Applications Management Staff) planned to take
action to develop and implement a procedure, linked to OEI's System Life Cycle
Management procedures, that ensures all new financial management systems and those
undergoing upgrades include a system requirement for the fielded system to include an
automated control to enforce separation of duties. OCFO has made significant strides to
complete corrective actions associated with the segregation of duties issue noted during
the FY 2009 financial statement audit. The agency has implemented a segregation of
duties policy, and detective system controls do exist. However, the EPA has not
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implemented automated separation of duties controls throughout the entire Compass
financial management system to enforce separation of duties. OCFO has not provided a
new planned completion date to implement these automated controls across the entire
Compass financial management system. The original agreed-to completion date was
September 30, 2010.
Recommendation 32: We recommend that the Office of the Chief Financial Officer 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 systems have an automated control in place to provide a failsafe that links to the Human
Resources data to identify and disable terminated/transferred personnel in the system in a timely
manner.
Status: OCFO has not implemented any corrective actions in response to this
recommendation. OCFO has indicated that no further actions have been taken due to
reevaluation of the business case for a new human resources system. The original agreed-
to completion date was September 30, 2010.
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Action Office: OECA
Report Title: EPA Oversight and Policy for High Priority Violations of Clean Air Act Need
Improvement
Report No.:	10-P-0007
Date Issued: 10/14/2009
Report Summary
High Priority Violations (HPVs) were not being addressed in a timely manner because regions
and states did not follow the HPV policy, the EPA headquarters did not oversee regional and
state HPV performance, and regions did not oversee state HPV performance. According to EPA
data, about 30 percent of state-led HPVs and about 46 percent of EPA-led HPVs were
unaddressed after 270 days. This can result in significant environmental and public health
impacts.
Regions are not ensuring that sources receive notices of violation within 60 days. None of the
regions reviewed held meetings with their states after HPVs had been unaddressed for 150 days
to discuss case strategy. Several states addressed HPVs with informal rather than formal
enforcement actions. EPA headquarters did not use the "Watch List" and trend reports to assess
performance of regions and states in addressing HPVs. The regions did not ensure that state-led
HPVs are addressed in a timely manner by taking over delinquent state HPV cases. Regions also
did not always ensure that states entered accurate data into the Air Facility System database.
Although EPA noted some of these deficiencies, it has not developed a plan to correct them.
The EPA regions reviewed generally conducted status meetings with states to discuss HPVs.
Also, the EPA implemented the State Review Framework as a means to better evaluate the
performance of its CAA compliance and enforcement programs.
Unimplemented Recommendation
Recommendation 2: We recommend that the Assistant Administrator for Enforcement and
Compliance Assurance revise the HPV policy to (1) require specific oversight steps and
remedies for HPVs that are unaddressed after 270 days, including taking over selected state HPV
cases that have not been addressed in a timely manner, especially cases in states that have no
administrative process; and (2) include a section detailing the roles and responsibilities of the
EPA headquarters and regions, the states, and local agencies.
Status: OECA is working with a number of state partners and completed work on a
revised policy on August 30, 2013. However, the agency believes it is important and
appropriate to provide all states the opportunity to comment on the policy and to suggest
changes before formal issuance of the policy. The EPA plans to formally issue the
revised policy in March 2014. Once the HPV Policy revision is final, OECA will work
with regions and states on an HPV management report that adapts to the new policy and
that will serve as the tool for the EPA and states to use to manage the HPV process. The
HPV management report will be provided no later than June 30, 2014. The original
agreed-to completion date was September 1, 2012.
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Action Office:
OARM
Report Title: Review of Hotline Complaint on Employee Granted Full-Time Work-at-Home
Privilege
Report No.:	10-P-0002
Date Issued: 10/07/2009
Report Summary
We found an unauthorized, full-time work-at-home arrangement that has existed for 9 years and
allows a National Enforcement Training Institute employee to work from home in Ohio instead
of an office in Washington, D.C. The employee and position were originally located in the
Washington area and the employee later moved as the result of a spouse transfer. In our opinion,
the National Enforcement Training Institute's actions are for the benefit of a single employee as
opposed to being primarily in the interest of the government, and this action was not equitably
provided within the institute. The EPA has no established or consistent policy, procedure or
criteria for granting full-time work-at-home privilege, and appears to be preferentially available
to only a few employees. Neither OARM nor the National Enforcement Training Institute has
any written documentation showing the government interest in or appropriateness of making this
arrangement, or that senior OARM officials approved this action.
Office of Human Resources personnel (Associate Deputy Director of Program Management and
Communications and the agency telework coordinator) stated that the EPA became aware of
similar arrangements due to research it performed for an unrelated court case. OARM raised
concerns about equity in such arrangements, and believes this must be brought under control.
To date, OARM has not corrected this situation.
Unimplemented Recommendations
Recommendation 1: We recommend that the Deputy Administrator assign responsibility for
authorizing all non-OARM geographically separate duty station changes to the Assistant
Administrator for OARM.
Recommendation 2a: We recommend that the Assistant Administrator for Administration and
Resources Management 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.
Status: OARM has been working to address the official worksite designation issue for
situations where employees are assigned to geographically separate locations. As OARM
anticipated, it has taken time to build the considerable cross program and regional support
that it believes is needed to effectively implement the final policy. OARM informed the
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OIGthat it continues to aggressively coordinate across the agency's program and
regional offices to develop and finalize the telework policy that formalizes procedures for
changing an employee's duty station to a location geographically separate from the
position of record. OARM expects to complete the final telework policy by July 1, 2014.
The policy will include a directive clearance review process and the agency negotiation
process with the unions. The agency continues to be in the negotiation process with the
unions. The original agreed-to completion date was June 20, 2011. (The corrective
actions apply to recommendations 1 and 2a.)
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Action Office:
OARM
Report Title: EPA Plans for Managing Counter Terrorism/ Emergency Response Equipment
and Protecting Critical Assets Not Fully Implemented
Report No.:	09-P-0087
Date Issued: 01/27/2009
Report Summary
On April 26, 2006, we issued an audit report, EPA Needs to Better Implement Plan for
Protecting Critical Infrastructure and Key Resources Used to Respond to Terrorist Attacks and
Disasters. It contained findings and recommendations for improving the implementation of the
initiatives in the EPA's Critical Infrastructure and Key Resources Protection Plan and managing
its Counter Terrorism/Emergency Response equipment. A follow-up audit was warranted, given
the nature and importance of the prior report recommendations. We conducted this audit to
determine whether the EPA effectively implemented corrective actions to address findings and
recommendations in our previous report. The EPA has progressed in implementing the Counter
Terrorism/Emergency Response initiatives, but is behind schedule in implementing the Radiation
Ambient Monitoring System. The EPA has not fully implemented a national equipment tracking
system. Not having a functional national system to track and manage equipment may impair the
EPA's ability to protect public health and the environment in the event of another terrorist attack
or other nationally significant incident.
Unimplemented Recommendation
Recommendation 4-l(b): We recommend that the Assistant Administrators for Solid Waste and
Emergency Response and for Air and Radiation, in conjunction with the OCFO, review the
information in MATS for the prior audit and ensure it is accurate, current, and complete for the
remaining corrective actions to upgrade facility and hardware to analytical lab in Las Vegas,
Nevada.
Status: In the EPA's April 23, 2009, response to the final OIG audit report, OARM was
designated as the action official for the implementation of this recommendation. OARM
agreed to construct a new lab in Las Vegas. OARM has since reorganized its laboratory
structure and rather than constructing a new facility in Las Vegas, it is in the process of
relocating OAR's laboratory functions performed by the Radiation and Indoor
Environment Laboratory in Las Vegas to Montgomery, Alabama. The Facilities
Management and Services Division within OARM's Office of Administration has the
responsibility for the completion of this action. OARM's planned milestone date for the
relocation of the lab is April 30, 2015. The original agreed-to completion date was
June 30, 2011.
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Action Office: Region 2
Report Title: Environmental Justice Concerns and Communication Problems Complicated
Cleaning Up Ringwood Mines/Landfill Site
Report No.:	2007-P-00016
Date Issued: 04/02/2007
Report Summary
We did not find evidence to indicate that the EPA's actions or decisionmaking to investigate or
remediate environmental conditions at the Ringwood Mines/Landfill site were affected by the
area's racial, cultural or socioeconomic status. However, residents living near the site continue to
believe they were unfairly treated because of their racial makeup and socioeconomic status.
Several residents believe their health was adversely affected by exposure to site contamination.
Ringwood residents said that multiple cleanups at the site beginning in 1987, and a lack of
effective communication with EPA Region 2, contributed to this perception. Additionally,
residents believe that EPA is pursuing the current activity because of outside pressures. Region 2
plans to address environmental justice concerns by cleaning up the site.
Problems with communications and relationships impeded effective cooperation between EPA
and residents. Although Region 2 has increased its community relations efforts at the site, the
new community relations plan being prepared must address these impediments.
Unimplemented Recommendation
Recommendation 2-1: We recommend that the Regional Administrator, Region 2, address the
Ringwood community's perception of unfair treatment and concerns regarding completely
cleaning up the site by directing his staff to ensure that the new record of decision includes a
detailed comparison of current and prior site investigations and cleanups.
Status: Region 2 presented its remedy for the Ringwood site to the National Remedy
Review Board on June 25, 2013. Region 2 allowed for time to address possible concerns
from the National Remedy Review Board review and issued to the public EPA's
proposed plan for the site on September 30, 2013. In anticipation of substantial public
comment on the proposed plan, Region 2 expects to issue the Record of Decision for the
site by June 30, 2014. The original agreed-to completion date was June 30, 2012.
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Action Office:
OSWER
Report Title: EPA Needs to Plan and Complete a Toxicity Assessment for the Libby
Asbestos Cleanup
Report No.:	2007-P-00002
Date Issued: 12/05/2006
Report Summary
In our limited review, we identified the following significant issues that we believe are critical to
a successful cleanup in Libby, Montana.
•	The EPA has not completed a toxicity assessment of amphibole asbestos necessary to
determine the safe level for human exposure; therefore, the EPA cannot be sure that the
Libby cleanup sufficiently reduces the risk that humans may become ill or, if ill already,
get worse.
•	The EPA's public information documents Living with Vermiculite and Asbestos in Your
Home are inconsistent about safety concerns.
Unimplemented Recommendation
Recommendation 1: We recommend that the EPA fund and execute a comprehensive
amphibole asbestos toxicity assessment to determine (1) the effectiveness of the Libby removal
actions, and (2) to determine whether more actions are necessary. The toxicity assessment should
include the effects of asbestos exposure on children. The EPA Science Advisory Board should
review the toxicity assessment and report to the OA and the Libby Community Advisory Group
whether the proposed toxicity assessment can sufficiently protect human health.
Status. The EPA's plan for the Libby Superfund site includes a human health risk
assessment which will address all areas of the Libby site (e.g., residential, commercial
and recreational areas, etc.). This human health risk assessment requires two components:
(1) a toxicological assessment of Libby Amphibole Asbestos being led by ORD in
collaboration with Region 8, and (2) a site-specific exposure assessment being conducted
by Region 8. Substantial progress has been made on both components. The draft
toxicological review for Libby Amphibole Asbestos was released to the public by the
EPA in August 2011. The EPA's Science Advisory Board provided their expert peer
review of the draft Integrated Risk Information System Toxicological Review for Libby
Amphibole Asbestos to the EPA Administrator on January 30, 2013. The EPA is
currently revising the draft toxicological review based on comments from the EPA
Science Advisory Board. In addition to document revisions, EPA is conducting further
analyses. Depending on the scope of the revisions, there may be a need for further public
comment/peer review. Thus, the schedule for completion remains highly uncertain.
Laboratory toxicity studies for the Libby Amphibole Asbestos are being conducted by
EPA's National Health and Environmental Effects Research Laboratory. Work is
complete and results published for four of seven studies. Laboratory work continues for
the remaining studies, which are fully funded and expected to be complete in 2014.
A final report summarizing the laboratory toxicity research is anticipated to be completed
by September 30, 2015. The original agreed-to completion date was September 30, 2012.
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Action Office:	OCFO
Report Title:	EPA Can Better Manage Superfund Resources
Report No.:	2006-P-00013
Date Issued:	02/28/2006
Report Summary
We provide answers to congressional questions about the EPA's Superfund program
expenditures. We also identify numerous opportunities for the EPA to more effectively manage
its existing Superfund resources and its program, and direct more resources to cleanup. The EPA
needs to overcome challenges in accounting for Superfund resources, understanding the
program's resource needs, and decentralized management of the Superfund program.
Several obstacles have prevented the EPA from efficiently and effectively managing the
Superfund program for performance and adequately accounting for Superfund resources. The
EPA has been unable to allocate and manage Superfund resources for cleanup as efficiently and
effectively as possible because of the way the agency accounts for program resources, manages
by functions, supplements the program with other funds, relies on an outdated workload model,
and maintains unliquidated Superfund obligations and funds in special accounts. Closely aligning
offices that support the Superfund program and that produce program performance and cost data
have been limited because the EPA disperses the responsibility for allocating and managing
program resources.
Unimplemented Recommendation
Recommendation 2-3: We recommend that the EPA should agree to define costs in a manner
that supports management decision making and improve their accounting of such resources to
maximize achieving program goals.
Status: OCFO will update the Funds Control Manual to describe the use of the Superfund
Cost Recovery Package Imaging and On-Line System in tracking all Superfund site
cleanup-related costs. As of September 30, 2012, the updated Funds Control Manual was
in the review process. After the agency review is completed, the manual will be sent to
OMB for final approval. The anticipated completion date is March 31, 2014. The original
agreed-to completion date was October 31, 2011.
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Action Office:
OECA
Report Title: Limited Knowledge of the Universe of Regulated Entities Impedes EPA's Ability
to Demonstrate Changes in Regulatory Compliance
Report No.:	2005-P-00024
Date Issued: 09/19/2005
Report Summary
We found that OECA has limited knowledge of the diverse regulated universe for which it
maintains responsibility. OECA has not updated its universe table since generating it in 2001,
even though some universe figures for reviewed program areas have changed substantially. The
EPA has used the 2001 table as a source for describing the size of its regulated universe in public
documents. Various data quality issues impact OECA's ability to adequately identify the size of
its regulated universe and associated compliance information. OECA concentrates most of its
regulatory activities on large entities and knows little about the identities or cumulative impact of
small entities. OECA cannot effectively use universe figures to assist with its regulatory
activities. OECA does not develop programmatic compliance information, adequately report on
the size of the universe for which it maintains responsibility, or rely on universe figures to assist
with planning.
