OFFICE OF
INSPECTOR GENERAL
Semiannual
Report to Congress
October 1, 2017-March 31, 2018
EPA-350-R-18-001
May 2018

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Index of Reporting Requirements
Inspector General Act of 1978, as amended
Section 4(a
Review of legislation and regulations
29
Section 5(a
Significant recommendations for corrective action
14-20, 24-25
Section 5(a
Matters referred to prosecutive authorities
11-13, 21-22, 24-25
36-37, 59-64
Section 5(a
List of reports issued
Section 5(a
Audit, inspection and evaluation reports—questioned costs
2, 34-35, 38
Section 5(a
Prior audit, inspection and evaluation reports unresolved
35, 39-41
Section 5(a
Significant management decisions with which OIG disagreed
None
Section 5(a
17-18)
Statistics on investigative reports, referrals, prosecutions, indictments
22, 34, 36-37
Section 5(a
20)
Description of whistleblower retaliation
Section 5(a
22)
Closed audits, evaluations and investigations not disclosed to public
59-64
Section 5(a
Information or assistance refused
9-10
Section 5(a
Reports with corrective action not completed
3-7, 42-58
Section 5(a
Any establishment attempts to interfere with independence
9-10
Section 5(a
Substantiated Investigations involving senior government employees
12-13, 59-60
Section 5(a
14-16)
Peer reviews conducted
65
Section 5(a
Audit, inspection and evaluation reports—funds to be put to better use 2, 34-35, 38
Section 5(a
Significant revised management decisions
None
Section 5(a
Significant problems, abuses and deficiencies
11-26
Section 5(a
Summaries of significant reports
14-20, 24-25, 30
Requirement
Subject
Pages
Abbreviations
CFR	Code of Federal Regulations
CSB	U.S. Chemical Safety and Hazard Investigation Board
EPA	U.S. Environmental Protection Agency
FY	Fiscal Year
OIG	Office of Inspector General
U.S.C.	United States Code
SES	Senior Executive Service
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Message to Congress
For the semiannual reporting period ending March 31, 2018, the Office of
Inspector General (OIG) for the U.S. Environmental Protection Agency (EPA)
saw a significant increase in congressional requests for audits and investigations.
As we navigate the allocation of OIG resources needed to address numerous
inquiries and strive to help the agency meet its mission to protect human health
and the environment, the OIG remains committed to detecting and preventing
fraud, waste and abuse.
Resource allocation is also a factor in the work that we do as the OIG for the U.S.
Chemical Safety and Hazard Investigation Board (CSB). Helping the CSB fulfill
its mission to investigate and report on accidental chemical releases is yet another
way the OIG allocates its resources to assist with protecting people and the environment.
Challenging Budget Environment
Since fiscal year (FY) 2014, the budget for the OIG has remained relatively flat. Despite an increase
in congressional requests and high-profile audits and investigations, our budget decreased from
$51.7 million in FY 2014 to $50.3 million in FY 2018. Further, our number one resource—appropriated
full-time equivalent staff—has declined from 331 in FY 2014 to 270 in FY 2018. All of these constraints
are occurring during a time of budget unpredictability and rising demands, which hampers our ability to
perform our work at past levels.
Impact of Our Work
Even with these constraints, we continue to move forward and post
accomplishments. One of our audit reports this period was on self-insurance
for companies with multiple cleanup liabilities. We found that the EPA does
not sufficiently verify all self-insurance and that companies are not required
to disclose all environmental liabilities. If a company's self-insurance is not
valid, the company can default on cleanup operations and saddle the EPA
and the American taxpayers with billions of dollars in cleanup costs.
In another audit report, we noted that during a 3-year period the EPA
awarded over $4 billion dollars in performance-based contracts. These
contracts attempt to achieve better value and enhanced performance, and
focus on the results to be achieved instead of how the work is to be performed. However, we found that
over $290 million awarded in performance-based contracts could have been put to better use if the EPA
had not granted award terms for less-than-superior service.
We also audited the EPA's use of high-risk contracts and found that the agency could reduce the
frequency of use of these contracts. Low-risk, firm-fixed-price contracts represented only 9 percent of the
EPA's contract obligations as of the second quarter of FY 2017. Without improving its acquisition
Arthur A. Elkins Jr.
OIG Accomplishments
During Reporting Period
•	More than $374.74 million in
potential monetary benefits.
•	More than $0,499 million in total
fines and recoveries (including
EPA only and joint investigations).
•	18 reports issued by EPA OIG.
•	54 investigative cases closed.
•	43 administrative actions
resulting from investigative cases.
•	123 hotline inquiries closed.
•	197 hotline inquiries referred for
action.

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
planning process, the EPA may continue to spend hundreds of millions of dollars on high-risk contracts
that waste taxpayer dollars.
As the summer season approaches, another one of our audits found that the EPA has not reported to
Congress on the Beaches Environmental Assessment and Coastal Health Act of 2000 (known as the
BEACH Act), which provides states, territories and tribes with funds to operate beach monitoring and
public notification programs. In FY 2013, the EPA stopped requesting funding for the program based, in
part, on its view that the program is "mature." Although the EPA no longer requests funds, Congress has
continued to fund the program. We found that the agency's failure to submit required reports and keep
required records limits congressional, public and EPA knowledge about the impact of the program and
decisions regarding the use of taxpayer dollars.
Highlights from our investigative work include the completion of our investigation into the August 2015
release of over 3 million gallons of contaminated mine water from the Gold King Mine. Rivers and
streams in four western states were affected by the release. The U.S. Attorney's Office declined
prosecution under any criminal offenses, and the EPA did not take administrative action against any
employees. Another important investigation involved a former Tribal Administrator receiving an
18-month prison sentence and a restitution fine of $297,731 for embezzling funds. We also investigated a
company president who was later ordered to serve a 12-month prison sentence, faces deportation, and has
to repay $180,392 for his role in deceiving U.S. municipalities into spending federal stimulus money on
his company's foreign-made products.
EPA Successes and Upcoming Projects
Two of our reports this period highlight the EPA implementing our recommendations and taking
appropriate corrective actions to improve human health and the environment. In our follow-up review of
recommendations made in our 2006 report on the Libby, Montana, Superfund site, we found that the EPA
completed all outstanding recommendations. The agency's corrective actions enabled the Libby toxicity
assessment to be completed with transparency, and stakeholders received important human exposure
information. The agency also took corrective actions following our audit of the EPA paying $840,000
for subsidized parking and $690,000 for unoccupied parking spaces over a 2-year period. The agency
accepted our recommendations and chose no longer to offer reduced-rate or free parking.
The audit reports and investigations during this semiannual reporting period demonstrate the OIG's
capacity to produce quality work as we adapt to budget uncertainty, constrained resources and increased
demands. Looking forward, we anticipate completing important projects involving the Flint (Michigan)
water crisis, the EPA Administrator's travels and protective service detail, asbestos in schools, and
asbestos demolition at the Old Davis Hospital in Statesville, North Carolina. We hope to cover these
projects in our semiannual reporting period that ends September 30, 2018.
Arthur A. Elkins Jr.
Inspector General

