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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Cleaning up and revitalizing land
Operating efficiently and effectively
EPA's Distribution of
Superfund Human Resources
Does Not Support
Current Regional Workload
Report No. 17-P-0397	September 19, 2017

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Report Contributors:	Tina Lovingood
Patrick Milligan
Kate Robinson
Nirvair Stein
Abbreviations
CFR
Code of Federal Regulations
DoD
U.S. Department of Defense
EPA
U.S. Environmental Protection Agency
FTE
Full-Time Equivalent
FY
Fiscal Year
NAVFAC
Naval Facilities Engineering Command
NPL
National Priorities List
NRBPP
National Risk-Based Priority Panel
OCFO
Office of the Chief Financial Officer
OIG
Office of Inspector General
OLEM
Office of Land and Emergency Management
USACE
U.S. Army Corps of Engineers
Cover photo: View of Commencement Bay Nearshore Tideflats Superfund site. As of
FY 2016, portions of this site do not have remedial project managers assigned
and work has slowed in these areas due to lack of FTEs. (EPA photo)
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*	U.S. Environmental Protection Agency	17-P-0397
JHLrS Office of Inspector General	September 19,2017
\
—At a Glance
Why We Did This Review
We evaluated whether the
U.S. Environmental Protection
Agency's (EPA's) distribution of
Superfund human resources
among EPA regions supports
the current regional workload.
In the past 21 years, the EPA
Office of Inspector General
(OIG) and U.S. Government
Accountability Office have
issued over 10 reports citing
the need for the EPA to
implement workload analysis
into its human resource
distributions. In the 1980s, the
EPA conducted comprehensive
workload analyses to determine
appropriate workforce levels
and each year, with regional
consensus, evaluated need
and allocated its human
resources accordingly.
However, in 1987, the agency
chose to no longer redistribute
Superfund staff positions
across the regions and, as a
result, the distribution of full-
time equivalent staff was
focused on marginal changes.
This report addresses the
following:
•	Cleaning up and
revitalizing land.
•	Operating efficiently
and effectively.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.aov/oia.
EPA's Distribution of Superfund Human Resources
Does Not Support Current Regional Workload
What We Found
The distribution of Superfund full-time equivalents
(FTEs) among EPA regions does not support
current regional workloads. As a result, some
regions have had to prioritize work and have slowed
down, discontinued or not started cleanup work due
to a lack of FTEs, while other regions have not had
to resort to such actions. In a survey of EPA
regions, in fiscal years 2015 and 2016, six of 10
regions said they were not able to start, or had to
discontinue, work due to lack of FTEs.
Due to insufficient
human resources to
cover all Superfund site
work, some regions
have had to slow down
or discontinue their
efforts to protect human
health and the
environment.
The EPA's Superfund program has only marginally changed the FTE distribution
in 30 years because it believes redistribution would cause a disruption of work
and there is general management unwillingness to redistribute FTEs. Some sites
where work has slowed down or been discontinued do not have "human
exposure under control" or "groundwater migration under control." Other impacts
include loss of subsistence fishing and continued contamination with chemicals
such as lead and mercury.
Other federal organizations that perform similar site cleanups demonstrate
opportunities for the EPA to align its workload prioritization and FTE distribution
according to a national risk-based prioritization structure. For example, two
Department of Defense (DoD) organizations—the U.S. Army Corps of Engineers
and the Naval Facilities Engineering Command—require, pursuant to DoD
regulations, prioritization of sites based on risk and other factors. According to
the DoD, funds supporting FTEs are distributed nationwide to the highest
prioritized sites.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Land and Emergency
Management address past obstacles to resource allocation; review the
U.S. Army Corps of Engineers and Naval Facilities Engineering Command
workload management and FTE distribution practices to identify those aspects of
the process that may be beneficial for the EPA to adopt; implement a national
prioritization of all sites (except emergency and time-critical removal actions and
federal facilities); regularly distribute regional FTEs according to that
prioritization; and obtain relevant data from regions. All recommendations are
resolved with agreed-to actions pending.
Listing of OIG reports.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 19, 2017
MEMORANDUM
SUBJECT: EPA's Distribution of Superfund Human Resources Does Not Support
Current Regional Workload
Report No. 17-P-0397
FROM: Arthur A. Elkins Jr.
TO:
Barry Breen, Acting Assistant Administrator
Office of Land and Emergency Management
This is our report on the subject review conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this review was OPE-FY16-0015.
This report contains findings that describe the problems the OIG has identified and corrective actions the
OIG recommends. This report represents the opinion of the OIG and does not necessarily represent the
final EPA position. Final determinations on matters in this report will be made by EPA managers in
accordance with established audit resolution procedures.
