\
^EDSX
Q
pro"^0
O
z
UJ
o
T
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
EPA Has Not Fully Implemented a
National Emergency Response
Equipment Tracking System
Report No. 11-P-0616
September 13, 2011

-------
Report Contributors:
Richard Eyermann
Mike Davis
Jennifer Hutkoff
Heather Layne
Gul Sharma
Abbreviations
CPIC
Capital Planning and Investment Control
EMP
Emergency Management Portal
EPA
U.S. Environmental Protection Agency
ERT
Environmental Response Team
NDT
National Decontamination Team
NEMS
National Equipment Management System
OEM
Office of Emergency Management
OIG
Office of Inspector General
OMB
Office of Management and Budget
OSWER
Office of Solid Waste and Emergency Response
SLCM
System Life Cycle Management
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail:	OIG Hotline@epa.gov	write: EPA Inspector General Hotline
phone: 1-888-546-8740	1200 Pennsylvania Avenue NW
fax:	703-347-8330	Mailcode 8431P (Room N-4330)
online:	http://www.epa.qov/oiq/hotline.htm	Washington, DC 20460

-------
£
33
\

PRO^°
o
in
(J
T
U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
11-P-0616
September 13, 2011
Why We Did This Review
We initiated this audit based
on a Hotline complaint related
to the Emergency Management
Portal (EMP) equipment
tracking module. Our
objectives were to determine
the extent to which the U.S.
Environmental Protection
Agency (EPA) implemented
the EMP equipment tracking
software, what efforts EPA has
made to assess functionality
and cost effectiveness, and
how the EMP equipment
module compared to the
previous interim system.
Background
Since September 11, 2001,
EPA's emergency response
focus has expanded to better
coincide with its new role in
homeland security. In May
2002, EPA determined that it
needed to create a national
equipment tracking system to
be better prepared for terrorist
acts and nationally significant
incidents.
For further information,
contact our Office of
Congressional, Public Affairs
and Management at
(202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2011/
20110913-11-P-0616.pdf
Catalyst for Improving the Environment
EPA Has Not Fully Implemented a National
Emergency Response Equipment Tracking System
What We Found
Although EPA spent $2.8 million as of October 2010 to develop and implement an
EMP emergency equipment tracking module, EPA has not fully implemented the
module, and the module suffers from operational issues. Our review of allegations
in a Hotline complaint found that:
•	EPA does not fully use the EMP equipment tracking module because no
EPA office with overall authority has mandated its use.
•	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.
EPA has guidance and policies that require the Agency to develop and implement a
plan for a national equipment tracking system. Both the Office of Management and
Budget and EPA require performance measurement of such systems. However,
EPA has not fulfilled this requirement. In addition to the $2.8 million it has already
spent, 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 EPA has not fully implemented the EMP equipment module and the
module is cumbersome and slow, EPA's ability to protect public health and the
environment in the event of a nationally significant incident may be impaired.
What We Recommend
We recommend that the Assistant Administrator for Solid Waste and Emergency
Response ensure that only essential equipment tracking data are required to be
recorded and determine whether the EMP equipment module is the most cost-
efficient alternative. We also recommend that the EPA Deputy Administrator
mandate that regions and emergency response teams employ the national tracking
system that EPA decides to use for emergency response equipment. The Agency
concurred with the findings and recommendations, but did not provide a corrective
action date for the first recommendation. The Assistant Administrator for Solid
Waste and Emergency Response will hire an outside contractor to conduct an
alternative analysis to determine the most efficient and effective national
emergency response equipment tracking alternative. The Deputy Administrator also
plans to issue a memo requiring the use of the EMP equipment module for tracking
equipment.

-------
^tDsrx
• Q v
S	S UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
% VK# *	WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 13, 2011
MEMORANDUM
SUBJECT:	EPA Has Not Fully Implemented a National Emergency Response
Equipment Tracking System
Report No. ll-P-0616
FROM:	Arthur A. Elkins, Jr.
Inspector General
TO:	Bob Perciasepe
Deputy Administrator
Mathy Stanislaus
Assistant Administrator for Solid Waste and Emergency Response
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the
problems the OIG has identified and corrective actions the OIG recommends. This report
represents the opinion of the OIG and does not necessarily represent the final EPA position.
Final determinations on matters in this report will be made by EPA managers in accordance with
established audit resolution procedures.
The estimated direct labor and travel costs for this report are $197,352.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this
report within 90 calendar days. You should include a corrective action plan for agreed-upon
actions, including milestone dates. Your response will be posted on the OIG's public website,
along with our memorandum commenting on your response. Your response should be provided
as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the
Rehabilitation Act of 1973, as amended. The final response should not contain data that you do
not want to be released to the public; if your response contains such data, you should identify the
data for redaction or removal. We have no objections to the further release of this report to the
public. We will post this report to our website at http://www.epa.gov/oig.