OECA's limited universe knowledge prevents it from determining overall compliance levels in
five of the six regulatory program areas we reviewed. This hinders OECA's ability to generate
valid programmatic compliance information and effectively determine program success. In
addition, OECA lacks adequate transparency in publicly reporting some currently available
compliance information.
Unimplemented Recommendation
Recommendation 2-4: We recommend that the Assistant Administrator for Enforcement and
Compliance Assurance 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 the 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.
Status: OECA published the proposed NPDES electronic reporting rule in the Federal
Register on July 30, 2013. A 90-day public comment period began with the publication of
rule. During this time period, OECA has been engaging in outreach presentations and
webinars for interested parties. Should there be significant comments on the rule, OECA
is committed to issuing a supplemental notice, which will require additional OMB review
and a subsequent public comment period. Should a supplemental rule be required, OECA
anticipates the final rule would be published in May 2015. The original completion date
for the corrective action was September 30, 2012.
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Action Office:
OAR
Report Title: Substantial Changes Needed in Implementation and Oversight of
Title V Permits If Program Goals Are To Be Fully Realized
Report No:	2005-P-00010
Date Issued: 03/09/2005
Report Summary
Our analysis identified concerns with five key aspects of Title V permits, including (1) permit
clarity, (2) statements of basis, (3) monitoring provisions, (4) annual compliance certifications,
and (5) practical enforceability. Collectively, these problems can hamper the ability of the EPA,
state and local regulators, and the public to understand what requirements sources are subject to,
how they will be measured, and ultimately to hold sources accountable for meeting applicable air
quality requirements. Factors such as extensive use of incorporation by reference; failure to fully
cite applicable regulations; complex permit format; and lack of detail in source requirements for
testing, monitoring and reporting had a negative impact on permit clarity. Also, the practical
enforceability of some permits was limited by vague permit language and insufficient monitoring
provisions. Further the EPA's guidance is needed in each of these Title V permitting program
elements.
The EPA's oversight and guidance of Title V activities have resulted in some improvements in
Title V programs; however, areas of further improvement remain. Many Title V programs have
improved as a result of the EPA's issuing formal notices of deficiency, and through the EPA's
efforts to obtain commitment letters from selected state and local permitting authorities.
However, some of the EPA regions have been slow in issuing program evaluation reports for
permitting authorities within their respective regions, and have not responded to public petitions
against Title V permits in a timely manner. For example, of the 31 state and local agency
Title V evaluations completed, the EPA regions have only reported on 14 agencies. Several
stakeholders expressed a need for an increase in the EPA's guidance and oversight.
Unimplemented Recommendations
Recommendation 2-1: We recommend that the Assistant Administrator for Air and Radiation
develop and issue guidance or rulemaking on annual compliance certification content, which
requires responsible officials to certify compliance with all applicable terms and conditions of
the permit, as appropriate.
Status: Based on recommendations from the CAA Advisory Committee Task
Force on Title V Implementation, the Office of Air Quality Planning and Standards has
begun developing a guidance document that will include, among other topics, guidance
on compliance certifications. The guidance document is delayed because of the limited
resources being focused on Title V Permit Petitions, New Source Review rulemaking,
and Greenhouse Gas-related rulemaking. OAR plans to have the actions completed by
December 31, 2013. The original agreed-to completion date was August 30, 2011.
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Recommendation 2-3: We recommend that the Assistant Administrator for Air and Radiation
develop nationwide guidance or rulemaking, as appropriate, on the contents of statements of
basis, which includes discussions of monitoring, operational requirements, regulatory
applicability determinations, explanations of any conditions from previously issued permits that
are not being transferred to the Title V permit, discussions of streamlining requirements, and
other factual information, where advisable, including a listing of prior Title V permits issued to
the same applicant at the plant, attainment status, and construction, permitting, and compliance
history of the plant.
Status: OAR will work with the regions to disseminate information about the positions
the EPA has taken on statements of basis in response to citizen program and permit
petitions. OAR will also develop a plan for identifying and sharing with permitting
agencies those statements of basis that represent "best practices." This effort will be
included in guidance documentation for recommendation 2-1. The guidance document is
delayed because of the limited resources being focused on Title V Permit Petitions, New
Source Review rulemaking, and Greenhouse Gas-related rulemaking. OAR plans to have
the actions completed by December 31, 2013. The original agreed-to completion date was
August 30, 2011.
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Action Office:
OECA
Report Title: State Enforcement of Clean Water Act Discharges Can Be More Effective
Report No.:	2001-P-00013
Date Issued: 08/14/2001
Report Summary
The objective of the audit was to determine whether state enforcement of CWA discharge
programs protect human health and the environment. This audit resulted from concerns over the
effectiveness of state enforcement programs. The OIG believes that state enforcement programs
could be much more effective in deterring noncompliance with discharge permits and,
ultimately, improving the quality of the nation's water. EPA and the states have been successful
in reducing point source pollution since the CWA passed in 1972. However, despite tremendous
progress, nearly 40 percent of the nation's assessed waters are not meeting the standards states
have set for them. The state enforcement strategies we evaluated needed to be modified to better
address environmental risks, including contaminated runoff. Contaminated runoff, including
agricultural and urban runoff, was widely accepted as causing the majority of the nation's
remaining water quality problems. Although many sources of contaminated runoff were
regulated, some were not. OECA had set national enforcement priorities for urban and
agricultural runoff, including storm water dischargers, sewer overflows, and concentrated animal
feeding operations. However, its core program and monitoring systems have emphasized major
industrial facilities and larger sewage treatment plants.
Unimplemented Recommendations
Recommendation 3-1: We recommend that the Assistant Administrator for Enforcement and
Compliance Assurance make modernizing the Permit Compliance System a high priority.
Further, ensure that future systems: (a) require electronic submission and evaluation of
self-monitoring reports for all dischargers, including minor facilities and storm water; and
(b) track storm water permits, inspections, compliance rates, and enforcement actions.
Recommendation 3-2: We recommend that the Assistant Administrator for Enforcement and
Compliance Assurance 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.
Status: OECA published the proposed NPDES electronic reporting rule in the Federal
Register on July 30, 2013. A 90-day public comment period began with the publication of
rule. During this time period, OECA has been engaging in outreach presentations and
webinars for interested parties. Should there be significant comments on the rule, OECA
is committed to issuing a supplemental notice, which will require additional OMB review
and a subsequent public comment period. Should a supplemental rule be required, OECA
anticipates the final rule would be published in May 2015. The original completion date
for these corrective actions was September 30, 2012. (The corrective action applies to
recommendations 3-1 and 3-2.)
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Part Two:
Unimplemented EPA Recommendations With
Future Planned Completion Dates
Action Office:	OARM and OSWER
Report Title:	EPA Should Increase Fixed-Price Contracting for Remedial Actions
Report No.:	13-P-0208
Date Issued:	03/28/2013
Recommendations
Recommendation 1: We recommend that the Assistant Administrator for the Office of
Administration and Resources Management:
a. Require that written acquisition plans for future cost-reimbursement Remedial Action
Contract contracts be approved by the Head of the Contracting Activity.
Planned Corrective Actions: OARM and OSWER plan to have a policy outlining the
governance structure for Acquisition Plan review and approval, including establishment
of a Contract Review Board.
Agreed-to Completion Date: December 31, 2013
b. For current cost reimbursement Remedial Action Contract contracts, at the end of the
base period, require written acquisition plans be prepared and approved by the Head of
the Contracting Activity
Planned Corrective Action: Once the governance structure is in place, strategy
development with regard to existing contract off-ramps and transitions to any new
vehicles is anticipated to commence.
Agreed-to Completion Date: March 31, 2014
Recommendation 2: We recommend the Assistant Administrators for both the Office of
Administration and Resources Management and the Office of Solid Waste and Emergency
Response 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.
Planned Corrective Actions: OARM and OSWER plan to award Superfund Multiple
Award Contracts on September 30, 2014. Metrics for evaluating and tracking Remedial
Action Contract requirements in terms of competition, contract type, etc. will be
developed as part of the implementation of the Remedial Action Contract, and collection
of data will commence.
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Agreed-to Completion Date: September 30, 2014
Recommendation 3: We recommend the Assistant Administrators for both the Office of
Administration and Resources Management and the Office of Solid Waste and Emergency
Response, 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.
Planned Corrective Action: OARM and OSWER will provide training to both
Superfund program and contracting staff. The training will include how to document the
analysis leading up to the contract type selection.
Agreed-to Completion Date: November 30, 2013
Recommendation 4: We recommend the Assistant Administrators for both the Office of
Administration and Resources Management and the Office of Solid Waste and Emergency
Response 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 Corrective Action: OARM and OSWER anticipate any resource alignment or
requirements resulting from the Centers of Expertise and Remedial Action Contract will
be identified by September 30, 2014. How any alignment or requirement needs will be
implemented is subject to budget and other resource constraints.
Agreed-to Completion Date: September 30, 2014
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Action Office: Region 7
Report Title: Review of Hotline Complaint Regarding Residential Soil Contamination in
Cherryvale, Kansas
Report No.: 13-P-0207
Date Issued: 03/28/2013
Recommendations
Recommendation 1: We recommend that the Regional Administrator, Region 7, review all site
records, including logbooks, to determine whether all imminent and substantial endangerment to
public health at the National Zinc Company site was identified and addressed. To support the
region's determination:
a.	Revise or prepare an addendum to the Removal Action Summary Report. Provide any
logbook pages, field sheets, site sketches, corrections, and any other missing
documentation needed to provide a complete and accurate account of all properties
identified, addressed and excavated during the removal action.
b.	Fully document and timely communicate any actions taken in response to issues
identified in this report to the public.
Planned Corrective Actions: Region 7 agreed to update the Comprehensive
Environmental, Response, Compensation and Liability Act site file by adding the log
books and property tables, and preparing an addendum to the Removal Action Summary
Report. In updating the file, should additional actions at the site be deemed necessary,
Region 7 will fully document and timely communicate any issues with the public.
Agreed-to Completion Date: December 31, 2013
Recommendation 2: We recommend that the Regional Administrator, Region 7, as needed,
work with the Kansas Department of Health and Environment to ensure appropriate action is
taken to respond to any imminent and substantial endangerment to public health at the National
Zinc Company site.
Planned Corrective Actions: Region 7 agreed to update the site file, as noted in
recommendation 1, should additional actions at the site be deemed necessary. Region 7
will work with the Kansas Department of Health and Environment. In accordance with
the National Contingency Plan, Region 7 will continue to coordinate with its state
counterparts.
Agreed-to Completion Date: December 31, 2013
Recommendation 3: We recommend that the Regional Administrator, Region 7, document the
costs to develop and implement the actions in recommendations 1 and 2.
Planned Corrective Action: Region 7 agreed to document costs incurred in responding
to recommendations 1 and 2.
Agreed-to Completion Date: December 31, 2013
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Action Office: Region 10
Report Title: Audit of American Recovery and Reinvestment Act-Funded Cooperative
Agreement 2S-96099601 Awarded to the Idaho Department of Environmental
Quality
Report No.:	13-R-0206
Date Issued: 03/28/2013
Recommendations
Recommendation 3: We recommend that the Regional Administrator, Region 10, 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).
Recommendation 4: We recommend that the Regional Administrator, Region 10, require Idaho
Department of Environmental Quality to update its policies and procedures to ensure that
they address:
a.	Bid proposal certification of independent price determination language as required by
40 CFR 35.6550(b) (3).
b.	10 year record retention period as required by 40 CFR 35.6705.
c.	Accident and catastrophic loss insurance as required by 40 CFR 35.6590 (b).
Planned Corrective Actions: Region 10 agreed to pursue a cooperative agreement-
specific waiver from requirement under 40 CFR Part 35.6590(b). Once approved, it will
provide a copy of the waiver to the OIG and Idaho Department of Environmental Quality.
Region 10 will instruct the Idaho Department of Environmental Quality in writing to not
require their contractors to acquire accident and catastrophic loss insurance, pending the
waiver determination.
Agreed-to Completion Date: January 1, 2014
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Action Office:
OA
Report Title: The EPA Needs to Improve Management of Its School Environmental Health
Efforts
Report No.:	13-P-0201
Date Issued: 03/27/2013
Recommendations
Recommendation 1: To improve management of the EPA's school environmental health
efforts, the Deputy Administrator should fulfill the requirement of Energy Independence and
Security Act to report to Congress all activities carried out under the Healthy High-Performance
Schools subtitle.
Planned Corrective Action: The agency will work to expedite internal review of report
to Congress and submit report to OMB.
Agreed-to Completion Date: March 31, 2013 (corrective action will be considered past
due as of March 31, 2014)3
Recommendation 2: The Director of the Office of Children's Health Protection should develop
implementation guidelines and management controls that specify how:
a.	The Office of Children's Health Protection will manage the adoption and implementation
of the newly developed Clean Green and Healthy Schools Vision, Goals, Objectives and
Activities document, and the Clean Green and Healthy Schools Regional FY 2013
Developmental Measures document.
b.	The Office of Children's Health Protection will continue to craft realistic measures
during FY 2013-2014.
Planned Corrective Action a: The Office of Children's Health Protection will
develop an implementation plan to manage the adoption of the visions, goals
and objectives and Clean Green and Healthy Schools Regional FY 2013
developmental measures.
Agreed-to Completion Date: June 30, 2013 (corrective action will be considered past
due as of June 30, 2014)
Planned Corrective Action b: The Office of Children's Health Protection schools
coordinator will continue to work with regional school coordinators to implement
adoption of realistic measures for FY 2014.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
3 Subsequent to the close of our review period, October 22, 2013, OA notified us that all actions associated with
report 13-P-0201 were completed prior to September 30, 2013. However, this was not reflected in MATS prior to
October 22, 2013.
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Recommendation 3: The Director of the Office of Children's Health Protection should develop
regional implementation guidelines and planning requirements for the Clean Green and Healthy
Schools initiative. These guidelines should:
a.	Include requirements for each region to develop an implementation plan that is
consistent with the measures, strategies, and expected outcomes identified in the Clean
Green and Healthy Schools Regional FY 2013 Developmental Measures document.
b.	Specify how Clean Green and Healthy Schools initiative staff will coordinate better with
internal EPA and external partners, taking into account recent changes in program status
and funding.
c.	Specify how Clean Green and Healthy Schools initiative staff will collect data, determine
the programmatic success of the initiative, and modify the program to meet customer
needs.
Planned Corrective Action a: The Office of Children's Health Protection will require
regions to develop implementation plans.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
Planned Corrective Action b: The Office of Children's Health Protection will partner
with OAR to use the recently formed School Health and Indoor Environments Leadership
Development schools stakeholder network group to engage internal and external partners.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
Planned Corrective Action c: The Office of Children's Health Protection will document
a basic data collection plan (process may vary by region).