The EPA's Office of Land and Emergency Management is responsible for the EPA's Superfund cleanup
program.
Action Required
The agency agreed with all recommendations and provided planned corrective actions and completion
dates; all recommendations are resolved with agreed-to actions pending. Therefore, the agency is not
required to provide a written response to this final report. Please update the EPA's Management Audit
Tracking System as you complete the planned corrective actions. Please notify my staff if there is a
significant change in the agreed-to corrective actions. Should you choose to provide a response to this
final report, we will post your response on the OIG's public website, along with our memorandum
commenting on your response. You should provide your response as an Adobe PDF file that complies
with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended.
We will post this report to our website at www.epa.gov/oig.

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EPA's Distribution of Superfund Human Resources
Does Not Support Current Regional Workload
17-P-0397
Table of Contents
Chapters
1	Introduction 		1
Purpose		1
Background		1
Responsible Offices		3
Scope and Methodology		3
2	Superfund FTEs Are Not Distributed Nationally Based on
Workload or National Priorities 		4
Lack of Management Will and Potential Short-Term Disruption
Deter Distribution by Workload		4
Site Cleanup Work Impacted by Current Distribution of
Superfund FTEs		5
EPA Does Not Nationally Prioritize All Sites and Distribute FTEs
Accordingly		6
Practices Used by Other Federal Departments Could Be Beneficial		8
Conclusion		9
Recommendations		9
Agency Response and OIG Evaluation 		10
Status of Recommendations and Potential Monetary Benefits		11
Appendices
A Agency Response to Draft Report		12
B Revised Recommendations and Agreed-To
Agency Corrective Actions		16
C Distribution		18

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Chapter 1
Introduction
Purpose
The purpose of this evaluation was to determine whether the U.S. Environmental
Protection Agency's (EPA's) distribution of Superfund resources1 among the
EPA regions supports the current regional workload. This evaluation was
conducted in response to an agency request.
Background
Prior Reports
The EPA has not incorporated workload analysis into its resource allocations
despite years of reporting by the EPA Office of Inspector General (OIG) and the
Government Accountability Office that this should be done. The OIG and the
Government Accountability Office have issued over 10 reports since 1996
identifying the agency's need to incorporate workload into allocating resources
agency-wide. As a result, the OIG continues to keep workload as one of the
agency's management challenges.
History of Superfund Distribution of Full-Time Equivalents (FTEs)
During the 1980s, the EPA conducted comprehensive workload analyses to
determine appropriate workforce levels, including the Superfund program.
According to EPA personnel, in 1987 the EPA decided it would discontinue these
analyses as it had become problematic, and instead focused on marginal changes
to FTE distribution. The EPA's programs were maturing and becoming more
established, budgets began to level off, and as a result the EPA began adjusting
the size of its workforce via incremental shifts from prior-year levels.
In responding in part to an OIG report recommendation,2 in 2008, the EPA
Superfund program undertook a Workload Assessment Study and found an
1	For purposes of this report, resources are human resources or FTEs used in the Superfund program for the cleanup
of all sites in the pre-remedial, study, design and remedial phases of cleanup; and sites with non-time-critical
removal actions. Emergency and time-critical removal actions, and federal facility sites, are excluded from the scope
of this evaluation. Emergency and time-critical removal actions are excluded because they are responses that are not
planned. Federal facility sites are excluded because, according to the EPA, they currently use a workload model that
factors in FTEs.
2	The 2006 OIG report, EPA Can Better Manage Superfund Resources (Report No. 2006-P-00013). issued
February 28, 2006, was completed in response to a congressional request to evaluate Superfund expenditures and
recommend options to increase resources directed to extramural cleanup while minimizing administrative costs.
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imbalanced resource distribution among the EPA's 10 regions. Specifically, the
report found that the distribution of fiscal year (FY) 2006 FTEs was not
proportional to future workload. However, the Superfund program decided that
moving or rebalancing resources would likely produce substantial disruption,
which could cause a short-term decrease in the national output. The Superfund
program declined to make any substantive changes to the FTE distribution.