-------
If you or your staff have any questions regarding this report, please contact Melissa Heist,
Assistant Inspector General for Audit, at (202) 566-0899 or heist.melissa@epa.gov; or Richard
Eyermann at (202) 566-0565 or evermann.richard@epa.gov.

-------
EPA Has Not Fully Implemented a National
Emergency Response Equipment Tracking System
11-P-0616
	Table of Contents	
Purpose	1
Background	1
National Equipment Management System	1
Emergency Management Portal	2
Scope and Methodology	2
Prior OIG Audits	3
Results of Review	4
EPA Directives and Policy Require Implementation and Formal
Review of a National Emergency Equipment Tracking System	4
EPA Has Not Performed Formal Functionality and Cost Effectiveness
Assessments of the EMP Equipment Module	5
Equipment Module Not Fully Used Because No EPA Office With
Overall Authority Has Mandated Use	6
The EMP Equipment Module Is Cumbersome and Slow Compared
With NEMS	8
Conclusion	9
Recommendations	10
Agency Comments and OIG Evaluation	10
Status of Recommendations and Potential Monetary Benefits	12
Appendices
A EPA Response to Draft Report	13
B Distribution	17

-------
Purpose
The U.S. Environmental Protection Agency (EPA), Office of Inspector General
(OIG), initiated this audit based on a Hotline complaint. The Hotline complaint
alleged that the regions and environmental response and radiological emergency
response teams were not using the Emergency Management Portal (EMP)
equipment module, and that the module was ineffective and costly. The Hotline
complaint also alleged that a significantly cheaper, previously developed interim
system, the National Equipment Management System (NEMS), was able to
accomplish the same overall objective of nationally tracking emergency response
equipment. Finally, the Hotline complaint alleged that, as of February 2010,
contractor costs in excess of $8 million had been expended for the replacement
EMP system, but that EPA had not fully implemented it.
Based on the allegations, our objectives were to answer the following questions:
•	To what extent has EPA implemented the EMP software for tracking
emergency response equipment?
•	What efforts has EPA made to assess the functionality and cost
effectiveness of its EMP system for emergency response equipment?
•	How does the cost, efficiency, and effectiveness of the EMP
equipment tracking capability compare to NEMS?
Background
Since September 11, 2001, EPA's counterterrorism and emergency response
responsibilities expanded to better coincide with its new role in homeland
security. EPA determined, in part due to these activities, that to be better prepared
for terrorist acts and nationally significant incidents, it needed to purchase more
emergency response equipment, establish maintenance contracts, and create a
national equipment tracking system.
Implementation of a national equipment tracking system has been a long-standing
gap in EPA's emergency support capabilities. The Office of Solid Waste and
Emergency Response's (OSWER's) May 2002 60-Day Task Force Report on the
EPA's Emergency Response Contracting Network initially identified the need to
track emergency response equipment on a national level.
National Equipment Management System
EPA's Edison, New Jersey, Environmental Response Team (ERT) developed
NEMS in 2005 at a cost of $300,000. NEMS was an interim system that provided
a national listing of emergency response equipment. Regions and response teams
maintained their own equipment management systems, but uploaded equipment
data through a Web-based service to NEMS. NEMS allowed regions and response
11-P-0616
1

