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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
•	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
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.