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Table of Contents
About EPA and Its Office of Inspector General	 1
Scoreboard of Results	 2
Status of OIG Unimplemented Recommendations	 3
Furthering EPA Efforts	 8
Status of Whistleblower Retaliation and Interference With Independence	 9
Significant OIG Activity	 V\
Congressional Activities	 11
Human Health and Environmental Issues	 14
Agency Business Practices and Accountability	 17
Investigations	 21
Hotline Activities	 24
Other Activities	 29
U.S. Chemical Safety and Hazard Investigation Board	 30
Other Results of OIG Work	 31
Follow-Up Is Important Aspect of OIG Efforts	 31
Single Audit Reporting Efforts Make Impact	 32
Agency Best Practices	 33
Statistical Data	 34
Profile of Activities and Results	 34
Audit Report Resolution	 35
Summary of Investigative Results	 36
Appendices	 38
Appendix 1—Reports Issued		38
Appendix 2—Reports Issued Without Management Decisions		39
Appendix 3—Reports With Corrective Action Not Completed		42
Appendix 4—Closed Investigations Not Publicly Disclosed		59
Appendix 5—Peer Reviews Conducted		65
Appendix 6—OIG Mailing Addresses and Telephone Numbers		66

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
About EPA and Its
Office of Inspector General
U.S. Environmental Protection Agency
The mission of the U.S. Environmental Protection Agency (EPA) is to protect
human health and the environment. As America's steward for the environment since
1970, the EPA has endeavored to ensure that the public has air that is safe to breathe,
water that is clean and safe to drink, food that is free from dangerous pesticide residues,
and communities that are protected from toxic chemicals.
EPA Office of Inspector General
The Office of Inspector General (OIG), established by
the Inspector General Act of 1978, as amended, 5 U.S.C
App. 3, is an independent office of the EPA that detects
and prevents fraud, waste and abuse to help the agency
protect human health and the environment more
efficiently and cost effectively. OIG staff are located at
EPA headquarters in Washington, D.C.; the EPA's 10
regional offices; and at Research Triangle Park, North
Carolina, and Cincinnati, Ohio. The EPA Inspector
General also serves as the Inspector General for the
U.S. Chemical Safety and Hazard Investigation Board
(CSB). Our vision, mission and goals are as follows:
Vision
Be the best in public service and oversight for a better environment tomorrow.
Promote economy, efficiency, effectiveness, and prevent and detect fraud, waste, and
abuse through independent oversight of the programs and operations of the EPA and
CSB.
Goals
1.	Contribute to improved human health, safety and environment.
2.	Contribute to improved EPA and CSB business practices and accountability.
3.	Be responsible stewards of taxpayer dollars.
4.	Be the best in government service.
EPA OIG Peer Reviewed
The systems of quality control for the EPA OIG
are peer reviewed by another OIG on a regular
basis to ensure that the EPA OIG satisfies
professional standards. The last external peer
review of the EPA OIG's audit and evaluation
offices was completed in June 2015 and the
last external peer review of the EPA OIG's
investigations office was completed in
December 2014. Both reviews gave the EPA
OIG the highest rating possible— pass. Further
details are in Appendix 5. New peer reviews
are currently underway.
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Scoreboard of Results
The information below shows taxpayer return on investment for work performed by the EPA OIG during the
first half of fiscal year 2018 compared to FY 2018 annual performance goal targets. All results reported are
based on goals and plans established under the Government Performance and Results Act.
Annual Performance Goal 1:
Environmental and business outcome actions taken; changes, corrections or improvements made;
risks reduced, eliminated or influenced by OIG work
Target: 196
Reported: 18
(9% of goal)
Supporting measures
3 Environmental/health improvements realized or influenced by OIG work
15 Environmental, chemical safety or business policy, practice or process change made or decisions
implemented
0 Legislative or regulatory changes
Annual Performance Goal 2:
Recommendations, challenges, best practices or risks identified for action
Target: 460
Reported: 352
(77% of goal)
Supporting measures
12	Certifications, verifications, validations
91 Recommendations for improvement (including risk identified)
13	Referrals for agency action
7 Unimplemented recommendations identified in issued reports
228 OIG-identified findings in external reports impacting EPA
1 Beneficial practices identified for potential transfer
Annual Performance Goal 3:
Return on investment: potential dollar return as percentage of OIG budget
Target: 160% of budget
Reported: 580% of target
Supporting measures fin millions)
OIG budget: $50.3
Potential return: $466.7
$0,074 Questioned costs
$374,664 Potential monetary benefits identified in report—excluding questioned costs
$90,952 Monetary actions taken or resolved prior to report issuance
$0 Fines, penalties, settlements and restitutions resulting from EPA OIG investigations
$0,013 Actual cost saved identified after report issuance
$0,539 Cost avoidance savings/cost savings identified after report issuance or based on
investigative results
$0,499 Fines, penalties, settlements and restitutions resulting from joint investigations between
EPA OIG and other entities
Annual Performance Goal 4:
Criminal, civil and administrative actions reducing risk, and loss of resources
and operational integrity taken or influenced by OIG work
Target: 87
Reported: 151
(174% of goal)
Supporting measures
39	Allegations disproved
3 Indictments
1 Convictions
0 Civil actions
40	Administrative actions taken (other than debarments or suspensions)
3 Suspension or debarment actions
65 Fraud briefings conducted
Other (no targets established)
Savings and recommendations sustained:
•	98 sustained environmental or business recommendations (resolved or agreed-to) for action
•	$9.03 million in sustained questioned costs
•	$374.66 million in sustained potential monetary benefits
Reports Issued: 18
Sources: The OIG Performance Measurement Results System and the Inspector General Enterprise Management System.
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Status of OIG Unimplemented
Recommendations
OIG audits provide recommendations to help improve EPA program offices and regions.
Benefits for the agency and the public are realized through the implementation of these
recommendations. To encourage continued progress on completing management action, we
analyzed the list of unimplemented recommendations in Appendix 3 and provide the results
of that analysis below. Unimplemented recommendations include those for which
implementation is past due as well as those that are due in the future.
Unimplemented Recommendations
90 	
an 	
70
60
50
40
30
20
10 	