-------
teams to identify the availability and location of emergency response equipment
stored throughout the nation. EPA never fully implemented NEMS, and it is not
currently in use.
Emergency Management Portal
EPA's Office of Emergency Management (OEM), part of OSWER, designed the
EMP to tie together prevention, preparedness, and response information that
EPA's emergency management community needs to plan for and act on in
emergency situations. OEM began developing the EMP equipment module in
2004 and released it for use in 2007. The EMP equipment module is a
comprehensive equipment system that provides warehouse management functions
that include equipment identification, location, and availability, along with
additional maintenance, repair, and expense records. The EMP also includes
removal and emergency response data on site cleanup, personnel readiness
(training and experience), and technical information in support of field personnel.
OEM developed the EMP equipment module to manage emergency response
equipment throughout the Agency. The primary objective of the module is to
provide information on the availability and location of emergency response
equipment. The module also includes information to assist warehouse managers
in managing and recording calibrations, maintenance, and repairs of their
equipment.
Scope and Methodology
We conducted this audit from September 2010 to June 2011 in accordance with
generally accepted government auditing standards. Those standards require that
we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
We visited OEM at headquarters to obtain an understanding of how it uses the
EMP to manage emergency response equipment, conducted interviews with the
EMP project manager, and participated in a walk-through demonstration of the
EMP equipment module.
We determined the extent to which EPA has implemented the EMP equipment
module through an analysis of documents and interviews with headquarters,
regional, and response team personnel. To determine the extent to which EPA has
implemented the module nationwide, we reviewed OEM's September 2010
assessment of regional and response team use of the equipment module, and an
OEM PowerPoint presentation provided to us in October 2010.
We reviewed the following documents to understand the requirements for
assessing the EMP equipment module's functionality and cost effectiveness:
11-P-0616
2

-------
•	EPA System Life Cycle Management (SLCM) policy and procedure
documents
•	EPA's Exhibit 300 Guide for Capital Planning and Investment Control
(CPIC) Budget Year 2012
•	Office of Management and Budget (OMB) Circular A-130
•	EPA's CPIC for Management of Information Technology Investments
To compare the cost, efficiency, and effectiveness of the EMP equipment module
to that of the previous tracking system, NEMS, we interviewed personnel in
Regions 2, 4, 5, and 6; ERTs in New Jersey and Las Vegas; the Radiological
Emergency Response Team in Las Vegas; and the National Decontamination
Team (NDT). Regions 4, 5, and 6 had recent major responses to nationally
significant incidents in April and July 2010 for which we could evaluate the EMP
equipment module. Region 2 had no equipment tracking software system prior to
EMP and therefore served as a pure baseline region. We also reviewed the NEMS
Systems Management Plan, the EMP Alternatives Analysis, and Exhibit 300:
Capital Asset Plan and Business Case Summary for the EMP (part of CPIC).
We reviewed fiscal years 2008, 2009, and 2010 Federal Managers Financial
Integrity Act Annual Assurance Letters for OSWER and for the Office of
Environmental Information to determine whether they identified any weaknesses
related to the EMP equipment module. The letters did not identify any such
weaknesses. We reviewed internal controls related to the processes for planning
and implementing information technology and management systems. We also
reviewed controls for measuring, reporting, and monitoring system performance.
Our scope was limited to evaluating EPA activities related to the equipment
module portion of the EMP. We did not evaluate activities related to development
and implementation of the EMP as a whole.
Prior OlG Audits
OIG reports in 2004, 2006, and 2009 cited EPA's lack of a nationwide tracking
system for emergency response equipment:
•	Report No. 2004-P-00011, EPA Needs to Better Manage Counter
Terrorism/Emergency Response Equipment, issued March 29, 2004
•	Report No. 2006-P-00022, EPA Needs to Better Implement Plan for
Protecting Critical Infrastructure and Key Resources Used to Respond to
Terrorist Attacks and Disasters, issued April 26, 2006
•	Report No. 09-P-0087, EPA Plans for Managing Counter
Terrorism/Emergency Response Equipment and Protecting Critical Assets
Not Fully Implemented, issued January 27, 2009
The 2004 report recommended that the Agency establish an aggressive timetable
to (1) determine what emergency response equipment and characteristics
11-P-0616
3