The EPA has not revised the methodology behind its distribution of Superfund
resources to EPA regions, despite its own data showing that regional distribution
of Superfund National Priorities List (NPL) sites has changed.3 The status of sites
has evolved overtime. In 1987, many Superfund sites were in the early stages of
the cleanup process, while the majority are now in the construction complete
phase, as shown in Figure 1. By the end of FY 2015, the EPA had achieved
construction completion on a large majority of NPL sites.4
Figure 1: Status of proposed, final and deleted NPL Superfund sites (FYs 1987-2015)
1800
1600
1400
1200
1000
800
600
400
200
0
FY87 FYB9 FY91 FY93 FY95 FY97 FY99 FY01 FY03 FY05 FY07 FY09 FY11 FY13 FY15
~ RenedialAssesmerrt Not Begun ~ Study Underway
R em edy Selected	~ Design U nd enh a,1
¦ Construction Underway	~ Construction Completed
Source: OIG analysis of EPA data.
Changes in regional NPL distribution, and progress in completing cleanup at existing
NPL sites can significantly change the regional need for Superfund resources.
One of the goals in the EPA Administrator's July 2017 "Superfund Task Force
Recommendations" report is to expedite Superfund cleanups and remediation.
This goal recognizes that re-prioritizing some resources to focus on remedial
actions, construction completions, ready-for-reuse determinations, and deletions will
be necessary.
3	According to the EPA, the Federal Facilities Restoration and Reuse Office undertook a workload model analysis in
FY 2014 that reviewed the distribution of FTEs for FY 2014 and projected need for FYs 2015 and 2016. Some
adjustments were made to FTE allocation at that time.
4	OLEM provided to OIG the most recent site status data for alternating years, beginning in 2005.
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Responsible Offices
The Office of Land and Emergency Management (OLEM) is responsible for the
EPA's Superfund Cleanup program. The Office of the Chief Financial Officer
(OCFO) determines the annual distribution of Superfund FTEs, and OLEM
decides how the allocation will be made to the regions. The Office of
Enforcement and Compliance Assurance is responsible for enforcement of the
Superfund program.
Scope and Methodology
We conducted our work from February 2016 to July 2017. We conducted this
performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objective. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objective.
We interviewed EPA headquarters staff in OLEM and OCFO to understand the
EPA budget cycle as it relates to FTE distribution at headquarters and the regions.
We also interviewed Superfund staff in Regions 9 and 10, and the Comptroller for
Region 10. We met with managers and staff from the U.S. Department of Energy
and for two organizations within the U. S. Department of Defense (DoD)—the
U.S. Army Corps of Engineers (US ACE) and the Naval Facilities Engineering
Command (NAVFAC)—to obtain information on how they prioritize the cleanup
of sites and distribute FTEs. We met with US ACE and NAVFAC because they
are other federal agencies that perform hazardous site cleanups.
We analyzed national Superfund data, including the remedial investigation/
feasibility study, remedial design and remedial action starts and completions, time
charging data from Compass Financials, and data on site status. We performed
analysis on data provided by Regions 9 and 10 on Superfund sites impacted by the
allocation of FTEs, and on data provided by the Office of Enforcement and
Compliance Assurance. We reviewed documents including Office of
Management and Budget circulars, National Program Manager Guidance, the
National Contingency Plan, and OCFO Funds Control Manual. We also reviewed
32 CFR § 179.1, which directs the DoD to assign a relative priority for response
activities at sites.
We conducted an online survey of the EPA's Superfund Regional Directors for all
10 regions in August 2016, which addressed three areas: workload, FTE
distribution and Superfund site work prioritization. We received responses from
all 10 regions—a response rate of 100 percent.
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Chapter 2
Superfund FTEs Are Not Distributed Nationally
Based on Workload or National Priorities
The distribution of Superfund FTEs among EPA regions does not support the
current regional workload. As a result, some regions have had to prioritize work
and have had to slow down, discontinue or not start cleanup work due to a lack of
FTEs. The EPA's Superfund program has generally not changed the national FTE
distribution in 30 years because it believes redistribution would cause a disruption
of work and there is a general management unwillingness to redistribute FTEs.
Some sites where work has slowed down or been discontinued do not have
"human exposure under control" or "groundwater migration under control." Other
impacts include loss of subsistence fishing and human health exposure to
chemicals such as lead and mercury.
Other federal organizations that perform similar site cleanups demonstrate
opportunities for the EPA to align its workload prioritization and FTE distribution
according to a national risk-based prioritization structure. For example, two DoD
organizations—the US ACE and NAVFAC—require, pursuant to DoD
regulations, prioritization of sites based on risk and other factors. According to the
DoD, funds that support FTEs are distributed nationwide according to the highest
prioritized sites.
Lack of Management Will and Potential Short-Term Disruption
Deter Distribution by Workload
We spoke to directors in OLEM's Office of Superfund Remediation and
Technology Innovation, and they acknowledged that Superfund FTEs are not
distributed consistent with current workload. Since 1987—30 years ago—only
marginal adjustments in FTEs have been made, and those adjustments were not
based on workload. One OLEM director noted that how FTEs are distributed is
influenced by the EPA's OCFO and Office of Administration and Resources
Management, and is atop-down allocation of FTEs.