n	-	-	— — ¦	


FTO8-11 FY12 FY13 FY14 FY15 FY16 FY17
Forthe semiannual reporting period ending March 31, 2018, the EPA had 114
unimplemented recommendations with potential monetary benefits totaling $860 million.
The table below shows the status of the recommendations, which fall into six categories.
Category
Total

#
$M
1. Management and Operations
48
$24.5
2. Water Issues
17
$791.8
3. Environmental Contamination and Cleanup
14
$27.8
4. Toxics, Chemical Safety and Pesticides
16
$0.0
5. Air Quality
9
$15.9
6. Research and Laboratories
10
$0.0
Total
114
$860.0
For each category, we include the benefit(s) of implementing each recommendation as one
or more of the following: (1) improved human health and the environment, (2) more
effective and efficient operations and (3) potential monetary benefits.
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Category 1—Management and Operations
The 48 unimplemented recommendations in this category offer potential for more
effective and efficient operations, and potential monetary benefits of $24.5 million.
•	Improved oversight of:
o	Audio conferencing services (Report No. 17-P-0408).
o	Puerto Rico's assistance agreements (Report No. 17-P-0402).
o	Leave bank program (Report No. 17-P-0374).
o	Management of the Brownfields Revolving Loan Fund Program to maximize
cleanups (Report No. 17-P-0368).
o	Text messaging (Report No. 17-P-0062).
o	Recording and management of funds receivable from other agencies
(Report No. 17-F-0046).
o	Use of religious compensatory time (Report No. 16-P-0333).
o	Travel cards (Report No. 16-P-0282).
o	Transit subsidy benefits program (Report No. 16-P-0268).
o	Hawaii water quality grants (Report No. 16-P-0218).
o	Cooperative agreements for Guam (Report No. 16-P-0166).
o	Employees on extended absences (Report No. 15-P-0167).
o	Grants execution in the U.S. Virgin Islands (Report No. 15-P-0137).
o	Software costs (Report No. 15-1-0021).
o	Emergency and Rapid Response Contracts (14-P-0109).
•	Institutionalized the Lean program to reap cost and time benefits
(Report No. 17-P-0346).
•	Better processes for information technology:
o	Internal controls for access management (Report No. 17-F-0046).
o	Integration and use of cloud services (Report No. 15-P-0295).
o	Information security vulnerability program (Report No. 15-P-0290).
o	Internal controls for applications management (Report No. 10-1-0029).
Category 2—Water Issues
The 17 unimplemented recommendations in this category offer the potential for
improved human health and the environment, more effective and efficient
operations, and potential monetary benefits of $791.8 million.
•	EPA's voluntary WaterSense program demonstrated success (Report No. 17-P-0352).
•	Evaluate options to restore the viability of Puerto Rico's Clean Water and
Drinking Water State Revolving Funds (Report No. 17-P-0186).
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
•	Provide leadership and better guidance to improve fish advisory risk
communications (Report No. 17-P-0174).
•	Drinking water contamination in Flint, Michigan, clarified EPA authority to
issue emergency orders to protect the public (Report No. 17-P-0004).
•	More consistent annual reviews of Clean Water State Revolving Funds
(Report No. 16-P-0222).
•	Assess environmental and economic benefits of completed Clean Water State
Revolving Fund green projects (Report No. 16-P-0162).
•	Develop strategies for monitoring the impact of state activities on the Gulf of
Mexico hypoxic zone (Report No. 14-P-0348).
•	Apply federal user fee policy in determining whether to charge fees for issuing
National Pollutant Discharge Elimination System permits (Report No. 14-P-0129).
•	Revise outdated or inconsistent EPA/state clean water memorandums of
agreement (Report No. 10-P-0224).
Category 3—Environmental Contamination and Cleanup
The 14 unimplemented recommendations in this category offer the potential for
improved human health and the environment, more effective and efficient
operations, and potential monetary benefits of $27.8 million.
•	Assure distribution of Superfund human resources supports current regional
workload (Report No. 17-P-0397).
•	Continue to reduce backlog of leaking underground storage tank cleanups in
Indian Country and demonstrate compliance with requirements
(Report No. 17-P-0118).
•	Reconcile Superfund special accounts balances to the special accounts database
detail (Report No. 17-F-0046).
•	Implement management controls to complete the required Treatment, Storage
and Disposal Facility inspections (Report No. 16-P-0104).
•	Improve oversight of the Underground Storage Tank/Leaking Underground
Storage Tank program for the U.S. Virgin Islands (Report No. 15-P-0137).
•	Revise risk management inspection guidance to recommend minimum
inspection scope and provide detailed examples of minimum reporting (Report
No. 13-P-0178).
•	Enter into memorandums of agreement that address oversight of municipalities
conducting inspections of underground storage tanks (Report No. 12-P-0289).
•	Improve oversight of facilities regulated by the EPA's oil pollution prevention
program (Report No. 12-P-0253).
•	Make better use of Stringfellow Superfund Special Accounts
(Report No. 08-P-0196).
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Category 4—Toxics, Chemical Safety and Pesticides
The 16 unimplemented recommendations in this category have the potential for
improved human health and the environment.
•	Reduce risks from illegal pesticides by effectively identifying imports for
inspection and sampling (Report No. 17-P-0412).
•	Assess needs and implement management controls to ensure effective
incorporation of chemical safety research products (Report No. 17-P-0294).
•	Strengthen oversight of herbicide resistance with better management controls
(Report No. 17-P-0278).
•	Take additional measures to prevent deaths and serious injuries from
residential fumigation (Report No. 17-P-0053).
•	Assure continued effectiveness of hospital-level disinfectants (Report No. 16-P-0316).
•	Improve oversight of state pesticide inspections to better ensure enforcement of
safeguards for workers, the public and the environment (Report No. 15-P-0156).
•	Re-examine the estimated costs and benefits of the lead rule to determine
whether the rule should be modified, streamlined, expanded or repealed
(Report No. 12-P-0600).
•	Establish criteria and procedures outlining what chemical or classes of
chemicals will undergo risk assessments and update/revise risk assessment
tools and models (Report No. 10-P-0066).
Category 5—Air Quality
The nine unimplemented recommendations in this category have the potential for
improved human health and the environment, and potential monetary benefits of
$15.9 million.
•	Improve data and oversight to assure compliance with the standards for benzene
content in gasoline (Report No. 17-P-0249).
•	Strengthen reviews of small particle monitoring in Region 6 (Report No. 16-P-0079).
•	Provide a verifiable and enforceable remedy to reduce diesel emissions in the
Baton Rouge ozone nonattainment area (Report No. 13-R-0297).
•	Prioritize and update existing oil and gas production emission factors and
develop new factors for processes that do not currently have emission factors
(Report No. 13-P-0161).
•	Update the fees rule to recover more motor vehicle and engine compliance
program costs (Report No. ll-P-0701).
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Category 6—Research and Laboratories
The 10 unimplemented recommendations in this category have the potential for
improved human health and the environment, and more effective and efficient
operations.
•	Review the Community-Focused Exposure and Risk Screening Tool and
develop an action plan with timeframes to address issues identified, including
considerations on whether to retain the tool (Report No. 17-P-0378).
•	Strengthen fraud controls for the EPA's contract laboratory program through risk
assessment and sharing investigative information (Report No. 17-P-01 19).
•	Account for current and future lab renovations (Report No. 15-1-0021).
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Furthering EPA's Efforts
Our audit work during this reporting period addressed what we determined to be key areas of effort for
the EPA. The table below shows how our reports on the EPA aligned with these areas.
OIG-lssued Reports — Linkage to Key EPA Areas of Effort
OIG Report
Report
No.
Improving
air quality
Ensuring
clean/safe
water
Cleaning up/
revitalizing
land
Ensuring
safety of
chemicals
Improving
EPA research
programs
Compliance
with the law
Partnering
with states/
others
Operating
efficiently/
effectively
Analysis of Toxics Release Inventory
Data Identifies Few Noncompliant
Facilities
18-P-0001