-------
(e.g., location and condition) EPA was to track, and (2) develop and implement a
plan, with points of accountability, for a national tracking system. The Agency's
response to this report set up the initial September 2004 deadline for establishing
a national emergency response equipment tacking system. The 2006 and 2009
OIG reports disclosed that EPA had not implemented a national system for
tracking emergency response equipment and recommended that EPA implement
such a system.
Results of Review
As of October 2010, EPA had spent $2.8 million on the EMP emergency
equipment tracking module, which has not been fully implemented. The system
suffers from operational issues. In our review of allegations in the Hotline
complaint, we found that:
•	EPA does not fully use the EMP equipment tracking module because no
EPA office with overall authority has mandated its use.
•	EPA has made no formal effort to assess functionality and cost
effectiveness due to its decision to perform such an assessment 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.
EPA has guidance and policies that require the Agency to develop and implement
a plan for a national tracking system, and both OMB and EPA require
performance measurement of such systems. However, EPA has not fulfilled these
requirements. EPA has spent $2.8 million as of October 2010 on the EMP
equipment module, and it plans to spend another $5.5 million over the next
15 years on maintenance. In addition, regions and response teams that are also
using the module continue to maintain their own tracking systems, resulting in
wasted resources. Because EPA has not fully implemented the EMP equipment
module and the module is cumbersome and slow, EPA's ability to protect public
health and the environment in the event of a nationally significant incident may be
impaired.
EPA Directives and Policy Require Implementation and Formal
Review of a National Emergency Equipment Tracking System
In implementing computer software systems like EMP, EPA offices must follow
the SLCM policy and procedure. EPA's SLCM policy promotes effective and
efficient solutions for designing and operating information systems. The policy
mandates a series of reviews and approvals, and integration with the Agency's
information technology security, enterprise architecture, and investment
management processes for information technology, while allowing flexibility to
accommodate varying developmental approaches. The SLCM policy states that
11-P-0616
4

-------
advancement from one phase to the next entails an Information Technology
Investment Management Board review. EPA designates these reviews as Agency-
level control gates and management must ensure that they take place. When a
control gate review is required, management should not advance a system without
documented, written approval resulting from that review.
EPA's SLCM procedure mandates the measurement of asset performance and the
alignment of costs to projected resources required within cost-benefit analyses.
EPA's Exhibit 300 Guide for CPIC FY 2012 quotes OMB's Capital Asset Plan
and Business Case Summary Exhibit 300 when it states that agencies should be
measuring the performance of assets against the baseline. EPA's SLCM
procedure states that EPA should conduct a postimplementation review to ensure
that the system functions as planned and to verify that the system cost is within
the estimated amount determined by the cost-benefit analysis.
The SLCM procedure directs EPA personnel to use technical management
practices in the planning, acquisition, operation, maintenance, and termination of
information technology systems. The SLCM procedure outlines various
documents and planning activities that EPA must conduct during different phases
of projects. Two key documents and activities are:
•	The Business Case—The OMB CPIC submission requires that current
business processes be described using activity and data models. Current
costs and performance are also associated with the models. The
submission must also (1) identify and analyze gaps between current and
desired outcomes, and (2) develop and evaluate alternatives for improving
the business based on readily available information.
•	Requirements Subphase—This phase emphasizes determining what
functions must be performed rather than how to perform those functions.
To do this, the project team defines functional and system requirements
that are not easily expressed in data and process models. Functional and
system requirements also include the requirements of the business process,
the user requirements, and operational requirements.
EPA Has Not Performed Formal Functionality and Cost Effectiveness
Assessments of the EMP Equipment Module
While EPA advised in an October 2008 OSWER memorandum that the
equipment module was in production and that the regions and special teams were
required to use the equipment module, it has not formally assessed operational
functionality or cost effectiveness. The Agency has committed to addressing
functionality issues within the EMP equipment module as they arise rather than
assessing usability and benefits against the baseline established to measure
performance of the equipment module. EPA plans to assess usability and benefits
against the baseline only when all regions and response teams are using the EMP
equipment module to track emergency response equipment. Thus, EPA has spent
11-P-0616
5