Agreed-to Completion Date: March 31, 2013 (corrective action will be considered past
due as of March 31, 2014)
Recommendation 4: The Director of the Office of Children's Health Protection should develop
assessment criteria and conduct regular reviews of the EPA's overall school environmental
health programs to determine whether the EPA is providing sufficient regulatory and voluntary
program services to address the risks to children's health in schools.
Planned Corrective Action a: The Office of Children's Health Protection will assess
EPA's school environmental health programs through the existing cross cutting
fundamental strategy review process (twice per year).
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
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Planned Corrective Action b: The Office of Children's Health Protection will assess
EPA's school environmental health programs through the Office of Children's Health
Protection strategic plan (with regional measures) review process (end of the year).
Agreed-to Completion Date: December 31, 2013
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Action Office:
OARM
Report Title: Improvements Needed in EPA's Smartcard Program to Ensure Consistent
Physical Access Procedures and Cost Reasonableness
Report No.:	13-P-0200
Date Issued: 03/27/2013
Recommendations
Recommendation 3: We recommend that the Deputy Administrator establish one entity
responsible for implementing and overseeing the agency's smartcard program, including
physical and logical access.
Planned Corrective Action: OARM agreed that under direction of the Deputy
Administrator, relevant stakeholders will convene to determine the entity responsible for
implementing and overseeing the program.
Agreed-to Completion Date: June 30, 2013 (corrective action will be considered past
due as of June 30, 2014)
Recommendation 5: We recommend that the Assistant Administrator for Administration and
Resources Management enforce applicable guidelines pertaining to independent government cost
estimates, including:
a.	Preparing independent government cost estimates for all procurement actions in excess
of the Federal Acquisition Regulation (FAR) threshold.
b.	Adopting an official independent government cost estimate format that shall include the
name and signature of the preparer, the date prepared, and the signature of the approving
official.
c.	Establishing a process that Security Management Division can use to conduct and
document cost analyses of prior upgrades to ensure that future project costs are
reasonable.
d.	Establishing a requirement that Security Management Division staff involved with
preparing and reviewing independent government cost estimates certify that they have
read OAM's Independent Government Cost Estimates Manual and understand the
guidance.
Planned Corrective Actions: OARM agreed to review current policy to provide more
details and specific guidance on the circumstances under which an independent
government cost estimate is required, including at what threshold, as well as the content
and level of detail and documentation required, to ensure clarity and consistency of
independent government cost estimates, and also to ensure they serve as meaningful tools
in the acquisition process. In addition, OARM is developing a paperless acquisition
program to receive procurement documentation exclusively in electronic format through
the EPA's Acquisition System.
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AgreedS-to Completion Date: September 30, 2013 (corrective actions will be considered past
due as of September 30, 2014)4
4 On August 29, 2013, OARM notified the OIG that it is moving forward with the audit resolution process.
Progress on the agreed-to action is on hold.
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Action Office:
OARM and OSWER
Report Title: Improvements Needed in EPA Training and Oversight for Risk Management
Program Inspections
Report No.:	13-P-0178
Date Issued: 03/21/2013
Recommendations
Recommendation 5: We recommend that the Assistant Administrator for Administration and
Resources Management direct EPA Regions 2, 4, 7 and 10 to amend their contracts for
inspection support to include provisions requiring contractor inspectors to meet EPA Order
3500.1 training requirements.
Planned Corrective Action: OARM will collaborate with the regions to ensure the
contracts are modified.
Agreed-to Completion Date: October 31, 2013
Recommendation 7: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response coordinate with the Assistant Administrator for Enforcement and
Compliance Assurance 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.
Planned Corrective Action: OSWER will publish final guidance which specifies
minimum inspection scope and examples for various types of inspections to assist
regions in focusing their limited resources on the most significant issues at
facilities.
Agreed-to Completion Date: July 31, 2014
Recommendation 8: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response coordinate with the Assistant Administrator for Enforcement and
Compliance Assurance 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.
Planned Corrective Action: OSWER and OECA are working with the regions to
identify key components of a repository of inspections reports in order to better ensure
and assess the quality of Risk Management Program inspections. This repository system
will be developed by the end of FY 2014.
Agreed-to Completion Date: September 30, 2014
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Action Office:
OSWER
Report Title: Results and Benefits Information Is Needed to Support Impacts of EPA's
Superfund Removal Program
Report No.:	13-P-0176
Date Issued: 03/11/2013
Recommendations
Recommendation 1: We recommend that Assistant Administrator for Solid Waste and
Emergency Response define environmental results and benefits of the removal program, and
communicate these results and outcomes with existing removal goal outcomes.
Planned Corrective Actions: OSWER will continue: (1) to report the top 10
contaminants of concern each fiscal year, and will begin reporting on total volume for
removals beginning FY 2013; (2) to highlight program accomplishments in OSWER
publications, including the annual OSWER Accomplishments Report; (3) to work with
the regions and special teams to build a repository of removal success stories, which will
be used to communicate program benefits on the EPA website and other channels; and
(4) looking into delineating different types of removal completions to communicate
impacts.
Agreed-to Completion Date: September 30, 2014 (corrective actions will be considered
past due as of September 30, 2015)
Recommendation 2: We recommend that Assistant Administrator for Solid Waste and
Emergency Response implement system controls to: (a) ensure required Comprehensive
Environmental Response, Compensation, and Liability Information System data are entered and
completed; and (b) synchronize data between the Pollution Reports and the Comprehensive
Environmental Response, Compensation, and Liability Information System.
Planned Corrective Action: OSWER will notify the regions of any discrepancies in the
Comprehensive Environmental Response, Compensation, and Liability Information
System and synchronize data fields in the final Pollution Report to fields in the Superfund
Enterprise Management System. The Superfund Enterprise Management System will
replace the Comprehensive Environmental Response, Compensation, and Liability
Information System in FY 2014.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
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Action Office:
OCFO and OW
Report Title: Corrective Action Plan Needed in Order to Fully Comply With the
Improper Payments Elimination and Recovery Act
Report No.:	13-P-0175
Date Issued: 03/11/2013
Recommendations
Recommendation 2: We recommend that Assistant Administrator, Office of Water, require staff
to use the Program Evaluation Reports, in addition to the transaction testing worksheets, to
identify improper payments.
Planned Corrective Action: OW staff will use the Program Evaluation Reports, in
addition to the transaction testing worksheets, to identify improper payments reflected in
the final Agency Financial Report.
Agreed-to Completion Date: November 15, 2013
Recommendation 3: We recommend that Assistant Administrator, Office of Water, submit
State Revolving Fund improper payment totals to OCFO earlier in the reporting cycle to allow
OCFO the opportunity to perform quality checks on the data.
Planned Corrective Action: OW will provide OCFO with the improper payments
information it needs to report in the final Agency Financial Report earlier in the reporting
cycle.
Agreed-to Completion Date: September 1, 2013 (corrective action will be considered
past due as of September 1, 2014)
Recommendation 6: We recommend that the Chief Financial Officer include any payment that
does not account for credit for an applicable discount as an improper payment in the EPA's
FY 2013 Agency Financial Report.
Planned Corrective Action: OCFO will include improper payments as defined in their
updated standard operating procedures for improper payments.
Agreed-to Completion Date: November 15, 2013
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Action Office:
OCSPP and OCFO
Report Title: EPA is Not Recovering All Its Costs of the Lead-Based Paint Fees Program
Report No.:	13-P-0163
Date Issued: 02/20/2013
Recommendations
Recommendation 1: We recommend that Assistant Administrator for Chemical Safety and
Pollution Prevention 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.
Planned Corrective Action: OCSPP will update the 2009 Fees Rule following
completion of at least one 5-year cycle of the Renovation, Repair and Painting
accreditation and certification program, if warranted, based on findings from at least two
consecutive biennial reviews that the Lead Program costs continue to exceed the amount
fees collected. If necessary, this will be conducted in conjunction with other regulatory
changes in the lead program, e.g., rules underway to address renovation activities in other
buildings.
Agreed-to Completion Date: January 31, 2017
Recommendation 2: We recommend that Assistant Administrator for Chemical Safety and
Pollution Prevention modify its lead-based paint program cost analysis procedures to apply
indirect cost rates to all applicable direct costs in order to obtain the full costs of the program.
(The CFO will develop the indirect cost rates.)
Planned Corrective Action: Upon clarification of applicable indirect cost rates by
OCFO, OCSPP will modify cost analysis procedures as appropriate.
Agreed-to Completion Date: October 30, 2013
Recommendation 3: We recommend that the Chief Financial Officer conduct biennial cost
reviews of the lead-based paint program fee collections and the full cost of operating the
program to determine whether EPA is recovering its costs.
Planned Corrective Action: In accordance with OMB Circular A-25, User Charges and
the Chief Financial Officer's Act of 1990, the OCFO will conduct a review of the Lead-
Based paint fee collections and the full cost of operating the program to determine
whether the EPA is recovering its costs. This will be performed in accordance with the
next biennial cost review scheduled for FY 2013.
Agreed-to Completion Date: November 15, 2013
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Action Office:
OARM
Report Title: EPA Can Further Reduce Space in Under-Utilized Facilities
Report No.:	13-P-0162
Date Issued: 02/20/2013
Recommendations
Recommendation 1: We recommend that Assistant Administrator for Administration and
Resources Management assess utilization of General Services Administration-owned and leased
facilities and relocate staff as warranted to reduce under-utilized space.
Planned Corrective Action: The agency has an aggressive space consolidation plan that,
with adequate funding, will reduce leased space by approximately 20 percent by 2022.
Agreed-to Completion Date: December 31, 2022
Recommendation 2: We recommend that Assistant Administrator for Administration and
Resources Management develop space guidelines for support spaces and assess the number and
size of support spaces needed at the time of a new or renewal lease.
Planned Corrective Action: The agency has guidance per the July 2004 Space
Acquisition and Planning Guidelines that describe the approximate size and frequency of
special spaces typically found at the EPA facilities. OARM will revise the October 2011
draft New Mobile Work Space Design Guidelines to include support space guidance that
will be used for new and renewal leases.
Agreed-to Completion Date: December 31, 2013
Recommendation 3: We recommend that Assistant Administrator for Administration and
Resources Management require the Office of Acquisition Management, in conjunction with the
Office of Administration, to develop and enforce a policy that requires contracting staff ensure
approval for on-site contractor personnel is obtained from the responsible office and documented
in the contract file.
Planned Corrective Action: OAM and the Office of Administration will collaborate to
develop the needed policy and determine a method of enforcement once implemented.
Agreed-to Completion Date: September 30, 2013 (corrective actions will be considered
past due as of September 30, 2014)
Recommendation 4: We recommend that Assistant Administrator for Administration and
Resources Management require that personnel information be consistently tracked and updated
in EPA's designated real property management system on an annual basis or more often if
needed.
Planned Corrective Action: OARM is developing a process whereby facility managers
will be required to update personnel data in the designated real asset management system.
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Facilities Management and Services Division staff will provide oversight to ensure
updates are provided.
Agreed-to Completion Date: December 31, 2013
Recommendation 5: We recommend that Assistant Administrator for Administration and
Resources Management require Facilities Management and Services Division to update usable
square feet information whenever a change in office space is made.
Planned Corrective Action: OARM has an internal policy to update the usable square
feet of any agency facility once the EPA assumes or releases occupancy of space.
Facility managers will update the usable square feet, which will be audited by
Facilities Management Services Division staff.
Agreed-to Completion Date: December 31, 2013
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Action Office:
ORD and OAR
Report Title: EPA Needs to Improve Air Emissions Data for the Oil and Natural Gas
Production Sector
Report No.:	13-P-0161
Date Issued: 02/20/2013
Recommendations
Recommendation 1: We recommend that the Assistant Administrator for Air and
Radiation and the Assistant Administrator for Research and Development develop and
implement a joint comprehensive cross-office strategy for improving data for the oil and
gas production sector. The strategy should:
a.	Identify gaps and limitations in (1) existing oil and gas air emissions data, (2) emission
factors, and (3) measurement techniques, including direct and remote measurement
methods.
b.	Prioritize what data limitations are most significant and develop specific action plans for
how the EPA will address these gaps and limitations.
Planned Corrective Action 1: ORD and OAR agreed to establish an ORD/OAR cross-
office team and begin developing a strategy for improving oil and gas sector emissions data,
emissions factors and measurement techniques that will build on work already underway or
completed. The strategy document will summarily describe the gaps/limitations identified in
ongoing agency research planning activities; consider opportunities for incorporating other
existing data sources in the public and private sectors; prioritize the data gaps over the
strategy time frame; propose actions in summary manner to address data gaps/limitations,
beginning with those considered as highest priority; and inform the EPA's Air, Climate and
Energy research plan as the framework for needed research.
Agreed-to Completion Date: December 31, 2013
Planned Corrective Action 2: ORD and OAR agreed to conduct a cross-office review of
the draft oil and gas sector emissions data improvement strategy.
Agreed-to Completion Date: December 31, 2013
Planned Corrective Action 3: ORD and OAR agreed to revise the draft strategy based
upon the cross-office review and submit the final draft for review and approval by both
OAR and ORD.
Agreed-to Completion Date: March 31, 2014
Planned Corrective Action 4: ORD and OAR agreed to begin implementation of the
approved, final oil and gas sector emissions data improvement strategy in a coordinated
cross-office effort.
Agreed-to Completion Date: June 30, 2014
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Recommendation 2: We recommend that the Assistant Administrator for Air and Radiation
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.
Planned Corrective Action 1: OAR agreed to finalize the revised emissions factors
development procedures for data collected from traditional test methods.
Agreed-to Completion Date: September 30, 2014
Planned Corrective Action 2: OAR agreed to revise Web Factor and Information
Retrieval System to include the emissions factors development procedures for data
collected using traditional test methods.
Agreed-to Completion Date: December 31, 2014
Planned Corrective Action 3: OAR agreed to revise the Electronic Reporting Tool to
accommodate those non-traditional measurement techniques identified in the cross-office
strategy. The Electronic Reporting Tool will be fully developed by the 4th quarter of
FY 2017.
Agreed-to Completion Date: September 30, 2018
Planned Corrective Action 4: OAR agreed to set forth procedures for developing
emissions factors based on data collected with non-traditional measurement techniques
and incorporate those procedures into Web Factor and Information Retrieval System.