X



X


EPA Telework Program Is Consistent
With U.S. Office of Personnel
Management Guidance
18-P-0024







X
EPA's Information Security Program Is
Established, but Improvements Are
Needed to Strengthen Its Processes
18-P-0031





X

X
EPA Paid $1.5 Million for Subsidized and
Unoccupied Parking Spaces Over a
2-Year Period
18-P-0036







X
EPA Reported Its Fiscal Year 2017
Second Quarter Financial and Award
Data in Accordance With the DATA Act
18-P-0037







X
Improved Acquisition Planning Will Help
EPA Reduce Hundreds of Millions of
Dollars in High-Risk Contracts
18-P-0038







X
EPA's Fiscal Years 2017 and 2016
Consolidated Financial Statements
18-F-0039







X
Self-Insurance for Companies With
Multiple Cleanup Liabilities Presents
Financial and Environmental Risks for
EPA and the Public
18-P-0059


X




X
Inconsistencies With EPA Policy
Identified in Region 10's Biweekly Pay
Cap Waiver Process
18-P-0068





X

X
EPA Has Not Reported to Congress on
BEACH Act Progress as Statutorily
Required or Fully Documented Budget
Decisions
18-P-0071

X



X


Follow-Up Review - EPA Completed OIG
Recommendations for Superfund Site in
Libby, Montana
18-P-0074


X





EPA Can Better Manage State Pesticide
Cooperative Agreements to More
Effectively Use Funds and Reduce Risk
of Pesticide Misuse
18-P-0079



X




EPA Needs to Evaluate the Impact of the
Revised Agricultural Worker Protection
Standard on Pesticide Exposure
Incidents
18-P-0080

X



X


EPA Can Achieve Better Value by
Complying With Performance-Based
Contract Requirements
18-P-0089







X
Differences in Processing Practices
Could Decrease the Reliability of Ozone
Data Used for Assessing Air Quality to
Protect Public Health
18-P-0105
X







EPA Did Not Use Allegedly Flawed
Studies to Estimate Methane Emissions
or Set New Source Performance
Standards for Oil and Natural Gas
Production
18-P-0129
X