-------
$2.8 million as of October 2010 on the equipment module without formally
verifying that the system cost is within the estimated amount determined by the
cost-benefit analysis, and without measuring the impact on the success, increased
functionality, and use of the module.
Equipment Module Not Fully Used Because No EPA Office With
Overall Authority Has Mandated Use
Despite an initial deadline of September 2004 for implementing a nationwide
tracking system, some regions and response teams are not using the EMP
equipment module because no EPA office with overall authority has mandated
that offices with an emergency response equipment managing role use it. EPA has
deployed the national system, but the Agency is not fully using the EMP
equipment module nationwide.
In October 2008, the Director of OEM issued a memorandum on the EMP
equipment portal, stating that the equipment module was in production and ready
for use for all EPA equipment warehouses. OEM sent the memorandum to
Regional Removal Managers; the Directors of the Office of Radiation and Indoor
Air and the Office of Superfund Remediation and Technology Innovation; and the
Deputy Director, Office of Criminal Enforcement, Forensics and Training. The
memorandum also stated, "All regions and special teams are required to use the
new system for tracking equipment that is used in support of emergency
response."
According to OEM, as of October 2010, 5 of the 10 regions and 3 of the
4 response teams were not fully using EPA's EMP equipment module to track and
maintain emergency response equipment (table 1). OEM determined whether
regions and response teams were using the equipment module by office
participation in Web conferences and training, calls for support, assistance on
using the system, and special reports requested. OEM considered an office to be
"fully implemented" and using the system if it was using the system to determine
availability of equipment.
11-P-0616
6

-------
Table 1: EMP equipment module implementation status by
region and response team
Region and response team
Implementation status
Region 3
Region 5
Region 6
Region 7
Region 9
ERT Las Vegas
Fully implemented
Region 1
Region 8
Region 10
ERT Kentucky
Radiological ERT Las Vegas
Nearly implemented
Region 2
Region 4
ERT New Jersey
Not implemented
Source: October 2010 OEM PowerPoint presentation.
While OEM has required the use of the EMP equipment module, OEM does not
have the direct authority to require that regions and response teams use the EMP
equipment module. Regions are under the authority of Regional Administrators,
and response teams are under the authority of the Office of Superfund
Remediation and Technology Innovation.
OEM has not elevated the issue of regions and response teams not using the
system. Instead, OEM has delegated the implementation of the equipment module
to its NDT. NDT's role is to:
•	Train the regional warehouse managers
•	Support warehouse managers in fully utilizing the equipment module
•	Assist the warehouse managers in developing equipment-related reports
•	Assist headquarters in developing and prioritizing new features and fixes
for a future version of the equipment module
As a subordinate group to OEM, NDT also cannot require compliance by
the regions and response teams. NDT staff responsible for the
implementation of the equipment module stated that regions and response
teams are resistant to change, and regions and response teams found their
own tracking systems to be more efficient and easier to use.
11-P-0616
7

-------
Regions and response teams had various reasons for not using the EMP
equipment module:
•	They are comfortable working with the warehouse systems they currently
have.
•	The EMP equipment module is not easy to use, and it is slow due to
additional required fields that users must complete.
•	The EMP equipment module is missing functions, such as the capability to
load large amounts of data simultaneously.
The EMP Equipment Module Is Cumbersome and Slow Compared
With NEMS
EMP equipment module user feedback casts doubt on it being the most efficient
and effective emergency equipment tracking alternative. The EMP equipment
module replaced the interim system, NEMS, because OEM determined that the
Agency needed a more robust national equipment management system based out
of headquarters. However, NEMS met the emergency equipment tracking needs
of the regions according to the New Jersey ERT and Regions 4 and 6.
NEMS provided a national view of equipment, including identification, location,
and availability. NEMS collected data from regional and response team systems
to display each region's individual categorization of equipment and equipment
location. EPA did not intend for NEMS to replace local systems. EPA designed
the EMP equipment module to collect data from user input or local systems to
track equipment and compile additional information such as cost and schedule of
equipment purchases and maintenance actions.
Some regional and response team personnel have deemed the EMP equipment
module to be "cumbersome" and slow because of the number of extra fields that
users are required to fill out to support the module's increased functionality.
Regional and response team personnel stated that some EMP equipment module
functionality is beyond what a national tracking system needs, and that the
functionality is not an improvement on previous regional warehouse management
systems. The number of extra fields that users are required to fill out to support
the module's increased functionality adversely affects the EMP equipment
module's efficiency. Specific comments include the following:
•	Region 4 staff stated that they do not use the EMP equipment module
because it is very slow. They tested the system by checking out (assigning
equipment to a first responder in the system) a piece of equipment both in
the EMP equipment module and in their regional system. To check out the
same piece of equipment, the EMP equipment module took 48 minutes,
and Region 4's system took 11 minutes.
•	Region 4 staff also stated that they need basic equipment tracking
information, which is the location and the availability of equipment on a
11-P-0616
8