Agreed-to Completion Date: September 30, 2019
Recommendation 3: We recommend that the Assistant Administrator for Air and Radiation
ensure that the data in National Emissions Inventory are complete by:
a.	Monitoring the states' submission of oil and gas emissions data for point sources and
nonpoint sources pursuant to the requirements of the Air Emissions Reporting
Requirements and assisting states in complying with the rule.
b.	Completing the development of a method for calculating default nonpoint emission
estimates to enter into the National Emissions Inventory when states do not submit
nonpoint data for oil and gas production.
c.	Developing default calculation guidance for states to use to estimate oil and gas nonpoint
source emissions.
Planned Corrective Action 1: OAR agreed to use the oil and gas tool for estimating
nonpoint emissions from oil and gas production to ensure the 2011 National Emissions
Inventory version 1 has a complete estimate for the oil and gas sector for both criteria air
pollutants and hazardous air pollutants.
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Agreed-to Completion Date: December 31, 2013
Planned Corrective Action 2: OAR agreed to publicly release and solicit comments for
the final draft tool for estimating nonpoint emissions from oil and gas production.
Agreed-to Completion Date: December 31, 2013
Planned Corrective Action 3: OAR agreed to incorporate public comments and release
the final tool for estimating nonpoint emissions from oil and gas production.
Agreed-to Completion Date: June 30, 2014
Planned Corrective Action 4: OAR agreed to release a final user's guide for the final
tool for estimating nonpoint emissions from oil and gas production.
Agreed-to Completion Date: June 30, 2014
Planned Corrective Action 5: OAR agreed to release a final draft user's guide that will
also serve as calculation guidance for the oil and gas emissions tool.
Agreed-to Completion Date: December 31, 2013
Planned Corrective Action 6: OAR agreed to incorporate public comments and release
a final user's guide for the final oil and gas emissions tool.
Agreed-to Completion Date: June 30, 2014
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Action Office:
OSWER
Report Title: EPA Could Improve Contingency Planning for Oil and Hazardous Substance
Response
Report No.:	13-P-0152
Date Issued: 02/15/2013
Recommendations
Recommendation 2: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response require regions to keep critical planning information up to date using the
most effective method available and avoid unnecessary duplication.
Planned Corrective Action: OSWER's OEM will issue guidance and work with the
regions on its timely implementation.
Agreed-to Completion Date: September 30, 2016
Recommendation 3: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response have the Director of OEM work through the office's National Response
Team capacity to develop a process to regularly incorporate lessons learned from national
exercises into contingency plan reviews and updates.
Planned Corrective Action: The National Response Team will continue to incorporate
lessons learned from exercises and real world events into its purview.
Agreed-to Completion Date: April 30, 2013 (corrective action will be considered past
due as of April 30, 2014)
Recommendation 4: We recommended that the Assistant Administrator for Solid Waste and
Emergency Response 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.
Planned Corrective Action: Building on the existing workgroup process, OSWER will
continue evaluation of on-scene coordinator resources based on needs and responsibilities
of the regions to develop the plan to redistribute regional on-scene coordinator
allocations.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
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Action Office:	OCFO and OECA
Report Title:	Audit of EPA's Fiscal 2012 and 2011 Consolidated Financial Statements
Report No.:	13-1-0054
Date Issued:	11/15/2012
Recommendations
Recommendation 1: We recommend that the Chief Financial Officer perform a thorough review
of all posting models to ensure the proper accounts are impacted.
Planned Corrective Action: OCFO will continue to track and communicate status of
posting model issues through the availability of the Lotus Notes Tracking System and
through email. If the Office of Financial Management requires additional discussion with
Finance Centers, it will organize accordingly.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
Recommendation 6: We recommend that the Chief Financial Officer update EPA's policy for
recognizing year-end accruals to require reconciliations of accruals and accrual reversals.
Planned Corrective Action: OCFO will update Policy Announcement Number
95-11, "Policies and Procedures for Recognizing Year-End Accounts Payable and
Related Accruals."
Agreed-to Completion Date: March 31, 2013 (corrective action will be considered past
due as of March 31, 2014)
Recommendation 8: We recommend the Assistant Administrator for Enforcement and
Compliance Assurance forward judicial documents to the financial center.
Planned Corrective Action: OECA will work with the Cincinnati Finance Center to
assess the timely transmission of civil judicial orders requiring payment of certain sums
to Cincinnati Finance Center on a quarterly basis, and will meet with Department of
Justice management as needed.
Agreed-to Completion Date: March 31, 2014
Recommendation 16: We recommend that the Chief Financial Officer develop procedures to
reconcile capitalized property in the agency's financial system with Maximo.
Planned Corrective Action: The Office of Financial Management will develop
procedures for reconciling capitalized property.
Agreed-to Completion Date: March 31, 2013 (corrective action will be considered past
due as of March 31, 2014)
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Action Office:
OCFO and OARM
Report Title: Improvements Needed in Estimating and Leveraging Cost Savings Across EPA
Report No.:	13-P-0028
Date Issued: 10/22/2012
Recommendations
Recommendation 1: We recommend that the Chief Financial Officer develop an agencywide
policy that defines what the agency considers cost savings, efficiencies, and avoidances.
Planned Corrective Actions: OCFO agreed to develop high level guidance/policy that
will establish support for all savings and efficiency efforts and highlights recent
successes. This document will define types of savings and efficiency efforts broadly,
provide high level framework for costs savings, cost efficiencies and cost avoidances;
establish expectations of new efforts; and utilize existing process that can be sued for idea
generation and development.
Agreed-to Completion Date: December 31, 2015
Recommendation 2: We recommend that the Chief Financial Officer develop an agencywide
procedure for estimating savings, efficiencies, and cost avoidances to include requiring program
offices and regions to consult with internal financial managers to obtain complete and up-to-date
cost data.
Planned Corrective Actions: OCFO agreed to develop high level procedures for
estimating savings. It will outline the types of consideration that should be reviewed
when preparing estimates for potential savings, with examples of how to prepare
calculations, and establish trial periods and interim measures when savings cannot be
calculated.
Agreed-to Completion Date: December 31, 2015
Recommendation 3: We recommend that the Assistant Administrator for Administration and
Resources Management develop a policy on estimating savings and cost avoidances relating to
contracts based on similar prior contract data that will show the actions not taken or improved
operations as opposed to using the independent government cost estimates.
Planned Corrective Actions: OARM agreed to work with the OCFO to support the
development of agencywide policy/guidance for identifying and calculating savings, and
will implement that policy in OAM, as appropriate. OAM also agreed that if the OMB
develops governmentwide policies/processes for identifying and calculating savings,
OAM will adopt that guidance, as well.
Agreed-to Completion Date: December 31, 2015
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Action Office:
OEI
Report Title: Results of Technical Network Vulnerability Assessment: EPA's National
Vehicle and Fuel Emissions Laboratory
Report No.:	12-P-0900
Date Issued: 09/27/2012
Recommendation
Recommendation 3: We recommend that the senior information official within the Office of
Air and Radiation and the Office of Environmental Information perform a technical vulnerability
assessment test of assigned networked resources within 60 days to confirm completion of
remediation activities.
Planned Corrective Action: OEI will perform a technical vulnerability assessment test
of assigned networked resources.
Agreed-to Completion Date: December 28, 2012 (corrective action will be considered
past due as of December 28, 2013)
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Action Office:
OEI
Report Title: Improvements Needed in EPA's Network Security Monitoring Program
Report No.:	12-P-0899
Date Issued: 09/27/2012
Recommendations
Recommendation 1: We recommend that the Assistant Administrator for Environmental
Information develop and implement a strategy with milestone dates to incorporate the EPA's
headquarters program offices within the Security Incident and Event Management environment.
Planned Corrective Actions: The Technology and Information Security Staff of the
Office of Technology Operations and Planning will refine the project plan to reflect a
thorough strategy for incorporating program offices into the Security Incident and Event
Management environment. This strategy will include milestone dates for all program
offices not already in Security Incident and Event Management.
Agreed-to Completion Date: December 31, 2013
Recommendation 4: We recommend that the Assistant Administrator for Environmental
Information finalize the Security Incident and Event Management tool's "Enterprise Reference
Guide."
Planned Corrective Actions: The Enterprise Reference Guide will be reviewed to
determine gaps between its guidance and the current status of the Security Incident and
Event Management project. The Enterprise Reference Guide will be updated and
finalized, and referenced in other Technology and Information Security Staff/Computer
Security Incident Response Capability Center operating procedures if necessary.
Agreed-to Completion Date: March 29, 2013 (corrective actions will be considered past
due as of March 29, 2014)
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Action Office: OEI
Report Title: EPA's Office of Environmental Information Should Improve Ariel Rios and
Potomac Yard Computer Room Security Controls
Report No.:	12-P-0879
Date Issued: 09/26/2012
Recommendations
Recommendation 2: We recommend that the Director, Office of Technology Operations and
Planning, Office of Environmental Information, acquire and implement an uninterruptible power
supply that will automatically perform an orderly shutdown of information technology assets
without manual intervention in the event of a long-term loss of power.
Planned Corrective Actions: As part of the federal government's data consolidation
initiative, OCFO will close the Ariel Rios computer room and have the servers migrated
to the Potomac Yard facility. Efforts are underway with General Services Administration
to install a backup generator at the Potomac Yard facility. The generator will provide
24/7 backup power to the computer room and, in the event of a prolonged power outage,
sufficient notification would enable an orderly shutdown of information technology
assets.
Agreed-to Completion Date: March 30, 2013 (corrective action will be considered past
due as of March 30, 2014)
Recommendation 3: We recommend that the Director, Office of Technology Operations and
Planning, Office of Environmental Information, move the server racks so that they are not
directly under sprinkler heads or water pipes, or, if that is not possible, install leak shields on or
above the server racks directly under sprinkler heads or water pipes.
Planned Corrective Actions: OEI will contact OARM to discuss the feasibility of taking
the recommended action. OARM is responsible for the installation of the sprinklers.
Agreed-to Completion Date: July 19, 2013 (corrective action will be considered past
due as of July 19, 2014)
Recommendation 4: We recommend that the Director, Office of Technology Operations and
Planning, Office of Environmental Information, install a master shutoff valve for the water pipes
that flow through the computer room.
Planned Corrective Actions: OEI will contact OARM to discuss the feasibility of taking
the recommended action. OARM is responsible for alterations to the facility, water pipes
and shut off valves.
Agreed-to Completion Date: July 1, 2013 (corrective action will be considered past due
as of July 1, 2014)
Recommendation 5: We recommend that the Director, Office of Technology Operations and
Planning, Office of Environmental Information, develop and implement policies and procedures
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that address limiting water damages to information technology assets in the computer room that
include:
a.	24 hours/day, 7 days/week monitoring.
b.	Timely actions to be taken in the event of water leak in the computer room.
Planned Corrective Actions: While monitoring of environmental variable information
such as water, fire, temperature, humidity, power and smoke is part of the current
standard procedures, OEI will develop and implement formal procedures that address
limiting water damage to information technology assets in the computer room.
Agreed-to Completion Date: February 8, 2014
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Action Office:
OARM and OEI
Report Title: EPA Should Improve Management Practices and Security Controls for Its
Network Directory Service System and Related Servers
Report No.:	12-P-0836
Date Issued: 09/20/2012
Recommendations
Note: The narrative of the recommendations and planned corrective actions for this report are
not being included in the Compendium due to the sensitive nature of the report's security
findings.
Recommendation 8: This recommendation was made to the Assistant Administrator for
Administration and Resources Management.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
Recommendation 9: This recommendation was made to the Assistant Administrator for
Administration and Resources Management.
Agreed-to Completion Date: April 1, 2015
Recommendation 16: This recommendation was made to the Assistant Administrator for
Environmental Information and Chief Information Officer.
Agreed-to Completion Date: November 30, 2013
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Action Office:
OAR
Report Title: EPA Could Improve the SmartWay Transport Partnership Program by
Implementing a Direct Data Verification Process
Report No.:	12-P-0747
Date Issued: 08/30/2012
Recommendation
Recommendation 1: We recommend that the Assistant Administrator for Air and Radiation
develop and implement direct verification or other measures to verify the accuracy of a sample
of the self-reported, industry data for the SmartWay Transport Partnership.
Planned Corrective Actions: OAR is implementing the following five-step action plan:
1.	Identified a cross-section of SmartWay shippers, carriers and logistics partners
that have demonstrated program compliance with a credible quality process or
certification program, such as information security officer certification, Six-Sigma
designation or similar quality assurance system. OAR staff interviewed each
candidate and selected the most appropriate candidates. This activity has been
completed.
2.	Conduct site visits on a sample of SmartWay partners, which includes first-hand
observation and recording of the processes and safeguards employed to collect,
handle, check, manage, track and preserve the data reported in their SmartWay
partner submissions. OAR conducted site visits for 13 SmartWay partners, and
held discussions and interviews with key staff involved in data collection and
review to clarify how their data management and quality assurance measures
ensure partner data validity. This activity has been completed.
3.	Assess and synthesize the results of these interviews and site visits into a
comprehensive and consistent set of best practices available for all SmartWay
partners to use in their data collection, management and quality assurance
procedures. OAR anticipated that the first draft of this guidance document would
be available by December 2012.
4.	Review draft document internally and externally by subject matter experts. OAR
anticipates that the review process for the best practices guidance document will
be completed by May 2013. Additionally, existing SmartWay partner tool guides
and technical guidance documents will also be updated to reflect the best practices
identified during the site visits and to further clarify program requirements for
data integrity. OAR anticipates that the updated partner tool guidance and
technical guidance documents will be finalized on or before March 31, 2013.
5.	Publish the best practices guidance document, and conduct partner outreach and
training. OAR will publish the guidance document on the SmartWay website by
August 2013. From September through December 2013, OAR will conduct a
series of training, communications and outreach activities to ensure that all
SmartWay partners are aware of and have access to this information, and fully
understand the program's expectations for partner data integrity.
Agreed-to Completion Date: December 31, 2013
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Action Office: OCSPP
Report Title: Review of Hotline Complaint Concerning Cost and Benefit Estimates for EPA's
Lead-Based Paint Rule
Report No.:	12-P-0600
Date Issued: 07/25/2012
Recommendation
Recommendation 1: We recommend that the Assistant Administrator for Chemical Safety and
Pollution Prevention, consistent with a retrospective and flexible regulatory culture, 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.
Planned Corrective Action 1: OCSPP will create an information gathering workplan. It
will submit an Information Collection Request to OMB for clearance.
Agreed-to Completion Date: March 31, 2013 (corrective action will be considered past
due as of March 31, 2014)
Planned Corrective Action 2: After OMB clearance on the Information Collection
Request is received, OCSPP will conduct information gathering and analysis.
Agreed-to Completion Date: September 30, 2014
Planned Corrective Action 3: OCSPP will draft the information and analysis submitted
to OMB for interagency review as part of the Action Development Process.