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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Status of Whistleblower Retaliation and
Interference With Independence
Whistleblower Retaliation
Section 5(a)(20) of the Inspector General Act of 1978, as amended, requires a detailed
description of any instances of whistleblower retaliation noted by the EPA OIG.
This requirement includes information about an official found to have engaged in
retaliation, and the consequences the agency imposed to hold that official accountable.
There were no whistleblower retaliation cases closed within the semiannual period
ending March 31, 2018.
Interference With Independence
The OIG's ability to conduct an employee misconduct investigation was impeded by a
union representative who erroneously demanded that the OIG comply with numerous
provisions in the union's collective bargaining agreement with the agency. This demand
was contrary to established case law holding that Inspector General investigative
procedures are determined exclusively by the Inspector General and are not subject to
modification from a collective bargaining agreement. Such bargaining would impinge
on the statutory authority of the Inspector General. (See Nat 'I R.R. Passenger
Corp. v. Fraternal Order of Police, Lodge 189 Labor Committee, 855 F.3d 335
(D C. Cir. April 28, 2017), cert, denied, 86 U.S.L.W. 3409 (U.S. Feb. 20, 2018)).
The union representative refused to make the subject, a union member, available for an
interview until the OIG complied with the bargaining agreement. At the request of the
union representative, OIG personnel met with the union representative in an attempt to
resolve the situation, but the union representative was belligerent and subjected OIG
personnel to yelling, cursing and an offensive comment. The OIG reported the
unprofessional conduct to the union representative's supervisor.
Interference With Access
Although the OIG reported in past semiannual reports that progress has been made in the
area of cooperation between our office and the EPA's Office of Homeland Security, we
still encounter situations where the OIG is not given access to all information required to
investigate threats against EPA employees and facilities, employee misconduct and
computer intrusions.
In a July 2015 letter, a former EPA Administrator stated that every office within the EPA
is subject to appropriate oversight by the OIG and should not impede OIG investigations.
Further, she stated that she would "not tolerate any interference with OIG's work
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
authorized under the Inspector General Act." In addition, the Federal Bureau of
Investigation indicated that the OIG should have access to requisite information.
However, during this reporting period there were at least two employee misconduct
investigations conducted by the OIG regarding which the EPA's Office of Homeland
Security did not share pertinent information. This failure to inform and share information
with the OIG caused unnecessary vulnerability for the agency and wasted taxpayer
dollars due to duplicative efforts.
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Semiannual Report to Congress
October '!, 2017—March 31, 2018
Significant OIG Activity
Congressional Activities
No congressionally requested reports were issued during this period, although numerous
such projects are currently in progress.
Investigations
Results of Gold King Mine Investigation
The OIG conducted an investigation into the August 5, 2015, release of over 3 million
gallons of contaminated mine water at the abandoned Gold King Mine. We produced
three Reports of Investigation, and on May 5, 2017, those reports were provided to the
agency for action deemed appropriate. On December 14, 2017, the agency provided a
memo detailing its responses.
The U.S. Attorney's Office responsible
for the area where the mine is located
was consulted during all stages of the
investigation and declined prosecution
of the matters noted below.
1. In response to a congressional
request, the OIG investigated
whether any EPA employees or
contractors engaged in criminal
or administrative misconduct in
connection with the mine water
release. The investigation
supported that an EPA employee
at the mine on August 5, 2015,
engaged in both potential
administrative and criminal misconduct in connection with the mine water
release—a potential violation of 18 U.S.C. § 1001 (False Statements), and
33 U.S.C. §§ 1311 and 1319 (Direct Discharge to Waters of the United States).
The EPA did not take any administrative action against the employee.
Junction
COLORADO
UTAH
FRAMQSCO PLAU
jquerque
Gold King Mine and Lake Powell are identified with
red markers. A blue line follows the river path that the
released mine water from Gold King Mine traveled.
Tribal lands are shown in tan.
Source: EPA OIG map.
11

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
2.	In response to a letter from the Executive Director of the Colorado Department of
Natural Resources, the OIG investigated whether any members of the EPA's internal
review team engaged in misconduct by falsifying information in the report that the
team issued—a potential violation of 18 U.S.C. § 1001 (False Statements). The
Executive Director identified seven assertions that were alleged to be factually
inaccurate in the team's report, which dealt with the state regulatory agency's roles and
responsibilities with respect to the release of mine water. The OIG investigation did not
support five of the seven assertions that the roles and responsibilities of the state
regulatory agency were factually inaccurate. The investigation did support that one
assertion was inaccurately reported (i.e., "for the Adit, a determination of no or low
mine water pressurization was made by experienced professionals The
investigation was inconclusive on whether a second assertion (i.e., "the ... experts ...
who supported the removal investigation ...") was factually inaccurate. The EPA did
not take administrative action against any members of the internal review team and did
not retract the team's report.
3.	In response to a letter from a state Attorney General regarding the timeliness and
methods of notification made to affected downstream stakeholders subsequent to
the mine water release, the OIG investigated whether there was a delay in reporting the
release—a potential violation of 42 U.S.C. § 9603(a) (Notification Requirements
Respecting Released Substances). The investigation did not support that any EPA
employees involved in the reporting of the mine water release to affected governments,
tribal authorities, water providers and communities downstream of the mine failed to
complete their communications in an effective and efficient manner. The OIG found
that the reporting was done in accordance with proper spill notification procedures. The
agency did not take administrative action against any EPA employees involved.
EPA Officials Collaborate to Retract Congressional Testimony
Four EPA officials, including two Senior Executive Service (SES) officials, a GS-15
EPA attorney, and a GS-15 EPA employee, participated in requiring an EPA employee
to retract testimony provided by that employee before a U.S. House of Representatives
committee as a precondition to settle an Equal Employment Opportunity complaint
filed by the employee against EPA managers, including one of the SES officials. The
investigation revealed that the second SES official asked the EPA attorney to present the
employee with the retraction offer as a settlement term, which the attorney did. The
investigation also revealed that the GS-15 employee collaborated with the second SES
official to condition the settlement of the employee's Equal Employment Opportunity
complaint on the retraction of that employee's sworn congressional testimony. It was also
found that the two SES officials collaborated to reach a settlement agreement with the
EPA employee who filed the complaint against EPA management. The U.S. Attorney's
Office, Fraud and Public Corruption Section, in Washington, D.C., and the Criminal
Division of the U.S. Attorney's Office for the district where the employee was located,
12

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
declined to prosecute the subjects for obstruction of proceedings before departments,
agencies and committees; bribery of public officials and witnesses; and conspiracy.
On December 7, 2017, the EPA attorney received a 10-day proposed suspension letter.
On February 8, 2018, the proposed suspension was mitigated to a 7-day suspension,
which was served by the attorney. On December 7, 2017, the first SES official and the
GS-15 employees were each issued a memorandum of warning for negligent performance
of duties. On December 7, 2017, the EPA issued the second SES official a notice of
proposed suspension for 60 calendar days. However, that SES official retired on
January 2, 2018 after receiving the written notice.
Briefings, Requests and Inquiries
Frequent Briefings Provided to Congress
During this reporting period, the OIG provided 16 formal briefings to Congress on the
OIG's work. The OIG received considerable congressional interest in our work related to
the EPA's travel policies and procedures, threat investigations, EPA policies and
procedures for filling administratively determined positions, and the EPA's oversight of
Puerto Rico's Clean Water and Drinking Water State Revolving Funds. In addition, several
briefings were scheduled to introduce OIG staff and work to various committee staff of the
115th Congress.
The OIG also handled dozens of informal congressional inquiries, considered numerous
requests for specific work to undertake, and responded to many data calls.
13