-------
nationwide basis, but nationally they do not need to know information on
other regions' maintenance of equipment and information on parts and
supplies. This information is not important in an emergency.
•	Region 5 staff stated that the EMP required that they enter more data into
the system (into the fields), so it takes more time and effort to complete
functions (e.g., entering costs).
•	Region 6 staff said that the EMP equipment module was more
cumbersome than the region's previous system. Using the EMP required
20-30 percent more effort (due to the extensive number of fields in EMP
that must be filled out), but had mostly the same functionality as the
region's Response Manager System. OEM created the check-in/check-out
part of the module with many extraneous features and steps.
•	NDT staff provided us with information compiled by Region 7. Region 7
performed a comparison of the EMP equipment module to its own system
and determined that it took 5 minutes and 9 seconds to perform multiple
tasks including: check back in, inventory event, and in-house repair tasks
in its own system, compared to 16 minutes and 2 seconds in the EMP
equipment module.
•	In a New Jersey ERT contractor comparison of speed in getting equipment
through the EMP equipment module versus the legacy system, the total
check-out and check-in time with the legacy system was 13 minutes,
compared to 54 minutes with the EMP equipment module.
•	ERT-Las Vegas staff stated that if they used the EMP, they would
duplicate some of their efforts. For example, their maintenance records are
already located in their own maintenance log books.
Conclusion
EPA has implemented neither the EMP equipment module nor NEMS as EPA's
national equipment tracking system. The development costs of the EMP
equipment module were significantly higher than the costs of NEMS. The cost of
developing the EMP equipment module accounted for $2.2 million of the
$2.8 million spent on the module through October 2010. Estimated development
costs for NEMS were $300,000. Therefore, EPA has spent millions of dollars on a
system that the regions and response teams are not fully using as intended, and
plans to spend $5.5 million more on maintenance over the next 15 years.
11-P-0616
9

-------
Recommendations
We recommend that the Assistant Administrator for Solid Waste and Emergency
Response:
1.	Ensure that only data essential to tracking emergency response equipment
are required in the EPA national emergency response tracking system.
2.	Determine whether the EMP equipment module is the most cost-efficient
and functional national equipment tracking alternative.
We recommend that the EPA Deputy Administrator:
3.	Mandate that regions and response teams employ the national tracking
system EPA decides to use for emergency response equipment.
Agency Comments and OIG Evaluation
EPA concurred with the findings and recommendations. Originally, the first
recommendation directed that only data essential to tracking emergency
equipment be included in the EPA national emergency response tracking system.
In its response, EPA explained that the equipment module is already only tracking
essential equipment, but went on to say that the equipment module contained data
elements beyond the essential needs to help regions and special teams manage
their equipment. The OIG agreed to change the first recommendation from
ensuring only essential tracking emergency response equipment data be
"included" in the system to ensuring that only essential tracking emergency
response equipment data are "required" in the system, and the Agency concurred
with the revised recommendation. OSWER stated that the users need more
training to better familiarize them with the system. OEM plans to send a memo in
September 2011 promoting all available training opportunities. While training
may assist users of the equipment module in understanding data applications
beyond their essential needs, it does not meet the intent of the recommendation to
require only essential equipment tracking data. To be responsive to this revised
recommendation, OSWER must assure that the system requires the data to track
equipment for emergency response and does not require data for other purposes,
such as equipment management. OSWER's 90-day response should provide a
completion plan and date for complying with the first recommendation. OSWER
is also planning to optimize the data entry screens to improve the responsiveness
of the equipment module and to allow users to enter essential tracking data
quickly and efficiently. However, OSWER did not provide a completion date for
optimizing the data entry screens and should include one in its 90-day response to
the final report.
The Agency agreed with recommendation 2 and stated that it would hire an
outside contractor to conduct an alternative analysis and determine the most
efficient and effective national emergency response equipment tracking
11-P-0616
10

-------
alternative by spring 2012. We agree with this corrective action plan for
recommendation 2.
The Agency agreed with recommendation 3 and stated that it would prepare a
memo for the Deputy Administrator's signature by fall 2011 requiring the regions
and special teams to use the equipment module. The Deputy Administrator needs
to establish plans, with dates, for when the Agency will send an updated memo
following the alternative analysis scheduled for 2012, to be completed in response
to recommendation 2.
We agree with the Agency corrective action plan for recommendation 2 and
request that additional information on action plans and completion dates for
recommendations 1 and 3 be added to its corrective action plans when responding
to the final report. The Agency's full response is in appendix A.
11-P-0616
11