Agreed-to Completion Date: March 31, 2015
Planned Corrective Action 4: OCSPP will publish the work practice and cost
information as part of the proposed rule.
Agreed-to Completion Date: September 30, 2015
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Action Office:
OSWER
Report Title: EPA Inaction in Identifying Hazardous Waste Pharmaceuticals May Result in
Unsafe Disposal
Report No.:	12-P-0508
Date Issued: 05/25/2012
Recommendation
Recommendation 3: We recommend the Assistant Administrator for Solid Waste and
Emergency Response 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 Corrective Actions: OSWER will develop nationally consistent outreach and
compliance assistance to help in complying with the Resource Conservation and
Recovery Act regulations for managing hazardous waste pharmaceuticals. It will propose
a rule designed to facilitate proper management of hazardous waste pharmaceuticals in
the health care industry.
Agreed-to Completion Date: August 31, 2013 (corrective action will be considered past
due as of August 31, 2014)
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Action Office:	OW
Report Title:	Alleged Misuse of Tribal Clean Water Act Section 106 Funds in EPA Region 8
Report No.:	12-P-0453
Date Issued:	05/04/2012
Recommendation
Recommendation 1: We recommend that the Assistant Administrator for Water develop
guidance for CWA Section 106 associated program support costs. Guidance should incorporate
specific requirements to use state and tribal assistance grants for associated program support, and
a process to obtain approval from recipients for associated program support costs funded with
Section 106 program funds. Alternatively, formally adopt OAR's guidance on associated
program support costs.
Planned Corrective Actions: OW will conduct a review of regional use of the
associated program support cost authority for assisting tribal programs and may, as
appropriate, develop new guidance or formally adopt existing guidance currently
applicable to other programs.
Agreed-to Completion Date: November 30, 2013
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Action Office:
OEI
Report Title: Office of Environmental Information Should Strengthen Controls Over Mobile
Devices
Report No.:	12-P-0427
Date Issued: 04/25/2012
Recommendation
Recommendation 3: We recommend that the Assistant Administrator for Environmental
Information and Chief Information Officer finalize agencywide draft domestic and international
mobile device procedures and develop other agencywide procedures as necessary that consider
standard operating procedures that encompass the areas listed in recommendation 1.
Planned Corrective Action: OEI will finalize the domestic draft Mobile Device and
Wireless Procedure.
Agreed-to Completion Date: December 31, 2012 (corrective action will be considered
past due as of December 31, 2013)
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Action Office:
OAR
Report Title: Weaknesses in EPA's Management of the Radiation Network System Demand
Attention
Report No.:	12-P-0417
Date Issued: 04/19/2012
Recommendation
Recommendation 8: We recommend that the Assistant Administrator for Air and Radiation
track the installation of the radiation network monitors against the revised schedule and use the
contract requirements in recommendations 4 and 5 to hold the contractor accountable.
Planned Corrective Action: All radiation network monitors have been delivered and
installations are being conducted as sites are prepared. The contracting officer
representative is working with the contracting officer to negotiate consideration for late
deliveries.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
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Action Office:
OARM
Report Title: EPA Should Improve Controls for Managing Contractor-Held Property
Report No.:	12-P-0388
Date Issued: 04/03/2012
Recommendations
Recommendation 3: We recommend that the Assistant Administrator for Administration and
Resources Management develop and implement policies and procedures for the property staff
that:
a.	Address how the EPA should maintain documentation to support acquisition values
reported by contractors on annual property reports.
b.	Require project management officers to have knowledge of CHP in their accountable
areas to ensure it is identified properly in Fixed Assets Subsystem.
c.	Define CHP responsibilities in locations where contractors and the EPA's staff are
co-located.
d.	Explain the required exchange between property and contract staffs to ensure the EPA
records property accurately in the financial statements.
Planned Corrective Action 9: In addition to the property guidelines and manual being
modified, OAM and the contract property coordinator are working to jointly update the
Contracts Management Manual to include any new or revised property policy and
procedures to be followed by the acquisition community. The EPA's Acquisition
Regulation will also be reviewed for potential updating. While the EPA's Acquisition
Regulation 1552.245-70 does require the contractor to conform to the requirements in
FAR 52.245-1, the only reporting requirement is for the annual summary report which
does not contain enough information to result in meaningful agency reporting.
A complete update of the EPA's acquisition policy is a part of the OAM balanced
scorecard performance measurement and management program.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
Planned Corrective Action 10: New training specific to the acquisition community will
be provided once the policy/procedures have been updated. This will be mandatory
training for contracting officers and will include information on the detailed property
record that is required to be included on a contract.
Agreed-to Completion Date: October 31, 2013
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Recommendation 4: We recommend that the Assistant Administrator for Administration and
Resources Management train property staff and contracting officers on current and any new
responsibilities over contracts with government property to ensure consistent application of and
adherence to EPA's administration of its property management program.
Planned Corrective Action: New training specific to the acquisition community will be
provided once the policy/procedures have been updated. This will be mandatory training
for contracting officers.
Agreed-to Completion Date: October 31, 2013
Recommendation 6: We recommend that the Assistant Administrator for Administration and
Resources Management revise or update the milestone dates and the corrective action plan in
MATS for the 2006 audit report and reference any corrective actions, and submit changes to the
OIG for tracking.
Planned Corrective Action 2: OARM agreed to update the policy and procedures
regarding government-furnished property management.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
Planned Corrective Action 5: OARM is updating the Contracts Management Manual to
include any new or revised property policy and procedures to be followed by the
acquisition community. The EPA's Acquisition Regulation will also be reviewed for
potential updating. While the EPA's Acquisition Regulation 1552.245-70 does require
the contractor to conform to the requirements in FAR 52.245-1, the only reporting
requirement is for the annual summary report which does not contain enough information
to result in meaningful agency reporting. A complete update of the EPA's acquisition
policy is a part of the OAM balanced scorecard performance measurement and
management program.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
Planned Corrective Action 7: OARM will conduct mandatory training for contracting
officers and additional training for contracting officer's representative on what
information is required to be provided when adding property to a contract and is
anticipated to significantly improve the agency's property management process. As part
of the training, best practices and/or standard operating procedures for documenting
property on contracts will be included to standardize reporting property and make CHP
information more accessible to the contract property coordinator.
Agreed-to Completion Date: October 31, 2013
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Action Office:
OSWER
Report Title: Controls Over State Underground Storage Tank Inspection Programs in EPA
Regions Generally Effective
Report No.:	12-P-0289
Date Issued: 02/15/2012
Recommendation
Recommendation 1: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response require the EPA and states to enter into memoranda of agreements that
reflect program changes from the 2005 Energy Policy Act and address oversight of
municipalities conducting inspections.
Planned Corrective Actions: The regulations will be finalized and OSWER will share
the specific date on which the memoranda of agreements will be in place.
Agreed-to Completion Date: August 1, 2013 (corrective actions will be considered past
due as of August 1, 2014)
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Action Office:
OSWER
Report Title: EPA Needs to Further Improve How It Manages Its Oil Pollution Prevention
Program
Report No.:	12-P-0253
Date Issued: 02/06/2012
Recommendation
Recommendation 1: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response, in consultation with the Assistant Administrator for Enforcement and
Compliance Assurance, improve oversight of facilities regulated by the EPA's oil pollution
prevention program by:
a.	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.
b.	Developing procedures for updating and issuing new guidance to ensure the regulated
community has access to the most current guidance.
c.	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.
d.	Consistently interpreting regulations and the EPA's authority to enforce regulations.
Planned Corrective Action 4(b): A summary of findings will be developed by OSWER.
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.
Agreed-to Completion Date: October 31, 2013
Planned Corrective Action 4(c): The model developed by OSWER for the Spill
Prevention, Control, and Countermeasure program will be used to develop a review
protocol for Facility Response Plans to examine the Facility Response Plan inspections
conducted during the FY 2013 inspection cycle.
Agreed-to Completion Date: September 30, 2013 (corrective actions will be considered
past due as of September 30, 2014)
Planned Corrective Action 4(d): A summary of findings will be developed by OSWER.
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.
Agreed-to Completion Date: October 31, 2014
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Action Office: Region 10
Report Title: Region 10 Technical and Computer Room Security Vulnerabilities Increase
Risk to EPA's Network
Report No.:	12-P-0220
Date Issued: 01/20/2012
Recommendations
Note: The narrative of the recommendations and planned corrective actions for this report are
not being included in the Compendium due to the sensitive nature of the report's security
findings.
Recommendation 4: This recommendation was made to the senior information official,
Region 10.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
Recommendation 7: This recommendation was made to the senior information official,
Region 10.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September, 2014)
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Action Office:
OECA
Report Title: EPA Must Improve Oversight of State Enforcement
Report No.:	12-P-0113
Date Issued: 12/09/2011
Recommendations
Recommendation 1: We recommend that the Deputy Administrator give OECA authority for all
nationwide enforcement resources and workforce allocation.
Planned Corrective Actions: OECA will gather and analyze information on regional
and program state oversight practices and make recommendations to the Deputy
Administrator on their adequacy and needed improvements.
Agreed-to Completion Date: October 31, 2012 (corrective action will be considered
past due as of October 31, 2013)
Recommendation 3: We recommend that the Assistant Administrator for Enforcement and
Compliance Assurance establish clear and consistent national enforcement benchmarks
throughout C AA, CWA and the Resource Conservation and Recovery Act guidance and policies
so that EPA's enforcement expectations are clear and consistent for state governments and the
regulated community.
Planned Corrective Action: OECA will ensure national performance expectations are
clearly identified and ensure these documents are readily accessible on the EPA's Online
Tracking Information System and the EPA's public website.
Agreed-to Completion Date: January 30, 2013 (corrective action will be considered past
due as of January 30, 2014)5
5 Subsequent to the close of our review period, October 22, 2013, OECA notified us that this action was completed
prior to September 30, 2013. However, this was not reflected in MATS prior to October 22, 2013.
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Action Office: Region 9
Report Title: Region 9 Technical and Computer Room Security Vulnerabilities Increase Risk
to EPA's Network
Report No.:	11-P-0725
Date Issued: 09/30/2011
Recommendations
Note: The narrative of the recommendations and planned corrective actions for this report are
not being included in the Compendium due to the sensitive nature of the report's security
findings.
Recommendation 4: This recommendation was made to the senior information official,
Region 9.
Agreed-to Completion Date: March 31, 2014
Recommendation 6: This recommendation was made to the senior information official,
Region 9.
Agreed-to Completion Date: March 31, 2014
Recommendation 8: This recommendation was made to the senior information official,
Region 9.
Agreed-to Completion Date: March 31, 2014
Recommendation 10: This recommendation was made to the senior information official,
Region 9.
Agreed-to Completion Date: March 31, 2014
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Action Office:
OAR
Report Title: EPA Should Update Its Fees Rule to Recover More Motor Vehicle and Engine
Compliance Program Costs
Report No.:	11-P-0701
Date Issued: 09/23/2011
Recommendation
Recommendation 1: We recommend that the Assistant Administrator for Air and Radiation
update the 2004 fees rule to increase the amount of the Motor Vehicle and Engine Compliance
Program costs it can recover.
Planned Corrective Action: OAR will begin planning for a new fees rule as part of the
2013 program prioritization and budget processes, and initiate formal work on rule
making early in calendar year 2014.
Agreed-to Completion Date: December 31, 2017
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Action Office:
OSWER
Report Title: Revisions Needed to National Contingency Plan Based on Deepwater Horizon
Oil Spill
Report No.:	11-P-0534
Date Issued: 08/25/2011
Recommendation
Recommendation 5: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response develop guidance and training for a Spill of National Significance that
clarifies roles and responsibilities for high-level agency officials. Review this response and the
NCP and work with federal partners to address lessons learned and include detail on how to
respond to a Spill of National Significance.
Planned Corrective Action 2: The EPA updated its Incident Management for executives
training as a result of lessons learned from the Deepwater Horizon spill. The training has
been presented in one region and additional training will be given.
Agreed-to Completion Date: October 31, 2013
Planned Corrective Action 3: As a result of this training, the agency will develop policy
guidance on this issue.
Agreed-to Completion Date: October 31, 2013
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Action Office: Region 8
Report Title: An Overall Strategy Can Improve Communication Efforts at Asbestos
Superfund Site in Libby, Montana
Report No.:	11-P-0430
Date Issued: 08/03/2011
Recommendations
Recommendation 2: We recommend that the EPA Regional Administrator, Region 8, 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.	Timelines for community involvement activities and outreach products.
c.	Measures for successful communication.
d.	Mechanisms for identifying community concerns and collecting feedback.
Planned Corrective Action: Region 8 will seek public comment on the next major
revision to the community involvement plan.
Agreed-to Completion Date: December 31, 2015
Recommendation 3: We recommend that the EPA Regional Administrator, Region 8,
implement a process for ongoing evaluation of Region 8's communication strategy and
incorporate results into community involvement planning.
Planned Corrective Action: Region 8 will conduct a customer satisfaction survey after
OSWER's Information Collection Request to OMB is approved. The region will arrange
with the manager of the Community Involvement and Public Initiatives Branch to notify
Region 8 when the approval is received.
Agreed-to Completion Date: November 30, 2013
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Action Office:
ORD
Report Title: Office of Research and Development Needs to Improve Its Method of
Measuring Administrative Savings
Report No.:	11-P-0333
Date Issued: 07/14/2011
Recommendation
Recommendation 1: We recommend that the Assistant Administrator for Research and
Development 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 Corrective Actions: ORD agreed to tag federal administrative personnel, senior
environmental employees, and on-site contractors in its ORD Management Information
System and reconcile this data with personnel rosters on a monthly basis. ORD senior
management had its initial meeting in 2011 and will continue to meet twice a year to
review current status and outline plans to attain organizational administrative staffing
targets.
Agreed-to Completion Date: December 15, 2015
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Action Office: OEI
Report Title: EPA Has Taken Steps to Address Cyber Threats but Key Actions Remain
Incomplete
Report No.:	11-P-0277
Date Issued: 06/23/2011
Recommendation
Recommendation 3: We recommend that the Assistant Administrator for Environmental
Information and Chief Information Officer update the Enterprise Transition Plan Information
Management segment to define actions the agency plans to take to achieve its security target
architecture.
Planned Corrective Actions: OEI planned to take five steps to define actions to achieve
the security target architecture in the EPA's Modernization Blueprint. OEI has completed
steps a-c and the following steps are remaining:
d. Develop implementation plans to close gaps.
Agreed-to Completion Date: July 1, 2013 (corrective actions will be considered past
due as of July 1, 2014)
e. Execute implementation plans.