Agency officials said that management lacks the will to shift FTEs between
regions annually. Rebalancing resources through such shifts is believed to cause
substantial short-term disruption of program outputs. As a result, OLEM has
opted to retain the current distribution year to year. OLEM directors and staff also
said there are complexities to changing the FTE distribution process. Regions
know what resources they need but it is difficult to plan for what they will need
because there is no formal process within the budget cycle where workload is
taken into consideration.
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Site Cleanup Work Impacted by Current Distribution of Superfund FTEs
Due to declining FTEs and the frozen distribution of FTEs since 1987, some
regions have had to stop or slow down cleanup work at sites. For example, in
2011, Region 10 used the criteria from
the National Risk-Based Priority Panel
(NRBPP) to prioritize its sites and, due
to lack of resources, the region either
discontinued or slowed work at
49 Superfund sites. In 2016, Region 10
had not assigned staff at 34 sites or
portions of sites.5 Of these 34 sites,
16 are currently on the NPL, 10 have
Native American interest, and two are
megasites.6 Four of the sites show the
status of the performance measure as
"human exposure is not under control,"
and three sites show the performance
measure as "groundwater migration is
not under control."7
Similarly, Region 9 had 14 NPL sites impacted by lack of resources and frozen
FTEs, wherein sites needed to be placed on hold or had project delays.
Our survey asked regions if they had work they have not been able to start or had
to discontinue due to lack of FTEs in FYs 2015 and 2016. Six regions answered
"Yes" (Regions 1, 3, 6, 8, 9 and 10) and four answered "No" (Regions 2, 4, 5 and
7). One of the regions that responded "No" qualified its response to say that it has
had to slow work at some sites and may manage sites with insufficient FTEs.
Specifically, the region stated in the survey:
While we indicated that no work has been discontinued due to a
lack of FTE, this should not be construed as an indication that site
work is adequately covered. It is important to know how we
distribute work within the region. We assign ALL sites to a project
manager regardless of how many FTE we have. This means that
our project managers are loaded up with multiple sites at the same
5	Region 10 has work at 34 sites but does not have enough staff to complete all of this work at this time. For
example, while there is a remedial project manager assigned to the Lower Duwamish Waterway Superfund site, the
work at this site exceeds the number of staff needed to complete it at this time.
6	A megasite is a potentially complex and expensive contaminated sediment and mining site where the total cost of
cleanup equals or exceeds $50 million.
7	"Human Exposure Is Not Under Control": Sites are assigned this category when (1) contamination has been
detected at an unsafe level, and (2) a reasonable expectation exists that people may be exposed to the contamination.
"Groundwater Migration Is Not Under Control": This category indicates that all information on known and
reasonably expected groundwater contamination has been reviewed and the migration of contaminated groundwater
is not stabilized.
Cleanup Slowed by Lack of FTEs
Region 10
Lower Duwamish Waterway, Seattle, Washington
This site is considered "Human Exposure Is Not Under
Control" because sediment and tissue data samples
have shown that eating certain fish and shellfish from
the river may result in unacceptable exposures to
humans. It is estimated that a population of 5,208
people are potentially impacted at this site. The
contaminants in the waterway sediments include
polychlorinated biphenyls (PCBs), polyaromatic
hydrocarbons (PAHs), arsenic, and dioxins/furans.
The Washington Department of Health has posted and
publicized fishing advisories, but people are still
harvesting and eating bottom fish and shellfish from the
river. According to Region 10 management, the lack of
FTEs has slowed progress at this site.
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time, which results in slower progress at some sites. We
continuously emphasize the priority of high risk site work, so sites
that are lower risk will progress at a slower pace (but they won't be
stopped altogether). Project managers, in consultation with their
supervisors, are constantly evaluating and adjusting priorities in
order to distribute their time to the highest priority. Additional FTE
in the program would alleviate this burden and would certainly
accelerate progress at our sites.
Region 8 stated in its survey response that it had site work it could not start due to
lack of FTEs at the Silver Bow Creek/Butte AreaNPL site in Butte, Montana.
Specifically, work is currently delayed at the West Side Soils Operable Unit
(OU13), which includes the mining-impacted areas in and around the city. For the
site, potential health threats include direct contact with and ingestion of
contaminated soil, surface water and groundwater; and inhaling contaminated
soil. Contaminants of concern include arsenic, cadmium, copper, lead and zinc.