-------
Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Page
Rec. No. No.
Subject
Status1
Action Official
Planned
Completion
Date
1	10	Ensure that only data essential to tracking
emergency response equipment are required
in the EPA national emergency response
tracking system.
2	10	Determine whether the EMP equipment
module is the most cost-efficient and
functional national equipment tracking
alternative.
3	10	Mandate that regions and response teams
employ the national tracking system EPA
decides to use for emergency response
equipment.
Deputy Administrator
Claimed
Amount
Ag reed-To
Amount
Assistant Administrator for
Solid Waste and Emergency
Response
0 Assistant Administrator for 06/20/12
Solid Waste and Emergency
Response
12/22/11
1 0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is unresolved with resolution efforts in progress
11-P-0616
12

-------
Appendix A
EPA Response to Draft Report

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
July 27, 20 ll
MEMORANDUM
SUBJECT: Comments on Draft Report: EPA Has Not Fully implemented a National
Emergency Response Equipment Tracking System. Project No. OA-FY10-0210
Thank you for the opportunity to review and comment on the Draft OIG Evaluation Report
"EPA Has Not Fully Implemented a National Emergency Response Equipment Tracking
System" Project No. OA-FY10-0210. We have completed our review of the report and proposed
recommendations. We have outlined in the attachment our response to the recommendations and
our proposed actions going forward.
We agree that the Emergency Management Portal (EMP) - Equipment Module ("Equipment
Module") has not been fully implemented. However, regions are making continual progress
toward using the Equipment Module as their day-to-day operational database. Furthermore, as
discussed in the attachment, we have several initiatives underway to ensure the success of the
Equipment Module.
Our comments on the draft OIG report are attached. Please contact Johnsie Webster at 202-566-
1912 if you have further questions or concerns.
FROM: Mathy Stanislaus, Assistant Administrator /Signed/
Office of Solid Waste and Emergency Response
THRU: Bob Perciasepe
Deputy Administrator
TO:
Melissa M. Heist
Assistant Inspector General for Audit
Attachment
11-P-0616
13

-------
ATTACHMENT
Response to OIG Recommendations
• Ensure that only essential "equipment tracking data" needs are included in the
EPA national emergency response equipment tracking system.
Response & Actions:
The Equipment Module is already designed to track equipment using only "essential
tracking data." To track equipment checked out for field use, the module requires six
pieces of "essential tracking data": unique barcode number, response site name, name of
the EPA responsible party, name of the person that actually picked up the equipment
from the warehouse (which may be the same as the EPA responsible party), the check-out
date, and the check-out type (field use, maintenance, demonstration/training). If a
warehouse enters this information, its equipment can be adequately located per the
purpose of the Equipment Module.
Additional information (maintenance, parts & supplies, etc.) can be entered and managed
within the Equipment Module. This information can provide data on the condition and
operability of the equipment, which is important information during a response. In
addition, the Equipment Module allows the warehouse to track all equipment-related
information in one application, rather than managing tracking data in one application and
maintenance data in another, or entering some of the same data in two applications.
In response to the comment that there are too many required fields and the database is too
cumbersome, our National Decontamination Team (NDT) provides ongoing support and
educational opportunities to the users of the Equipment Module through various means.
Contractor support is available on a daily basis via email, a toll free help line and via
direct cell phone line. User support requests are typically handled immediately over the
phone or by conducting an impromptu web conference if a more extensive response is
needed. In addition to the help desk requests, routine webinars are scheduled to introduce
and review some the newer functions (e.g. bulk data uploads) that continue to be added to
the system. A regularly scheduled quarterly Equipment Module User's Group web
conference has also been held for the past few quarters. These web conferences are used
to inform the users of upcoming changes and to gather their input on areas for possible
improvements to the system. Several refresher training courses have been conducted at
the request of the Regions. These courses provide a means to train new staff and review
existing and new functions for all the staff. However, in order to better inform our users,
OEM will send a memo promoting all training opportunities to the Regions and Special
Teams by September 2011.
In response to earlier concerns that the Equipment Module is cumbersome and slow, we
have completed a pilot study on the use of bar code scanners. The results of this study
showed that by using barcode scanners, the warehouse managers will be able to easily
record the barcode numbers of equipment scheduled for check out or transfer to another
warehouse and then have that information transferred to the Equipment Module, using
either a direct interface, or by using a batch process with a spreadsheet or text file
11-P-0616
14