Agreed-to Completion Date: September 15, 2013 (corrective actions will be considered
past due as of September 15, 2014)
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Action Office:
OCFO
Report Title: EPA Needs to Strengthen Its Management Controls Over Its Travel
Authorization Process
Report No.:	11-P-0223
Date Issued: 05/10/2011
Recommendations
Recommendation 2: We recommend that the that the Chief Financial Officer request that the
General Services Administration change GovTrip to prevent self-authorization of travel and
include audit trails to determine who made changes to routing lists.
Planned Corrective Actions: The current contract with GovTrip expires on
November 12, 2013. However, the EPA will most likely transition to a new service
provider prior to this deadline. A routing audit trail is one of the requirements under
E-Gov Travel Service 2 contract. At this time, OCFO sees updating GovTrip with the
addition of a routing list as cost prohibitive.
Agreed-to Completion Date: November 12, 2013
Recommendation 4: We recommend that the that the Chief Financial Officer develop scripts to
determine whether travelers are in compliance with policy for managing routing lists, run the
scripts monthly, and investigate exceptions.
Planned Corrective Actions: The routing list audit table in the Electronic Travel
Systems product will allow OCFO to run a list of changes that occurred during the
reporting period. OCFO would then be able to compare the list to the requests received
for the same period and investigate exceptions. In the meantime, OCFO has developed a
report that provides a list of vouchers where the traveler's name and the authorizer are the
same. The Cincinnati Financial Management Center will run this report monthly and
require additional documentation from any exceptions it produces.
Agreed-to Completion Date: November 12, 2013
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Action Office:
OSWER
Report Title: EPA Promoted the Use of Coal Ash Products With Incomplete Risk Information
Report No.:	11-P-0173
Date Issued: 03/23/2011
Recommendation
Recommendation 1: We recommend that the Assistant Administrator for Solid Waste and
Emergency Response define and implement risk evaluation practices to determine the safety of
the coal combustion residual beneficial uses the EPA promotes.
Planned Corrective Actions: OSWER will develop a conceptual model for evaluating
risks from unencapsulated uses.
Agreed-to Completion Date: March 30, 2014
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Action Office:
OAR
Report Title: ENERGY STAR Label Needs to Assure Superior Energy Conservation
Performance
Report No.:	11-P-0010
Date Issued: 10/28/2010
Recommendation
Recommendation 2: We recommend that the Assistant Administrator for Air and Radiation
develop a set of goals and valid and reliable measures that can accurately inform shareholders
and the public of the benefits of the program.
Planned Corrective Actions: Consistent with recommendations made through a recent
peer review of the model used to document ENERGY STAR products benefits, the EPA
is in the process of enhancing its approach to accounting for program savings. An
important aspect of this is better articulation of program goals and documentation of a
market model for key product areas. (A market model is similar to program logic but
adapted to the unique aspects of market transformation programs.) OAR will complete
the Phase II Reassessment of baselines for core products and finalize new goals and
measures.
Agreed-to Completion Date: December 31, 2012 (corrective actions will be considered
past due as of December 31, 2013)
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Action Office: OECA and OW
Report Title: EPA Should Revise Outdated or Inconsistent EPA-State Clean Water Act
Memoranda of Agreement
Report No.:	10-P-0224
Date Issued: 09/14/2010
Recommendation
Recommendation 2-2: We recommend that the Deputy Administrator 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.
Planned Corrective Action: Using the tracking system, OECA and OW agreed to verify
that memoranda of agreement identified during the first 4-year round of integrated
permitting and enforcement reviews are updated.
Agreed-to Completion Date: September 30, 2017
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Action Office:	OARM, OCFO and OEI
Report Title:	EPA Revised Hiring Process Needs Additional Improvements
Report No.:	10-P-0177
Date Issued:	08/09/2010
Recommendations
Recommendation 2-1: We recommend that the Assistant Administrator for Administration and
Resources Management, the Chief Financial Officer, and the Assistant Administrator for
Environmental Information determine the scope of services to be provided under a human
resources line-of-business provider contract. Among the services considered should be an
automated workflow process, a tracking system with responsive in-process metrics that will be
provided to the EPA, and a system to develop and catalog position descriptions.
Recommendation 2-2: We recommend that the Assistant Administrator for Administration and
Resources Management, the Chief Financial Officer, and the Assistant Administrator for
Environmental Information, based on the above considerations, select a line-of-business provider
and develop a plan to migrate to the selected provider.
Planned Corrective Actions: OARM, OCFO and OEI agreed to develop the scope of
services to be provided under a human resources line-of-business provider contract, and
present this business case to Office of Personnel Management. They will make a decision
on the proposed human resources line-of-business provider. In addition, they will
tentatively plan to deploy the system and train the user community, contingent upon a
decision and a mutually approved project schedule with the selected human resources
line-of business provider. (These corrective actions apply to recommendations 2-1 and
2-2.)
Agreed-to Completion Date: September 30, 2013 (corrective actions will be considered
past due as of September 30, 2014).
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Action Office:
OCSPP
Report Title: EPA Needs a Coordinated Plan to Oversee Its Toxic Substances Control Act
Responsibilities
Report No.:	10-P-0066
Date Issued: 02/17/2010
Recommendation
Recommendation 2-4: We recommend that the Assistant Administrator for Chemical Safety
and Pollution Prevention 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.
Planned Corrective Action 2: OCSPP agreed to initiate cumulative assessments of eight
phthalates and the EPA intends to lay the groundwork to consider initiating rulemaking
under Toxic Substances Control Act section 6(a) to regulate the eight phthalates. In
preparation for the rulemaking, the EPA intends, in cooperation with the U.S. Consumer
Product Safety Commission and the U.S. Food and Drug Administration, to continue to
work to fully assess the use, exposure and substitutes for these chemicals. In its further
review, the EPA plans to consider the future results of the cumulative assessment that
will be developed by the Consumer Product Safety Commission. Further specific actions
for the EPA will be determined based on the results of Consumer Product Safety
Commission's and Food and Drug Administration's work. Further specific actions for the
EPA, such as the establishment of criteria and procedures for how OCSPP will, in the
future, identify classes of chemicals to undergo assessments for low-level and cumulative
exposure assessments, will be determined based on the results of Consumer Product
Safety Commission's and Food and Drug Administration's work.
Agreed-to Completion Date: December 31, 2012 (corrective action will be considered
past due as of December 31, 2013)
Planned Corrective Action 3: OCSPP is an active participant in an agencywide
introspective analysis of risk assessment practices that brings agency risk assessors and
risk managers together to work toward advancing human health risk assessment focusing
on selected recommendations presented in the National Research Council reports:
Science and Decisions: Advancing Risk Assessment, Phthalates and Cumulative Risk:
The Tasks Ahead; and Toxicity Testing in the 21st Century: A Vision and A Strategy. The
EPA plans to issue agency guidance for the conduct of cumulative exposure assessments
and OCSPP's implementation is dependent on the agency issuing the guidance.
Agreed-to Completion Date: February 28, 2013 (corrective action will be considered
past due as of February 28, 2014)
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Action Office: OSWER
Report Title: Lack of Final Guidance on Vapor Intrusion Impedes Efforts to Address
Indoor Air Risks
Report No.:	10-P-0042
Date Issued: 12/14/2009
Recommendations
Recommendation 2: We recommend the Assistant Administrator for Solid Waste and
Emergency Response 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.
Planned Corrective Actions: OSWER will issue final guidance(s) on vapor intrusion to
seek public comment prior to initiating OMB-led interagency review.
Agreed-to Completion Date: November 30, 2012 (corrective actions will be considered
past due as of November 30, 2013)
Recommendation 3: We recommend the Assistant Administrator for Solid Waste and
Emergency Response train EPA and state staff and managers and other parties on the newly
updated, revised and finalized guidance document(s).
Planned Corrective Actions: OSWER will develop training materials and train the EPA
and state staff and managers on the finalized guidance document(s).
Agreed-to Completion Date: May 31, 2013 (corrective actions will be considered past
due as of May 31, 2014)
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Action Office:
OECA
Report Title: EPA Oversight and Policy for High Priority Violations of Clean Air Act Need
Improvement
Report No.:	10-P-0007
Date Issued: 10/14/2009
Recommendations
Recommendation 1: We recommend that the Assistant Administrator for Enforcement and
Compliance Assurance direct the EPA regions to comply with the High Priority Violation policy,
and monitor and report on regions' compliance.
Recommendation 3: We recommend that the Assistant Administrator for Enforcement and
Compliance Assurance implement proper management controls over HPV 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 Corrective Action: OECA will issue the HPV Identification Report. (This
corrective action applies to recommendations 1 and 3.)
Agreed-to Completion Date: October 1, 2012 (corrective action will be considered past
due as of October 1, 2013)
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Action Office: OARM
Report Title: Review of Hotline Complaint on Employee Granted Full-Time Work-at-Home
Privilege
Report No.:	10-P-0002
Date Issued: 10/07/2009
Recommendation
Recommendation 2b: We recommend that the Assistant Administrator for Administration and
Resources Management 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 the EPA's
policy.
Planned Corrective Action 1: The EPA headquarters program and regional offices plan
to review the current arrangements (6 months from approval date of policy).
Agreed-to Completion Date: June 30, 2013 (corrective action will be considered past
due as of June 30, 2014)
Planned Corrective Action 2: Bring any arrangements into alignment with the policy by
obtaining approval through the new policy's request process or terminate the existing
arrangement. (Note: the 6 months to review current arrangements is included within the
1-year for final resolution.)
Agreed-to Completion Date: December 31, 2013
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Action Office: OW
Report Title: EPA Needs to Accelerate Adoption of Numeric Nutrient Water Quality
Standards
Report No.:	09-P-0223
Date Issued: 08/26/2009
Recommendations
Recommendation 2-3: We recommend that the Assistant Administrator for Water establish the
EPA and state accountability for meeting milestones for adopting numeric nutrient water quality
standards for those waters in the rest of the nation that require them. The EPA should do this by:
a.	Requiring states to develop milestones based on resources available.
b.	Reviewing those milestones and approving them as appropriate.
Recommendation 2-4: We recommend that the Assistant Administrator for Water establish
metrics to gauge the actual progress made by the states in adopting numeric nutrient water
quality standards.
Recommendation 2-5: We recommend that the Assistant Administrator for Water ensure that
the regions annually validate the Water Quality Standards Action Tracking Application data.
Planned Corrective Actions: OW will publish and make available on the EPA's nutrient
criteria website a state status review report showing a cross walk between milestones and
program activity measures. Once completed, OW will continue to do this every 2 years.
(This corrective action applies to recommendations 2-3, 2-4 and 2-5.)
Agreed-to Completion Date: December 31, 2012 (corrective actions will be considered
past due as of December 31, 2013) and every 2 years thereafter
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Action Office:	OAR
Report Title:	EPA Does Not Provide Oversight of Radon Testing Accuracy and Reliability
Report No.:	09-P-0151
Date Issued:	05/12/2009
Recommendation
Recommendation 1: We recommend that the Assistant Administrator for Air and Radiation
disclose to the public that while radon testing is recommended by the agency and the
U.S. Surgeon General, EPA cannot provide assurance that commercially available radon testing
devices or radon testing laboratories are accurate and reliable.
Planned Corrective Action 1: OAR will conduct a study of device accuracy under an
approved Quality Assurance Project Plan.
Agreed-to Completion Date: March 31, 2014
Planned Corrective Action 2: OAR will publish the study results and make them
available to the public and to the radon community in general.
Agreed-to Completion Date: June 30, 2014
Planned Corrective Action 3: OAR will update the radon website to show results of the
study.
Agreed-to Completion Date: June 30, 2014
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Action Office:
Report Title:
Report No.:
Date Issued:
Region 9
Making Better Use of Stringfellow Superfund Special Accounts
08-P-0196
07/09/2008
Recommendation
Recommendation 2: We recommend that the Region 9 Administrator 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.
Planned Corrective Actions: Region 9 will reclassify or transfer to the EPA Hazardous
Substance Superfund Trust Fund, as appropriate, up to $27.8 million of the Stringfellow
special accounts in annual reviews, and at other milestones, when the record of decision
is signed and the final settlement is achieved.
Agreed-to Completion Date: December 31, 2012 (corrective actions will be considered
past due as of December 31, 2013)
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Action Office:
OSWER
Report Title: EPA Needs to Plan and Complete a Toxicity Assessment for the
Libby Asbestos Cleanup
Report No.:	2007-P-00002
Date Issued: 12/05/2006
Recommendation
Recommendation 1: We recommend that the EPA fund and execute a comprehensive
amphibole asbestos toxicity assessment to determine (1) the effectiveness of the Libby removal
actions, and (2) to determine whether more actions are necessary. The toxicity assessment should
include the effects of asbestos exposure on children. The EPA Science Advisory Board should
review the toxicity assessment and report to the OA and the Libby Community Advisory Group
whether the proposed toxicity assessment can sufficiently protect human health.
Planned Corrective Action: OSWER will complete the National Health and
Environmental Effects Research Laboratory animal toxicity studies.
Agreed-to Completion Date: September 30, 2015
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Action Office:
OECA
Report Title: State Enforcement of Clean Water Act Discharges Can Be More Effective
Report No.:	2001-P-00013
Date Issued: 08/14/2001
Recommendation
Recommendation 3-4: We recommended that the Assistant Administrator for Enforcement and
Compliance Assurance continue to report the Permit Compliance System as an agency-level
weakness until the modernization project is implemented and the system data is reasonably
accurate and complete.
Planned Corrective Action: OECA will continue to report the Permit Compliance
System as an agency-level weakness until the modernization project is implemented and
the system data is accurate and complete.
Agreed-to Completion Date: December 31, 2013
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Part Three:
Unimplemented CSB Recommendations With
Past Due Completion Dates
Report Title:
Evaluation of U.S. Chemical Safety and Hazard Investigation Board's

Compliance with the Federal Information Security Management Act

(Fiscal Year 2011)
Report No.:
12-P-0363
Date Issued:
03/21/2012
Report Summary
KPMG, LLP noted that CSB has an information security program in place that appears to be
functioning as designed. KPMG, LLP also noted that CSB takes information security weaknesses
seriously, as three of the four prior-year recommendations were resolved. However, KPMG, LLP
identified areas in which CSB could improve upon its vulnerability scanning and patch
management process, and inventory of information technology assets.
In addition to reviewing CSB's information security practices, KPMG, LLP conducted a security
assessment of key CSB system and network devices. This assessment disclosed several
challenges CSB faces in securing its main information technology system. KPMG, LLP found
unpatched network devices, which elevated CSB's risk of system and data compromise by
unauthorized users. KPMG, LLP provided detailed results of its assessment to CSB officials.