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Human Health and Environmental Issues
Differences in Processing Practices Could Decrease the Reliability of Ozone
Data Used for Assessing Air Quality to Protect Public Health
Report No. 18-P-0105, issued February 28, 2018
Three of the six state, local and tribal air monitoring agencies we
reviewed did not consistently use the EPA's recommended quality
assurance practices for validating and adjusting data related to
ozone in the ambient air. In addition, the EPA's oversight controls
did not always identify when data validation and adjustment
practices were inconsistent with EPA guidance. Variation in data
processing practices can decrease the reliability of the data that the
EPA uses to determine whether air is healthy and to make
regulatory decisions about air quality. We recommended that the
EPA determine the risk of data adjustments impacting its National
Ambient Air Quality Standards determinations and strengthen its
oversight of air monitoring agencies" data processes. The agency
agreed with our recommendations.
Health effects of ozone
Short-term health effects
Long-term health effects
•	Shortness of breath and pain when taking
a deep breath.
•	Coughing and sore or scratchy throat.
•	Inflamed and damaged airways.
•	Increased frequency of asthma attacks.
•	Increased susceptibility to lung infection.
•	Aggravation of asthma, and is likely to be one
of many causes of asthma development.
•	May be linked to permanent lung damage,
such as abnormal lung development in
children.
•	May increase the risk of death from
respiratory causes.
Source: OIG analysis of EPA websites describing the health effects of ozone.
EPA Has Not Reported to Congress on BEACH Act Progress as Statutorily
Required or Fully Documented Budget Decisions
Report No. 18-P-0071, issued January 18, 2018
States, territories and tribes use funds received under the Beaches
Environmental Assessment and Coastal Health Act of 2000—
known as the BEACH Act—to operate beach monitoring and public
notification programs if contamination occurs in coastal recreation
waters. However, the EPA has not submitted required quadrennial reports to Congress
describing progress and impacts under the act since 2006, stating it no longer believes


ill
it
r
Ii
!
1
1


An air monitor audit
being conducted.
(EPA photo)
A podcast on the
Beach Act report
is available.
14

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Semiannual Report to Congress
October '!, 2017—March 31, 2018
reporting is needed. Also, beginning in FY 2013, the EPA stopped requesting
funding for the program based, in part, on its view that the program is
"mature." While the agency documented initial deliberations and the final
decision to no longer request funds for this grant program, it did not document
supporting analysis and information used to make this decision. Congress has
continued to fund the program. Failure to submit required reports and keep
required records limits congressional, public and EPA knowledge about the
impact of the program. The agency disagreed with our recommendation to
submit mandated reports and resolution efforts are in progress. However, the
agency agreed with our other recommendations related to improving controls
for mandated reports. While the agency agreed to update its records
management policy and schedules, it disagreed with our recommendation to
develop and implement a tool to demonstrate compliance with recordkeeping
requirements on budget decisions. Resolution efforts are in progress.
EPA Can Better Manage State Pesticide Cooperative Agreements to
More Effectively Use Funds and Reduce Risk of Pesticide Misuse
Report No. 18-P-0079, issued February 13, 2018
The EPA could not ensure that its cooperative agreement
funding under the Federal Insecticide, Fungicide, and
Rodenticide Act achieved agency goals and reduced risks to
human health and the environment from pesticide misuse. The
EPA did not consistently assess whether funding requested by
states for compliance inspections was reasonable, and funding
for states varied significantly. Also, the EPA did not use the
performance of completed state pesticide enforcement work
plans to improve successive work plans or to demonstrate
whether compliance inspections achieved goals and
requirements. The agency agreed with our recommendations
to develop additional guidance and conduct a national review
of state work plans and performance to ensure consistent
application.
EPA Needs to Evaluate the Impact of the Revised Agricultural
Worker Protection Standard on Pesticide Exposure Incidents
Report No. 18-P-QQ8Q, issued February 15, 2018
The EPA had policies and procedures to implement the revised Agricultural Worker
Protection Standard, designed to protect the nation's more than 2 million agricultural
workers and pesticide handlers from pesticide exposure. However, management controls
to implement the revised standard were not fully adequate as of January 2, 2017, when
Pensacola Beach in
Florida. (EPA OIG photo)
Pesticide inspection.
(EPA OIG photo)
15

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Semiannual Report to Congress
October '!, 2017—March 31, 2018
compliance with most of the revised rule was required.
Although required training was provided, essential
materials were not available when the majority of the
training was conducted. Also, the EPA did not have the
ability to collect pesticide exposure incident data to
measure impact. The agency did not agree with our
recommendation to develop a methodology to
evaluate incident data, and resolution efforts are in
progress.
Analysis of Toxics Release Inventory Data Identifies Few Noncompliant Facilities
Report No. 18-P-QQ01, issued October 5, 2017
Businesses that manufacture, process or otherwise use large volumes
of listed chemicals and meet other conditions file Toxics Release
Inventory reports with the EPA, and we sought to determine how the
EPA could use cross-program data to identify potentially
noncompliant facilities in the agency's major regulatory programs.
Although we identified hundreds of potential non-filers, the EPA
found few actual non-filers. During the course of our review, the
Toxics Release Inventory program implemented changes in its filing
software that notifies filers of potential requirements in other EPA
programs. We recommended that the EPA clarify limitations to public
data and review usefulness of that data. The agency agreed with the
recommendations and initiated corrective actions.
Follow-Up Review: EPA Completed OIG Recommendations for Superfund Site
in Libby, Montana
Report No. 18-P-0Q74, issued January 24, 2018
We found that the EPA had completed all five
outstanding recommendations from the OIG s
2006 and 2013 reports regarding the Libby,
Montana, Superfund site. Contaminated with
asbestos, the Libby site was designated a national
priority in the Superfund program in 2002. The
EPA took corrective actions that enabled the
Libby toxicity assessment to be completed with
transparency and provided stakeholders with
important human exposure information.
Pesticide handler spraying a
pesticide, (EPA photo)
Image of a 2005 fire at
EQ Resource Recovery Inc.
in Romulus, Michigan.
(EPA photo)
Cleanup at a Libby residential property.
(EPA photo)
16

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Semiannual Report to Congress
October '!, 2017—March 31, 2018
Agency Business Practices and Accountability
EPA Paid $1.5 Million for Subsidized and Unoccupied Parking Spaces Over a
2-Year Period
Report No. 18 P-0036, issued November 8, 2017
Only EPA headquarters (based in Washington, B.C.) and	a podcast on the
Region 4 (based in Atlanta, Georgia) subsidized employee parking. EPA'S Parking
subsidies report
From January 2015 through December 2016, these offices paid	js avajiabie
over $840,000 to subsidize employee parking 	
and approximately $690,000 for leased parking spaces that remained
unoccupied. While allowed by law, providing subsidized parking is
not required, and we questioned the EPA"s doing so. We
recommended that the EPA determine whether the costs of
providing subsidized parking were justified according to federal
requirements and, if not, eliminate or reduce the parking subsidy .
EPA headquarters paid for	The EPA concurred with all of our recommendations and provided
unoccupied parking spaces.	corrective actions. The EPA chose no longer to offer reduced-rate or
(EPA OIG photo)	, •
' '	tree parking.
Calendar Years 2015 and 2016 subsidized parking spaces