-------
containing the data. The scanners can be used for recording maintenance activities,
annual warehouse inventories and other routine equipment inventory reports, although
this use is not required. Most importantly during a large scale response when various
equipment is borrowed or rented, the barcode scanners can be utilized as a standalone
unit, with the Equipment Module updated on a periodic basis.
We are currently working on improving the responsiveness by optimizing the data entry
screens so that users can enter the essential tracking data quickly and efficiently.
We believe the steps we are taking to improve the application will alleviate the problems
we have had in the past and allow all of the warehouses to use the application more
efficiently and therefore no corrective action date is needed.
• Determine whether the EMP equipment module is the most cost-efficient and
functional national emergency response equipment tracking alternative.
Response and Actions:
We plan to conduct a thorough alternatives analysis by Spring 2012, utilizing an outside
firm that specializes in this analysis. This analysis will consider several products,
including commercial and government off-the-shelf software. Once complete, we will
share the results with the OIG for review. While we are conducting this analysis, we will
still move forward with the bar code scanning functionality. If the alternatives analysis
shows that we should move to another solution, the bar code scanners can be integrated
into that tool.
In response to the comment "The EMP Equipment Module is Cumbersome and Slow
Compared to NEMS," the EMP Equipment application cannot be easily compared with
the NEMS system. The Equipment Module is a web-based application that was
developed to ensure nationally consistent terminology and tracking. The NEMS system
was an interim solution that connected to regional databases through web services. The
NEMS system did not promote nationally consistent equipment terminology and was not
meant to be an operational, day-to-day equipment management system. If the NEMS
system were implemented as a national tool, each region would need to maintain its own
database and ensure that it could successfully share data with NEMS utilizing the correct,
consistent terminology.
Recently the National Decontamination Team (NDT) conducted a review of internet
speeds at each of the EPA warehouses. Many of the issues that the regions have
experienced with the EMP Equipment application is due to slow internet speeds. We are
developing a minimum internet speed standard. Once the warehouses have bar code
scanners and acceptable internet capability, usability should improve.
In addition, the Equipment Module already includes a local version that can be installed
on the warehouse local machines and that does not require constant access to the internet.
The data within the local version can then be uploaded to the central system on a regular
basis, usually during downtime of the warehouse. This mitigates problems with
11-P-0616
15

-------
suboptimal warehouse internet connections. We recommend this solution to until the bar
code scanners and improved internet capabilities can be implemented fully.
For the past two years NDT has been gathering input from the regions on improvements
to the Equipment Module and to date, over 100 improvements have been implemented,
which have greatly improved usability.
• Mandate that regions and response teams employ the national tracking system
EPA decides to use for emergency response equipment.
Response and Actions:
We agree with this recommendation and OEM will prepare a memo for the Deputy
Administrator's signature by Fall 2011 requiring the Regions and Special Teams to use
the Equipment Module.
For the purpose of background, the majority of regions and special teams use the EMP
Equipment application, many regions have existing contracts in place that do not require
the use of the EMP Equipment application. As these contracts turnover, more warehouses
will be required to use the application as part of their contract renewals or contract
competitions. Additionally, OEM conducts annual evaluations with each region called
Core National Approach to Response (Core NAR). Core NAR sets standards to ensure
that each region works toward improving and maintaining an excellent response program.
For the past two years, the Core NAR evaluation has included a criterion which we use to
determine whether or not the regions and special teams are complying with the 2008
memo and using the Equipment Module. OEM will continue to include this criterion in
the Core NAR to further evaluate the increased usage of the Equipment Module by EPA
regions and special teams.
11-P-0616
16

-------
Distribution
Office of the Administrator
Deputy Administrator
Assistant Administrator for Solid Waste and Emergency Response
Agency Followup Official (the CFO)
Agency Followup Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Audit Followup Coordinator, Office of Solid Waste and Emergency Response
11-P-0616

-------