KPMG, LLP also identified 199 excess information technology devices, of a total of 408, which
could allow for misuse or loss of information technology devices or data.
Unimplemented Recommendation
Recommendation 2: We recommend that the Chairman, U.S. Chemical Safety and Hazard
Investigation Board, develop and implement standard baseline configurations for the network
devices.
Status: The CSB installed or completed the installation of the four missing patches
identified in the scan and will continue to actively review and patch network devices.
The CSB did not document the standard baseline configuration. The original agreed-to
completion date was July 31, 2012.
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Report Title: U.S. Chemical Safety and Hazard Investigation Board Did Not Take Effective
Corrective Actions on Prior Audit Recommendations
Report No.:	11-P-0115
Date Issued: 02/15/2011
Report Summary
The CSB did not take timely corrective actions to address a total of 34 audit recommendations
from three OIGs and from the Government Accountability Office. In four instances, it took CSB
4 years beyond the agreed-upon corrective actions date (or report date) to implement corrective
actions. The CSB's actions to address 13 recommendations were not completely effective and
require additional corrective actions, while seven additional recommendations are not yet
completed.
The CSB has not established and implemented a management control program to evaluate and
report on the effectiveness of controls related to its program operations. The CSB's control
environment and control activities do not ensure accountability. Specifically, the CSB's office
directors are not accountable for achieving individual and program initiatives leading to chemical
accident prevention. Effective control activities, including board orders, have not been developed
and implemented. In addition, without a clearly defined statutory mandate, the CSB will face
difficulties in developing outcome-related goals for measuring its impact on chemical accident
prevention. Without effective controls, the CSB is not timely in carrying out initiatives to
achieve the board's goal of chemical accident prevention.
On September 16, 2010, the CSB announced an internal reorganization, appointing a managing
director who will oversee all aspects of the CSB operations. A managing director who ensures
accountability should provide for more timely and effective resolution of audit
recommendations.
Unimplemented Recommendations
Recommendation 1: We recommend that the Chairman, U.S. Chemical Safety and Hazard
Investigation Board, develop and implement a management control plan that documents and
addresses the five internal control standards in accordance with OMB Circular A-123 and
Government Accountability Office'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.
Status: The CSB agreed to develop a management control plan as an initiative in its
FY 2011 action. The CSB is developing a management control plan with references to
appropriate OMB circulars. The plan will direct periodic review of all board orders. The
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CSB expects to complete the plan by December 31, 2013. The agreed-to completion date
for this corrective action was February 28, 2011.
Recommendation 2: We recommend that the Chairman, U.S. Chemical Safety and Hazard
Investigation Board, develop and publish a regulation requiring persons to report chemical
accidents, as required by the CAA.
Status: The CSB agreed to issue a proposed rule on accident reporting as an initiative in
its FY 2011 action plan. After further considering this issue, the CSB believes that it
receives adequate incident notifications through constant media and Internet searches, as
well as existing federal sources such as the National Response Center. The CSB's ability
to consider rulemaking and program development in this area has been further impacted
by congressional budget cuts and sequestration, which effectively prevent any hiring that
would be needed for a regulatory reporting program. The CSB has developed two written
questionnaires that are being sent to companies that have incidents, on a discretionary
basis. The CSB does not have any further action planned. The agreed-to completion date
for this corrective action was September 30, 2011.
Recommendation 3: We recommend that the Chairman, U.S. Chemical Safety and Hazard
Investigation Board, follow up with Congress on the CSB's 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 the CSB's statutory mandate.
Status: The CSB agreed to transmit a formal package of suggested legislative
improvements to the CSB's congressional authorizing committee as an initiative in its
FY 2011 action plan. The package will include suggested language to clarify the statutory
mandate to investigate. The CSB noted that it is not in a position to guarantee a
congressional response as indicated in our recommendation. The CSB now believes this
recommendation should be closed since the CSB raised the statutory issue with Congress
by letter in November 2009. In addition, the letter from then-Chairman Bresland stated,
"Pending any further direction from Congress, the CSB will continue to adhere to its
interpretation of its statutory authority and mandate." In the event that Congress opts to
consider reauthorization of the CSB, the CSB will remind Congress of this wording
concern of the OIG. The CSB does not have any further action planned. The agreed-to
completion date for this corrective action was April 30, 2011.
Recommendation 5: We recommend that the Chairman, U.S. Chemical Safety and Hazard
Investigation Board, 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.
Status: The CSB agreed to develop a system for periodic reviews of board orders and
include the requirement for such a review in the management control plan. As indicated
in recommendation 1, CSB expects to complete the plan by December 31, 2013. The
agreed-to completion date for this corrective action was February 28, 2011.
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Recommendation 6: We recommend that the Chairman, U.S. Chemical Safety and Hazard
Investigation Board, take corrective actions that will satisfy prior audit recommendations by
updating and formalizing board orders that are essential to facilitate and manage effective and
efficient control activities. Specifically, update:
a.	Board Order 036, "Incident Selection Process," to reflect current changes, such as its data
sources, changes due to technology improvements, and the incident selection process
decision-making flowchart, to improve the incident screening and deployment decision-
making process. In addition, formalize the Incident Screeners Guide (appendix A, audit
recommendation 17, 18, 19, 20, and 31).
b.	Board Order 040, "Investigation Protocol," to govern employees retaining memberships
in societies or organizations to which the CSB issues recommendations (appendix A,
audit recommendation 21).
c.	Board Order 027, "Roles, Responsibilities, and Standards of Conduct in Procurement
Activities," to reflect current procurement practices and processes to ensure consistency
in the procurement process (appendix A, audit recommendation 7).
d.	Board Order 022, "Recommendation Program," to include new practices adopted for
following up on safety recommendations, to include a quality review program to ensure
timely follow-up on closed safety recommendations (appendix A, audit recommendations
12 and 15).
e.	Board Order 028, "Executive Administrative Functions of the Board," to document the
role and responsibility of the managing director position.
Status: The CSB indicated its intention to satisfy prior audit recommendations by
updating and formalizing board orders that are essential to facilitate and manage effective
and efficient control activities. Specifically, for each of the sub-recommendations:
a.	The CSB has completed the corrective actions.
b.	The CSB has completed the corrective actions.
c.	For those board orders that refer to positions that no longer exist (e.g., chief operating
officer), the CSB general counsel has concluded that the delegated position authority
references the equivalent position (e.g., managing director). In those instances in
which no equivalent position exists, authority is reposed in the next higher ranking
official with decision-making authority. In those rare instances in which no equivalent
position can be determined, the administrative authority will revert to the chair or the
board, as appropriate. The agreed-to completion date was March 31, 2011.
d.	The CSB agreed to consider including a quality review program to ensure timely
follow-up on safety recommendations in Board Order 022. The CSB will also update
the Recommendations Office "Standards of Practice" document and expects that the
board order will contain general guidance and the Standards of Practice will include
detailed procedures. The CSB staff proposed a revision of Board Order 22 to address
this issue, but the board has not been able to agree on approval. The CSB will adopt
pertinent changes through a management directive. The CSB plans to complete these
actions by September 30, 2014. The agreed-to completion date was September 30,
2011.
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e. The CSB agreed to review Board Order 028, and update it as appropriate to reflect the
role and responsibility of the managing director position by September 20, 2011. The
CSB determined, as of February 14, 2012, after review of Board Order 028, that it is
not appropriate to document the role and the responsibilities of the managing director
in this board order. The purpose of the board order is to establish the manner in which
the board exercises its executive and administrative functions through the position of
the chairperson. The managing director is a staff position for which roles and
responsibilities is no longer applicable. The OIG, however, still considers the
recommendation to be open.
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Part Four:
Unimplemented CSB Recommendations With
Future Planned Completion Dates
Report Title: Audit Follow-Up Process Needed for the U.S. Chemical Safety and Hazard
Investigation Board
Report No.:	13-P-0128
Date Issued: 02/01/2013
Recommendation
Recommendation 1: We recommend that the Chairperson, U.S. Chemical Safety and Hazard
Investigation Board, develop and implement a follow-up system as required by OMB Circulars
A-50 and A-123 that includes 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 Corrective Action: The CSB agreed to create agency audit follow-up
procedures.
Agreed-to Completion Date: April 30, 2013 (corrective action will be considered past
due as of April 30, 2014)
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Report Title: U.S. Chemical Safety and Hazard Investigation Board Should Improve Its
Recommendations Process to Further Its Goal of Chemical Accident
Prevention
Report No.:	12-P-0724
Date Issued: 08/22/2012
Recommendations
Recommendation 1: We recommend that the Chairperson, U.S. Chemical Safety and Hazard
Investigation Board, update board orders to ensure that the CSB achieves its mission of chemical
accident prevention through improved recommendations processes, to include:
a.	Board Order 022, CSB Recommendation Program,
i.	To establish and implement data quality reviews to verify the accuracy,
completeness, and reliability of recommendations data entered in TRIM
(Total Records and Information Management), such as error checks and inclusion
of required supporting documentation.
ii.	To require that the Office of Recommendations director periodically analyze and
assess the recommendations process to identify potential process improvements.
b.	Board Order 001, Board Quorum and Voting, to establish and implement guidelines that
define the length of time notation items can be calendared before a vote must be taken.
c.	Board Order 040, Investigation Protocol, to clearly outline roles and responsibilities of
the 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.
Planned Corrective Action for l.a: The CSB submitted the revised Board Order 22 to
the board for consideration and it was calendared by one of the members on November 1,
2012. The CSB will adopt pertinent changes through a management directive.
Agreed-to Completion Date: May 31, 2013 (corrective action will be considered past
due as of May 31, 2014)
Planned Corrective Action for l.b: The CSB disagrees with this recommendation and
no further action is planned.
Agreed-to Completion Date: Unavailable
Planned Corrective Action for l.c: Due to the CSB's workload to complete several
investigations by the beginning of the second quarter of FY 2013, it was not able to meet
the previous December 31, 2012, deadline to complete the sections of Board Order 040
related to the OIG's recommendations. The staff task force completed the section on
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causal analysis and it has been approved by the board. The task force from the Offices of
Investigations, Recommendations, and Administration met on January 22, 2013, to create
chapter work plans for Product Development and Review and Recommendations.
The CSB will revise Board Order 40.
Agreed-to Completion Date: September 30, 2013 (corrective action will be considered
past due as of September 30, 2014)
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Report Title: Evaluation of U.S. Chemical Safety and Hazard Investigation Board's
Compliance with the Federal Information Security Management Act
(Fiscal Year 2011)
Report No.:	12-P-0363
Date Issued: 03/21/2012
Recommendation
Recommendation 1: We recommend that the Chairman, U.S. Chemical Safety and Hazard
Investigation Board, review and implement patches as required for network devices.
Planned Corrective Action: The CSB installed or completed the installation of the four
missing patches identified in the scan and will continue to actively review and patch
network devices.