The EPA reports that it has insufficient data to determine whether human
exposure is under control, and the site is not ready for anticipated use. Region 8
also added that other sites could be advancing more quickly through the NPL
process if they had additional regional project manager FTEs to assist in the work.
A portion of the Silver Bow Creek/Butte Area Superfund site. (EPA photo)
EPA Does Not Nationally Prioritize All Sites and Distribute FTEs
Accordingly
The EPA does not nationally prioritize all of its Superfund-financed work
according to a "worst first" method. The EPA nationally prioritizes the funding of
new Superfund-financed remedial action and high-cost removal action starts using
its NRBPP. However, the EPA does not distribute the FTEs required to support
the priorities identified by the NRBPP. According to the OIG survey results, in
addition to the NRBPP prioritization, some regions also prioritize remedial and
removal work. However, FTEs are allocated separately from national risk-based
prioritization of work and other factors impacting cleanups.
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NRBPP Prioritizes Sites Without Corresponding Shift in
FTE Distribution
In 1995, amid severe budget reductions, the EPA moved away from regional
prioritization to a national prioritization system for all high-cost removals and
new start remedial action projects. The NRBPP uses five criteria and associated
weighting factors to compare projects, as shown in Figure 2. Each region sends its
priority projects to be compared and ranked against priority projects from other
regions.
Figure 2: National risk-based priority panel criteria
1.
Risks to human population exposed: Population size, proximity to contaminants,
likelihood of exposure.
2.
Stability: Mobility of contaminant, site structure, and effectiveness of any
institutional or physical controls.
3.
Contaminant characteristics: Concentration, toxicity and volume.
4.
Threat to a significant environment: Endangered species or their critical
habitats, sensitive environmental areas.
5.
Program measurement consideration: Innovative technologies, cost delays, high
profile projects, environmental justice, state involvement, Brownfields/economic
redevelopment.
Source: EPA's Superfund National Risk-Based Priority Panel website.
EPA Regions inconsistentiy Prioritize Remaining Work, but Allocate
FTEs According to the Regional Priorities
According to some regional survey responses, Superfund FTEs are prioritized
regionally to address work that has the most potential negative impacts on human
health and the environment. The OIG survey asked regions if they use a formal
process to prioritize Superfund site work. Nine of 10 regions8 responded that they
use a formal process for site prioritization other than the hazard ranking system.
Regions listed different processes they use to prioritize Superfund site work.
These included: site management meetings; national review of best practices;
National Prioritization Panel and Remedial Action Prioritization Panel;9
National Contingency Plan 300.405, 300.410 and 300.415; Superfund Enterprise
Management System; meetings with states; annual work planning template;
Government Performance and Results Act and Superfund Comprehensive
Accomplishment Plan targets; and response prioritization criteria and remedial
prioritization criteria.
8	One region responded that it did not use a formal process to prioritize Superfund site work (other than the hazard
ranking index).
9	According to OLEM, the regions were referring to the NRBPP when they responded with "National Prioritization
Panel" and "Remedial Action Prioritization Panel."
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At least one region is prioritizing site work in an attempt to address higher-
priority sites with decreasing funds and FTEs. Region 10 uses a ranking process
that captures the same criteria that the NRBPP uses, except that the region has an
additional criterion—the addition of new work (e.g., starting a new remedial
investigation/feasibility study versus completing construction, post-construction
work).
Practices Used by Other Federal Departments Could Be Beneficial
The DoD has regulations that require national prioritization of sites for cleanup
under their jurisdiction. Once the sites are prioritized, the agencies distribute
resources needed to the highest-priority sites. US ACE and NAVFAC manage
fluctuations in resources between their regions by conducting long-term planning.
OLEM officials acknowledge that long-term planning has been a challenge in the
Superfund program and, instead, the EPA uses an annualized process. Conversely,
most EPA regions have methods and criteria for prioritizing types of site work, but
the EPA does not allocate FTEs based on workload.
In the FY 2002 National Defense Authorization Act, Congress directed the DoD to
develop a protocol for assigning a relative priority for response actions conducted
by the DoD on defense sites. The DoD issued 32 CFR Section 179.1, which:
require [s] that the Department assign to each defense site in the
inventory... a relative priority for response activities based on the
overall conditions at each location and taking into consideration
various factors related to safety and environmental hazards.
In accordance with DoD Manual 4715.20, USACE and NAVFAC prioritize all
sites based on "worst first," meaning that each agency "address[es] sites that pose
a relatively greater potential risk to public safety, human health, and the
environment before sites posing a lesser risk." These agencies use a relative risk
site evaluation or other risk evaluation criteria to prioritize the sites nationally.