Headquarters
Region 4
Total
Number of leased spaces
344
30
374
EPA net costs for employee-related parking spaces
Employer-subsidized spaces
$811,628
$29,991
$841,619
Unoccupied spaces
682,363
11,083
693,446
Total
$1,493,991
$41,074
$1,535,065
Source: QiG analysis of data provided by EPA regions and offices.
Improved Acquisition Planning Will Help EPA Reduce Hundreds of Millions of
Dollars in High-Risk Contracts
Report No. 18-P-Q038, issued November 15, 2017
The EPAs use of high-risk contracts could be reduced. Low-risk, firm-fixed-price
contracts represented only 9 percent of the EPAs contract obligations as of the second
quarter of FY 2017. Also, the agency cited planning difficulties as factors in each of the
10 sole-source bridge contracts sampled and did not always document acquisition
planning as required. We recommended that the EPA permit high-risk and sole-source
bridge contracts only under specific circumstances; require higher level approvals for
17

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
high-risk contracts; and issue guidance, policy and memorandums as needed. The EPA
agreed with our recommendations.
EPA contract types and values as of second quarter FY 2017
Number of contracts
Value of contracts
$406,420,048




$3,951,310,990
FFP
i All other contracts
Source: OIG analysis of EPA data as of second quarter FY 2017.
The OIG did not independently verify the EPA data.
"FFP" stands for "Firm-Fixed Price."
EPA Can Achieve Better Value by Complying With Performance-Based
Contract Requirements
Report No. 18-P-0089. issued February 20, 2018
Over a 3-year period, the EPA awarded over $4 billion dollars in performance-based
contracts. These contracts attempt to achieve better value and enhanced performance, and
focus on the results to be achieved instead of how the work is to be performed. However,
we found that over $290 million awarded in performance-based contracts could have
been put to better use if the EPA had not granted award terms for less-than-superior
service. We also found that over $75 million could have been put to better use if the EPA
required superior service in its award term contract language. The EPA agreed with 14 of
our 15 recommendations.
Self-Insurance for Companies With Multiple Cleanup Liabilities Presents
Financial and Environmental Risks for EPA and the Public
Report No. 18-P-0059, issued December 22, 2017
Financial assurance—which can include either self-insurance or assurance obtained
through third parties—is meant to prove that companies responsible for cleaning up
hazardous waste sites have the financial resources to do so. However, the EPA does not
sufficiently verify all such self-insurance. Also, companies are not required to disclose all
environmental liabilities. If self-insurance is not valid, a company may default on its
18

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Semiannual Report to Congress
October '!, 2017—March 31, 2018
cleanup obligations, leaving the EPA and
taxpayers with billions of dollars in cleanup costs.
Unlike the EPA, some federal agencies do not
accept corporate sell-insurance. We made various
recommendations regarding financial assurance.
The agency agreed with nine of our
14 recommendations, and work is underway to
resolve the remaining five recommendations.
EPA Telework Program Is Consistent With U.S. Office of Personnel
Management Guidance
Report No. 18-P-0024, issued October 16, 2017
We found that all EPA telework policies are consistent with
Office of Personnel Management guidance, the EPA includes
employee eligibility criteria in its telework policies, and the EPA
has established telework training as mandatory for supervisors and managers of
teleworking employees. While we issued no recommendations, we did provide the EPA
with suggestions for improvement, which were submitted by EPA managers and
supervisors in response to an OIG-fielded survey, as noted in the figure below.


¦ ¦ ¦ ¦



X —


•
Better
communication
tools
Consistent
telework
policy
agencywide
Expanded
telework
training
for staff
>¦ -
Union
policy
ratification
Outcome-
based
management
More
flexibility for
managers
The figure above depicts possible telework program enhancements suggested by
EPA managers and supervisors in an OIG-fielded survey, (EPA OIG)
EPA Reported Its Fiscal Year 2017 Second Quarter Financial and Award Data
in Accordance With the DATA Act
Report No. 18-P-0037, issued November 9, 2017
In accordance with the Digital Accountability and Transparency Act of 2014, also known
as the DATA Act, the EPA assessed the accuracy, completeness, quality and timeliness
of the FY 2017 second quarter financial and award data submitted for publication on
USASpending.gov. The EPA also implemented governmentwide financial data standards
Cleanup activity at the Kerr-McGee
Chemical Corp. Superfund site in
Columbus, Mississippi. (EPA photo)
A podcast on the
EPA's telework
program is
available.
19

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Semiannual Report to Congress
October '!, 2017—March 31, 2018
set by the Office of Management and Budget and the U.S. Department of the Treasury.
Historical program activity and budget class levels did not align with the act's reporting
requirements, but a tool created by the EPA resolved this issue. Therefore, no
recommendations were made.
EPA's information Security Program Is Established, but Improvements Are
Needed to Strengthen Its Processes
Report No. 18-P-0031. issued October 30, 2017
The EPA has an effective information security program and has
completed all the requirements to achieve a Level 3 (Consistently
Implemented) maturity level for the five security functions and
related domains defined within the FY 2017 Inspector General
Federal Information Security Modernization Act reporting
metrics. However, we found substantial weaknesses in the EPA's
information security training program related to how the agency
verifies whether contractor personnel with significant
information security responsibilities comply with specialized
security training requirements. We worked closely with EPA
officials and briefed them on the results.
EPA's Fiscal Years 2017 and 2016 Consolidated Financial Statements
Report No. 18-F-0039. issued November 15, 2017
We rendered an unmodified opinion on the EPA's consolidated financial statements for
FYs 2017 and 2016, meaning they were fairly presented and free of material
misstatement. We did not note any significant noncompliance with laws and regulations.
We did note the following material weaknesses:
•	The EPA's accounting for software continues to be a material weakness.
•	The EPA incorrectly recorded unearned revenue for Superfund special accounts
and did not reconcile unearned revenue for those accounts.
In addition, we noted the following significant deficiencies:
•	Additional efforts are needed to resolve the EPA's cash difference with the
U.S. Department of the Treasury.
•	The EPA needs to appoint a Project Manager to oversee the management of
Compass Financials—the agency's accounting system—and to improve
acquisition planning.
The EPA agreed with our findings and our recommendation and expects to complete the
corrective action in FY 2018.
Cybersecurity Framework. (EPA OIG graphic)
20