Agreed-to Completion Date: Ongoing
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Appendix A
EPA OIG Reports With
Unimplemented Recommendations
by Program Office as of September 30, 2013
Recommendations With Past Due Completion Dates
OA	
12-P-0125 Early Warning Report: Use of Unapproved Asbestos Demolition Methods May Threaten Public
Health (Recommendation 5)
ll-P-0708 EPA Progress on the 2007 Methamphetamine Remediation Research Act (Recommendation 3)
OAR	
11-R-0179	EPA Needs to Better Document Project Delays for Recovery Act Diesel Emissions Reduction Act
Grants (Recommendations 3 and 5)
10-P-0154	Key Activities in EPA's Integrated Urban Air Toxics Strategy Remain Unimplemented
(Recommendations 2-1 and 2-2)
2005-P-00010 Substantial Changes Needed in Implementation and Oversight of Title V Permits If Program
Goals Are To Be Fully Realized (Recommendations 2-1 and 2-3)
OARM	
12-P-0388	EPA Should Improve Controls for Managing Contractor-Held Property
(Recommendations 1,3, and 6)
12-1-0073 Audit of EPA's Fiscal 2011 and 2010 Consolidated Financial Statements
(Recommendation 9)
11-P-0705	EPA's Contract Oversight and Controls Over Personal Computers Need Improvement
(Recommendation 2)
ll-P-0687 EPA Should Improve Timeliness for Resolving Audits Under Appeal
(Recommendation 2)
ll-P-0616 EPA Has Not Fully Implemented a National Emergency Equipment Tracking System
(Recommendation 3)
ll-P-0136 EPA Needs Better Agency-Wide Controls Over Staff Resources (Recommendation 1)
10-P-0002 Review of Hotline Complaint on Employee Granted Full-Time Work-at-Home Privilege
(Recommendations 1 and 2a)
09-P-0087 EPA Plans for Managing Counter Terrorism/Emergency Response Equipment and Protecting
Critical Assets Not Fully Implemented (Recommendation 4-l(b))
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OCFO	
ll-P-0630 EPA Needs Workload Data to Better Justify Future Workforce Levels
(Recommendations 1 and 2)
11-P-0031	EPA Needs to Strengthen Internal Controls for Determining Workforce Levels
(Recommendations 2-1 and 2-2)
10-1-0029 Audit of EPA's Fiscal 2009 and 2008 (Restated) Consolidated Financial Statements
(Recommendations 27 and 32)
2006-P-00013 EPA Can Better Manage Superfund Resources (Recommendation 2-3)
OCSPP	
10-P-0066	EPA Needs a Coordinated Plan to Oversee Its Toxic Substances Control Act Responsibilities
(Recommendation 2-5)
OECA	
12-P-0113	EPA Must Improve Oversight of Sate Enforcement (Recommendation 4)
11-P-0315	Agency-Wide Application of Region 7 NPDES Program Process Improvements Could Increase
EPA Efficiency (Recommendation 1)
10-P-0230 ECHO Data Quality Audit—Phase II Results: EPA Could Achieve Data Quality Rate with
Additional Improvements (Recommendation 5)
10-P-0007	EPA Oversight and Policy for High Priority Violations of Clean Air Act Need Improvement
(Recommendation 2)
2005-P-00024 Limited Knowledge of the Universe of Regulated Entities Impedes EPA's Ability to Demonstrate
Changes in Regulatory Compliance (Recommendation 2-4)
2001-P-00013 State Enforcement of Clean Water Act Discharges Can Be More Effective
(Recommendations 3-1 and 3-2)
ORD	
11-P-0386	Office of Research and Development Should Increase Awareness of Scientific Integrity Policies
(Recommendation 3)
OSWER	
ll-P-0534 Revisions Needed to National Contingency Plan Based on Deepwater Horizon Oil Spill
(Recommendations 1,3,6 and 7)
ll-P-0171 EPA Needs an Agency-Wide Plan to Provide Tribal Solid Waste Management Capacity
Assistance (Recommendations 1 and 2)
2007-P-00002 EPA Needs to Plan and Complete a Toxicity Assessment for the Libby Asbestos Cleanup
(Recommendation 1)
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Region 2
2007-P-00016 Environmental Justice Concerns and Communication Problems Complicated Cleaning Up
Ringwood Mines/Landfill Site (Recommendation 2-1)
Region 9	
12-2-0072	Agreed-Upon Procedures Applied to EPA Grants Awarded To Summit Lake Paiute Tribe,
Sparks, Nevada (Recommendation 2)
Recommendations With Future Planned Completion Dates
OA	
13-P-0201	The EPA Needs to Improve Management of Its School Environmental Health Efforts
(Recommendations 1,2,3 and 4)
OAR	
13-P-0161 EPA Needs to Improve Air Emissions Data for the Oil and Natural Gas Production Sector
(Recommendations 1,2, and 3)
12-P-0747 EPA Could Improve the SmartWay Transport Partnership Program by Implementing a
Direct Data Verification Process (Recommendation 1)
12-P-0417	Weaknesses in EPA's Management of the Radiation Network System Demand Attention
(Recommendation 8)
ll-P-0701 EPA Should Update Its Fees Rule to Recover More Motor Vehicle and Engine Compliance
Program Costs (Recommendation 1)
ll-P-0010 Energy Star Label Needs to Assure Superior Energy Conservation Performance
(Recommendation 2)
09-P-0151 EPA Does Not Provide Oversight of Radon Testing Accuracy and Reliability
(Recommendation 1)
OARM	
13-P-0208	EPA Should Increase Fixed-Price Contracting for Remedial Actions
(Recommendations 1,2,3 and 4)
13-P-0200 Improvements Needed in EPA's Smartcard Program to Ensure Consistent Physical Access
Procedures and Cost Reasonableness (Recommendations 3 and 5)
13-P-0178 Improvements Needed in EPA Training and Oversight for Risk Management Program Inspections
(Recommendation 5)
13-P-0162	EPA Can Further Reduce Space in Under-Utilized Facilities
(Recommendations 1,2,3,4 and 5)
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13-P-0028 Improvements Needed in Estimating and Leveraging Cost Savings Across EPA
(Recommendation 3)
12-P-0836 EPA Should Improve Management Practices and Security Controls for Its Network Directory
Service System and Related Servers (Recommendations 8 and 9)
12-P-0388	EPA Should Improve Controls for Managing Contractor-Held Property (Recommendations 3,4
and 6)
10-P-0177 EPA Revised Hiring Process Needs Additional Improvements (Recommendations 2-1 and 2-2)
10-P-0002	Review of Hotline Complaint on Employee Granted Full-Time Work-at-Home Privilege
(Recommendation 2b)
OCFO	
13-P-0175	Corrective Action Plan Needed in Order to Fully Comply With the Improper Payments
Elimination and Recovery Act (Recommendation 6)
13-P-0163 EPA is Not Recovering All Its Costs of the Lead-Based Paint Fees Program
(Recommendation 3)
13-1-0054 Audit of EPA's Fiscal 2012 and 2011 Consolidated Financial Statements
(Recommendations 1,6 and 16)
13-P-0028 Improvements Needed in Estimating and Leveraging Cost Savings Across EPA
(Recommendations 1 and 2)
11-P-0223	EPA Needs to Strengthen Its Management Controls Over Its Travel Authorization Process
(Recommendations 2 and 4)
10-P-0177
EPA Revised Hiring Process Needs Additional Improvements (Recommendations 2-1 and 2-2)
OCSPP
13-P-0163 EPA is Not Recovering All Its Costs of the Lead-Based Paint Fees Program
(Recommendations 1 and 2)
12-P-0600 Review of Hotline Complaint Concerning Cost and Benefit Estimates for EPA's Lead-Based Paint
Rule (Recommendation 1)
10-P-0066 EPA Needs a Coordinated Plan to Oversee Its Toxic Substances Control Act Responsibilities
(Recommendation 2-4)
OECA
13-1-0054 Audit of EPA's Fiscal 2012 and 2011 Consolidated Financial Statements
(Recommendation 8)
12-P-0113 EPA Must Improve Oversight of State Enforcement (Recommendations 1 and 3)
10-P-0224 EPA Should Revise Outdated or Inconsistent EPA-State Clean Water Act Memoranda of
Agreement (Recommendation 2-2)
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10-P-0007	EPA Oversight and Policy for High Priority Violations of Clean Air Act Need Improvement
(Recommendations 1 and 3)
2001-P-00013 State Enforcement of Clean Water Act Discharges Can Be More Effective
(Recommendation 3-4)
OEI	
12-P-0900 Results of Technical Network Vulnerability Assessment: EPA's National Vehicle and Fuel
Emissions Laboratory (Recommendation 3)
12-P-0899 Improvements Needed in EPA's Network Security Monitoring Program
(Recommendations 1 and 4)
12-P-0879 EPA's Office of Environmental Information Should Improve Ariel Rios and Potomac Yard
Computer Room Security Controls (Recommendations 2,3,4 and 5)
12-P-0836 EPA Should Improve Management Practices and Security Controls for Its Network Directory
Service System and Related Servers (Recommendation 16)
12-P-0427	Office of Environmental Information Should Strengthen Controls Over Mobile Devices
(Recommendation 3)
11-P-0277	EPA Has Taken Steps to Address Cyber Threats but Key Actions Remain Incomplete
(Recommendation 3)
10-P-0177 EPA Revised Hiring Process Needs Additional Improvements (Recommendations 2-1 and 2-2)
ORD	
13-P-0161	EPA Needs to Improve Air Emissions Data for the Oil and Natural Gas Production Sector
(Recommendation 1)
1 l-P-0333 Office of Research and Development Needs to Improve Its Method of Measuring Administrative
Savings (Recommendation 1)
OSWER	
13-P-0208 EPA Should Increase Fixed-Price Contracting for Remedial Actions
(Recommendations 1,2,3 and 4)
13-P-0178 Improvements Needed in EPA Training and Oversight for Risk Management Program Inspections
(Recommendations 7 and 8)
13-P-0176 Results and Benefits Information Is Needed to Support Impacts of EPA's Superfund Removal
Program (Recommendations 1 and 2)
13-P-0152 EPA Could Improve Contingency Planning for Oil and Hazardous Substance Response
(Recommendations 2,3 and 4)
12-P-0508	EPA Inaction in Identifying Hazardous Waste Pharmaceuticals May Result in Unsafe Disposal
(Recommendation 3)
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12-P-0289 Controls Over State Underground Storage Tank Inspection Programs in EPA Regions
Generally Effective (Recommendation 1)
12-P-0253	EPA Needs to Further Improve How It Manages Its Oil Pollution Prevention Program
(Recommendation 1)
ll-P-0534 Revisions Needed to National Contingency Plan Based on Deepwater Horizon Oil Spill
(Recommendation 5)
11-P-0173	EPA Promoted the Use of Coal Ash Products With Incomplete Risk Information
(Recommendation 1)
10-P-0042 Lack of Final Guidance on Vapor Intrusion Impedes Efforts to Address Indoor Air Risks
(Recommendations 2 and 3)
2007-P-00002 EPA Needs to Plan and Complete a Toxicity Assessment for the Libby Asbestos Cleanup
(Recommendation 1)
ow	
13-P-0175	Corrective Action Plan Needed in Order to Fully Comply With the Improper Payments
Elimination and Recovery Act (Recommendations 2 and 3)
12-P-0453	Alleged Misuse of Tribal Clean Water Act Section 106 Funds in EPA Region 8
(Recommendation 1)
10-P-0224 EPA Should Revise Outdated or Inconsistent EPA-State Clean Water Act Memoranda of
Agreement (Recommendation 2-2)
09-P-0223 EPA Needs to Accelerate Adoption of Numeric Nutrient Water Quality Standards
(Recommendations 2-3,2-4 and 2-5)
Region 7
13-P-0207 Review of Hotline Complaint Regarding Residential Soil Contamination in Cherryvale, Kansas
(Recommendations 1,2 and 3)
Region 8
ll-P-0430 An Overall Strategy Can Improve Communication Efforts at Asbestos Superfund Site in Libby,
Montana (Recommendations 2 and 3)
Region 9
ll-P-0725 Region 9 Technical and Computer Room Security Vulnerabilities Increase Risk to EPA's Network
(Recommendations 4,6,8 and 10)
08-P-0196 Making Better Use of Stringfellow Superfund Special Accounts (Recommendation 2)
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Region 10	
13-R-0206 Audit of American Recovery and Reinvestment Act-Funded Cooperative Agreement 2S-96099601
Awarded to the Idaho Department of Environmental Quality (Recommendations 3 and 4)
12-P-0220 Region 10 Technical and Computer Security Vulnerabilities Increase Risk to EPA's Network
(Recommendations 4 and 7)
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Appendix B
Unimplemented Recommendations:
Current EPA Compendium
(Past Due Recommendations)
Compared to 04/30/13 Compendium
Continuing Unimplemented Recommendations
12-P-0388 EPA Should Improve Controls for Managing Contractor-Held Property
(OARM, Recommendations 1 and 3)
12-P-0125 Early Warning Report: Use of Unapproved Asbestos Demolition Methods May Threaten Public
Health (OA, Recommendation 5)
ll-P-0705 EPA's Contract Oversight and Controls Over Personal Computers Need Improvement
(OARM, Recommendation 2)
ll-P-0315 Agency-Wide Application of Region 7 NPDES Program Process Improvements Could Increase
EPA Efficiency (OECA, Recommendation 1)
ll-R-0179 EPA Needs to Better Document Project Delays for Recovery Act Diesel Emissions Reduction Act
Grants (OAR, Recommendations 3 and 5)
ll-P-0031 EPA Needs to Strengthen Internal Controls for Determining Workforce Levels
(OCFO, Recommendation 2-2)
10-P-0066 EPA Needs a Coordinated Plan to Oversee Its Toxic Substances Control Act Responsibilities
(OCSPP, Recommendation 2-5)
10-1-0029 Audit of EPA's Fiscal 2009 and 2008 (Restated) Consolidated Financial Statements
(OCFO, Recommendations 27 and 32)
10-P-0002 Review of Hotline Complaint on Employee Granted Full-Time Work-at-Home Privileges
(OARM, Recommendations 1 and 2a)
09-P-0087 EPA Plans for Managing Counter Terrorism/Emergency Response Equipment and Protecting
Critical Assets Not Fully Implemented (OARM, Recommendation 4-l(b))
2006-P-00013 EPA Can Manage Superfund Resources (OCFO, Recommendation 2-3)
2005-P-00010 Substantial Changes Needed in Implementation and Oversight of Title V Permits If Program
Goals Are To Be Fully Realized (OAR, Recommendations 2-1 and 2-3)
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New Unimvlemented Recommendations
12-P-0388 EPA Should Improve Controls for Managing Contractor-Held Property
(OARM, Recommendation 6)
12-P-0113 EPA Must Improve Oversight of Sate Enforcement (OECA, Recommendation 4)
12-1-0073 Audit of EPA's Fiscal 2011 and 2010 Consolidated Financial Statements
(OARM, Recommendation 9)
12-2-0072 Agreed-Upon Procedures Applied to EPA Grants Awarded To Summit Lake Paiute Tribe,
Sparks, Nevada (Region 9, Recommendation 2)
ll-P-0708 EPA Progress on the 2007 Methamphetamine Remediation Research Act
(OA, Recommendation 3)
ll-P-0687 EPA Should Improve Timeliness for Resolving Audits Under Appeal
(OARM, Recommendation 2)
ll-P-0630 EPA Needs Workload Data to Better Justify Future Workforce Levels
(OCFO, Recommendations 1 and 2)
ll-P-0616 EPA Has Not Fully Implemented a National Emergency Equipment Tracking System
(OARM, Recommendation 3)
ll-P-0534 Revisions Needed to National Contingency Plan Based on Deepwater Horizon Oil Spill
(OSWER, Recommendations 1,3,6 and 7)
ll-P-0386 Office of Research and Development Should Increase Awareness of Scientific Integrity Policies
(ORD, Recommendation 3)
ll-P-0171 EPA Needs an Agency-Wide Plan to Provide Tribal Solid Waste Management Capacity
Assistance (OSWER, Recommendations 1 and 2)
ll-P-0136 EPA Needs Better Agency-Wide Controls Over Staff Resources (OARM, Recommendation 1)
ll-P-0031 EPA Needs to Strengthen Internal Controls for Determining Workforce Levels
(OCFO, Recommendation 2-1)
10-P-0230 ECHO Data Quality Audit—Phase II Results: EPA Could Achieve Data Quality Rate with
Additional Improvements (OECA, Recommendation 5)
10-P-0154 Key Activities in EPA's Integrated Urban Air Toxics Strategy Remain Unimplemented
(OAR, Recommendations 2-1 and 2-2)
10-P-0007 EPA Oversight and Policy for High Priority Violations of Clean Air Act Need Improvement
(OECA, Recommendation 2)
2007-P-00016 Environmental Justice Concerns and Communication Problems Complicated Cleaning Up
Ringwood Mines/Landfill Site (Region 2, Recommendation 2-1)
2007-P-00002 EPA Needs to Plan and Complete a Toxicity Assessment for the Libby Asbestos Cleanup
(OSWER, Recommendation 1)
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2005-P-00024 Limited Knowledge of the Universe of Regulated Entities Impedes EPA's Ability to Demonstrate
Changes in Regulatory Compliance (OECA, Recommendation 2-4)
2001-P-00013 State Enforcement of Clean Water Act Discharges Can Be More Effective
(OECA, Recommendations 3-1 and 3-2)
Removed Unimvlemented Recommendations
Note: Removal of an unimplemented recommendation does not imply that it was verified as implemented but rather
that it was reported as being completed.
12-P-0125 Early Warning Report: Use of Unapproved Asbestos Demolition Methods May Threaten Public
Health (OA, Recommendation 6)
12-P-0320 Policies Needed for Proper Use and Management of Cost-Reimbursement Contracts Based on
Duncan Hunter Act (OARM, Recommendation 1)
12-1-0073 Audit of EPA's Fiscal 2011 and 2010 Consolidated Financial Statements
(OARM, Recommendations 11 and 12)
ll-P-0001 EPA Lacks Internal Controls to Prevent Misuse of Emergency Drinking Water Facilities
(OW, Recommendations 2-1,2-2,2-3, and 2-4)
10-P-0177 EPA Revised Hiring Process Needs Additional Improvements (OARM, Recommendation 3-2)
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