Pursuant to 32 CFR Section 179.7 and DoD Manual 4715.20, USACE and
NAVFAC "sequence" funding of the actions—such as remedial actions,
preliminary assessment, etc.—based primarily on the national risk-based
workload. Other factors, such as state input and environmental justice concerns,
may also be considered in sequencing action funding. According to the DoD,
FTEs are then distributed based on the prioritized, funded actions. USACE and
NAVFAC conduct long-term planning for site cleanups, including the cost of
staff. The long-term planning may help address impacts from tight fiscal
constraints, future challenges and evolving requirements. Emergency work is
exempt from the national ranking.
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Conclusion
The distribution of Superfund FTEs does not support, and is not aligned with,
current regional workload. With decreasing budgets and FTEs, it is imperative that
the EPA understands Superfund risks, prioritizes them, and distributes its FTEs in a
manner that sufficiently addresses risks. The EPA should examine the feasibility of
adopting the USACE's and NAVFAC's workload management and FTE
distribution practices. The EPA needs to collect and analyze risk-based workload
data from the regions and incorporate the data into its budget cycle to create a
distribution of FTEs to the regions based on national priorities and other factors
affecting cleanups. The EPA could use the data to better ensure that the most
needed cleanup work is funded, and optimize its limited resources to most
effectively protect human health and the environment. Such efforts are well aligned
with the EPA Administrator's emphasis on cleaning up the country's worst pollution
as expeditiously and as thoroughly as possible.
Recommendations
We recommend that the Assistant Administrator for Land and Emergency
Management:
1.	In coordination with the Chief Financial Officer, develop and implement
actions to address past obstacles that have affected the EPA's ability to make
progress on the allocation of human resources. Obstacles include
management's unwillingness to change its human resource allocation process
and perceived short-term disruptions that would result from such a change.
2.	Review the U.S. Army Corps of Engineers and Naval Facilities
Engineering Command workload management and full-time equivalent
distribution practices to identify those aspects that may be beneficial for
the EPA to adopt.
3.	Implement a national prioritization of all sites10 including risk and other
factors in the prioritization and regularly distribute regional full-time
equivalents according to the national prioritization.
4.	Obtain information from the regions necessary to carry out
Recommendations 2 and 3.
10 Includes all sites in the Superfund program in the pre-remedial, study, design and remedial phases of cleanup; and
sites with non-time-critical removal actions. Emergency and time-critical removal actions, and federal facility sites,
are excluded from the scope of this recommendation. Emergency and time-critical removal actions are excluded
because they are responses that are not planned. Federal facility sites are excluded because, according to the EPA,
they currently use a workload model that factors in FTEs.
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Agency Response and OIG Evaluation
OLEM's original response is in Appendix A. OLEM generally agreed that there
would be benefits to a revised process for distribution of regional FTEs. OLEM
also responded that due to the length and complexity of future Superfund site
work in each region and the significant disruption that annual FTE realignments
may result in, it supports a more measured approach to Superfund FTE allocation
that applies a longer-term planning horizon. We met with OLEM staff and had
subsequent communications to discuss their comments. Based on our
communication, we revised Recommendations 3 and 4, and OLEM agreed to a
revised corrective action plan (Appendix B). All recommendations are resolved
with agreed-to actions pending.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS






Potential





Planned
Monetary
Rec.
Page



Completion
Benefits
No.
No.
Subject
Status1
Action Official
Date
(in $000s)
9 In coordination with the Chief Financial Officer, develop and
implement actions to address past obstacles that have affected
the EPA's ability to make progress on the allocation of human
resources. Obstacles include management's unwillingness to
change its human resource allocation process and perceived
short-term disruptions that would result from such a change.
9 Review the U.S. Army Corps of Engineers and Naval Facilities
Engineering Command workload management and full-time
equivalent distribution practices to identify those aspects that
may be beneficial for the EPA to adopt.
9 Implement a national prioritization of all sites2 including risk and
other factors in the prioritization and regularly distribute regional
full-time equivalents according to the national prioritization.
9 Obtain information from the regions necessary to carry out
Recommendations 2 and 3.
Assistant Administrator for 9/30/18
Land and Emergency
Management
Assistant Administrator for 3/31/18
Land and Emergency
Management
Assistant Administrator for 9/30/18
Land and Emergency
Management
Assistant Administrator for 12/31/17
Land and Emergency
Management
1	C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
2	Includes all sites in the Superfund program in the pre-remedial, study, design and remedial phases of cleanup; and sites with non-time-critical removal
actions. Emergency and time-critical removal actions, and federal facility sites, are excluded from the scope of this recommendation. Emergency and time-
critical removal actions are excluded because they are responses that are not planned. Federal facility sites are excluded because, according to the EPA,
they currently use a workload model that factors in FTEs.
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Appendix A
Agency Response to Draft Report
AUG 08 2017
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report No. OPE-FY16-0015
"EPA's Distribution of Superfund Human Resources Does Not Support Current
Regional Workload," July 7, 2017
FROM: Barry N.Breen
Acting Assistant Administrator
TO:	Carolyn Copper, Assistant Inspector General
Office of Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. The following is a summary of our overall position, along with our position on each of
the report recommendations. For those report recommendations with which we agree, we will
provide corrective actions and estimated completion dates to the extent we can, following the
release of the final OIG report. For your consideration, we have included a Technical Comments
Attachment to supplement this response.
AGENCY'S OVERALL POSITION
The Office of Land and Emergency Management (OLEM) generally agrees that there would be
benefits to a revised process for distribution of regional Full Time Equivalent (FTE) adjustments.
Since an annual realignment of Superfund FTE across regions would cause disruption, it seems
more effective to adopt a longer term planning horizon for FTE adjustment. The adoption of a
multi-year FTE plan could allow flexibility to redistribute FTE among the regions more
effectively. This plan would need to be determined among OLEM, OCFO, and the regions.
Additionally, it would need to coordinate with Federal Facilities and Removal staff at
headquarters and the regions, who were not interviewed in the conduct of this audit. Finally, as
the OIG report points out, there are many considerations other than risk that support resource
decision making including regional workload, community concerns, environmental justice, and
other considerations.
Recommendation 1 encourages OLEM to work with Office of the Chief Financial Officer
(OCFO) to develop and implement actions to address past obstacles that have affected EPA's
ability to make progress on the allocation of human resources. OLEM will coordinate with
OCFO, in coordination with the regions, to develop a multi-year regional FTE plan for the
Superfund program. In FY2014, the Federal Facilities Restoration and Reuse Office (FFRRO)
undertook a workload model to determine if FTE were appropriately distributed for planned
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work in the current and upcoming two fiscal years. A small number of FTE was redistributed
between a few regions. Since then, FFRRO has focused on work sharing between regions, in
order to respond to human resource needs in a more timely and nimble manner.
Recommendation 2 requests that EPA review the U.S. Army Corps of Engineers (USACE) and
Naval Facilities Engineering Command (NAVFAC) workload management and FTE distribution
practices to identify those aspects that may be beneficial for EPA to adopt. While OLEM will
undertake an effort to review these practices to determine their applicability to the Superfund
program, there are significant differences between EPA and DOD sites. For example, the DOD
site inventory is generally fixed and EPA's continues to grow; most DOD sites have been
characterized to a reasonable degree, whereas a considerable number of EPA's have not been;
and, the DOD has greater ability to dispatch environmental FTE to sites and the ability to
redistribute FTE at their sites which provides a flexibility to a degree that EPA does not have.
Recommendation 3 highlights the need for EPA to implement a national risk-based prioritization
of all sites (which could include other factors in the prioritization) and regularly distribute
regional FTE according to the national risk-based prioritization. Due to the length and
complexity of future Superfund site work in each region and the significant disruption that
annual FTE realignments may result in, we support a more measured approach to Superfund FTE
allocation that applies a longer term planning horizon. The horizon would have to be determined
between OLEM, OCFO, and the regions.
Recommendation 4 requires the EPA regions to submit to OLEM the information necessary to
carry out Recommendations 2 and 3. OLEM will solicit input from OECA and the regions to
respond to the OIG's recommendations.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated Completion by
Quarter and FY
1
In coordination with the
Chief Financial Officer,
develop and implement
actions to address past
obstacles that have
affected the EPA's ability
to make progress on the
allocation of human
resources.
1.1 OLEM will meet with
OCFO to discuss regional
FTE distribution issues for the
Superfund program.
2nd quarter FY2018
1.2 OLEM will partner with
OCFO to develop a multi-year
regional FTE distribution plan
for the Superfund program.
4th quarter FY2018
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2
Review the U.S. Army
Corps of Engineers and
Naval Facilities
Engineering Command
workload management and
full-time equivalent
distribution practices to
identify those aspects that
may be beneficial for the
EPA to adopt.
2.1 OLEM will review the
USACE and Naval Facilities
Engineering Command
workload management and
full-time equivalent
distribution practices to
determine their applicability
to the Superfund program.
2nd quarter FY2018
3
Implement a national risk-
based prioritization of all
sites (which could include
other factors in the
prioritization) and
regularly distribute
regional full-time
equivalents according to
the national risk-based
prioritization.
3.1 OLEM will work with
OECA, OCFO and the regions
to develop a multi-year
regional FTE distribution plan
for the Superfund program.
4th quarter FY2018
4
Require the EPA regions to
submit to OLEM the
information necessary to
carry out
Recommendations 2 and 3.
4.1 OLEM will solicit input
from OECA, OCFO and the
regions to respond to the
OIG's recommendations.
1st quarter FY2018
If you have any questions regarding this response, please contact Art Flaks, in OLEM's Office of
Superfund Remedial and Technology Innovation, at (703)-603-9088.
Attachment
cc: Nigel Simon
Patrick Davis
James Woolford
Reggie Cheatham
Charlotte Bertrand
Cynthia L. Mackey, OECA/OSRE
Carol Terris, OCFO
Karen Melvin, Region 3
Jennifer Wilbur
Tina Lovingood, OIG
Patrick Milligan, OIG
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Kecia Thornton
Art Flaks
Kevin Hollingsworth
Daniel Ginsburg
Jenee Sharon
Regional Audit Follow-Up Coordinators, Regions 1-10
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Appendix B
Revised Recommendations and
Agreed-To Agency Corrective Actions
AUG 25 2017
No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated Completion by
Quarter and FY
1
In coordination with the
Chief Financial Officer,
develop and implement
actions to address past
obstacles that have
affected the EPA's ability
to make progress on the
allocation of human
resources.
1.1 OLEM will meet with
OCFO to discuss regional
FTE distribution issues for
the Superfund program to
develop and implement
actions to address past
obstacles that have affected
the EPA's ability to make
progress on the allocation of
human resources.
2nd quarter FY2018
1.2 OLEM will partner with
OCFO to develop a multi-
year regional FTE
distribution plan for the
Superfund program to
facilitate EPA's ability to
make progress on the
allocation of human
resources.
4th quarter FY2018
2
Review the U.S. Army
Corps of Engineers and
Naval Facilities
Engineering Command
workload management
and full-time equivalent
distribution practices to
identify those aspects that
may be beneficial for the
EPA to adopt.
2.1 OLEM will review the
USACE and Naval
Facilities Engineering
Command workload
management and full-time
equivalent distribution
practices to determine their
applicability to the
Superfund program.
2nd quarter FY2018
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3
Implement a national
prioritization of all sites10
including risk and other
factors in the
prioritization and
regularly distribute
regional full-time
equivalents according to
the national prioritization.
3.1 OLEM will work with
OECA, OCFO and the
regions to develop a multi-
year national FTE
distribution plan for the
Superfund program.
Distribution of FTE will
occur regularly according to
the national prioritization.
4th quarter FY2018
4
Obtain information from
the regions necessary to
carry out
Recommendations 2 and
3.
4.1 OLEM will solicit input
from OECA, OCFO and the
regions to respond to the
OIG's recommendations
and obtain information
necessary to carry out
Recommendations 2 and 3.
1st quarter FY2018
10 Includes all sites in the Superfund program in the pre-remedial, study, design, and remedial
phases of cleanup; and sites with non-time-critical removal actions. Emergency and time-critical
removal actions, and federal facility sites, are excluded from the scope of this recommendation.
Emergency and time-critical removal actions are excluded because they are responses that are
not planned. Federal facility sites are excluded because, according to the EPA, they currently use
a workload model that factors in FTEs.
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Appendix C
Distribution
The Administrator
Chief of Staff
Chief of Staff for Operations
Deputy Chief of Staff for Operations
Assistant Administrator for Land and Emergency Management
Assistant Administrator for Administration and Resources Management
Chief Financial Officer
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Regional Administrators, Regions 1-10
Controller, Office of the Controller, Office of the Chief Financial Officer
Deputy Controller, Office of the Controller, Office of the Chief Financial Officer
Principal Deputy Assistant Administrator, Office of Land and Emergency Management
Deputy Assistant Administrator, Office of Land and Emergency Management
Deputy Assistant Administrator, Office of Administration and Resources Management
Director of Regional Operations
Director, Office of Superfund Remediation and Technology Innovation,
Office of Land and Emergency Management
Deputy Director, Office of Superfund Remediation and Technology Innovation,
Office of Land and Emergency Management
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Administration and Resources Management
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of the Controller, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of Land and Emergency Management
Audit Follow-Up Coordinators, Regions 1-10
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