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Investigations
Significant Investigations
Tribal Administrator Sentenced for Embezzling EPA Grant Funds
On January 22, 2018, Delia Commander, former Tribal Administrator of the Skagway
Traditional Council in Skagway, Alaska, was sentenced to prison for embezzling funds
from the council. Commander was sentenced to 18 months in prison and 3 years of
supervised release. She was ordered to pay restitution in the amount of $297,731 to the
Skagway Traditional Council. The council had been awarded two EPA Indian General
Assistance Program grants totaling over $900,000, both of which were subject to the
fraudulent activity.
This investigation was conducted jointly with the U.S. Department of the Interior Office
of Inspector General.
Man Sentenced for Fraud Scheme to Collect Stimulus Funds
On February 27, 2018, Heon Seok Lee received a 12-month prison sentence, was fined
$20,000, and will be deported upon the completion of his term related to a fraud scheme
to collect stimulus funds. In addition, restitution in the amount of $180,392 will be
divided between two municipalities that were victims of his scheme. A criminal forfeiture
determination is pending.
Heon Seok Lee served as President of KTurbo Inc. in South Korea and President of its
subsidiary, KTurbo USA Inc., which has an office and warehouse in Illinois. From
January 2010 to February 2011, Lee directed others to procure contracts for KTurbo to
provide centrifugal turbo blowers to municipal wastewater treatment facilities in the
United States receiving American Recovery and Reinvestment Act of 2009 stimulus
funds from the EPA. Lee and others sent at least five email communications to U.S.
municipal wastewater treatment facilities falsely representing that KTurbo would
manufacture and deliver turbo blowers in compliance with the "Buy American" provision
of the Recovery Act. Lee had nine turbo blowers sent to the KTurbo facility in Illinois
from South Korea. The turbo blowers were largely assembled in South Korea but had
"Assembled in USA" placards. Lee and others did not intend to perform substantial
transformation of the turbo blowers. In total, Lee and others intended to fraudulently
obtain over $1.3 million in Recovery Act funds. Lee was convicted on multiple fraud
21

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
charges for deceiving U.S. municipalities into spending federal stimulus money on
foreign-made products.
This investigation was conducted with Interpol the U.S. Department of Homeland
Security and the U.S. Department of Justice.
Contractor Debarred From Participating in Federal Grants and Contracts
On October 11, 2017, an EPA contractor was debarred from participating in federal
contracts and assistance activities for a period of 3 years. Nirilla Allen-Kearney, a
contract employee at the EPA, was arrested at an EPA facility by Internal Revenue
Service and Federal Bureau of Investigation investigators, with assistance from EPA OIG
investigators. The arrest was conducted in conjunction with the arrests of several other
individuals not associated with the EPA for various alleged narcotics charges, none of
which were alleged to have occurred at an EPA facility. Allen-Kearney and several
co-subjects were indicted on various charges by a federal grand jury in the Eastern
District of North Carolina. Allen-Kearney pleaded guilty to conspiracy to commit money
laundering and was sentenced to 24 months in prison. Allen-Kearney was also barred
from accessing all EPA facilities and debarred by the EPA's Office of Suspension and
Debarment from participating in government contracts for 3 years.
This investigation was conducted jointly with the Internal Revenue Service Criminal
Investigation Division and the Federal Bureau of Investigation.
Man Sentenced for Providing False Asbestos Training Certifications
On November 15, 2017, the U.S. District Court for the District of Connecticut sentenced
Guido Cortes-Rodriguez, an employee of an EPA grantee, to 2 years of probation, with
the first 6 months served in home confinement, for making a false statement to the federal
government. He also was ordered to perform 160 hours of community service. Cortes-
Rodriguez was the training director for a nonprofit organization that received EPA grant
funds to conduct asbestos training for contractors handling lead abatement and asbestos
removal. In that role, Cortes-Rodriguez was responsible for conducting training classes
and notifying the Connecticut Department of Public Health about who had attended and
successfully completed asbestos and lead abatement training. The investigation supported
that, in exchange for money, Cortes-Rodriguez provided false training certifications for
certain individuals who, in reality, had not taken the training.
This investigation is ongoing and is being conducted jointly with the Federal Bureau of
Investigation and the EPA Criminal Investigation Division.
22

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Reports of Investigation
A Report of Investigation is a stand-alone document used to report the facts of an OIG
investigation and generally involves an employee integrity matter. When the OIG's
Office of Investigations provides a Report of Investigation that has at least one
"supported" allegation to the EPA or internally to the OIG, the Office of Investigations
requests that the entity receiving the report provide a notification within 60 days as to
whether there are plans to take any actions. This section provides information on how
many Reports of Investigation with at least one supported allegation were issued to the
agency and to the OIG, and for how many of those Reports of Investigation a response
was not received within a 60-day period.
For the reporting period ending March 31, 2018, the Office of Investigations received one
internal OIG response to a Report of Investigation after 60 days:
Agency and OIG Reports of Investigation
No. of Reports of
Investigation issued
during reporting
period with findings
Agency
response*
received after
60 days
Awaiting
agency
response
OIG
response*
received
after
60 days
Awaiting
OIG
response
13
0
0
^ **
0
* Agency or the OIG will or will not take an action, or will conduct a supplemental investigation.
** Report of Investigation issued within the OIG.
At the end of a reporting period, the Office of Investigations lists Reports of Investigation
cases for which no agency or OIG response has been received, as shown below:
Cases awaiting agency response
Case No.
Date sent to
agency
Number of days
without response
Agency explanation
None
None
0
None
Cases awaiting OIG response
Case No.
Date sent to
agency
Number of days
without response
Agency explanation
None
None
0
None
23

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Hotline Activities
The purpose of the EPA OIG Hotline is to receive complaints of fraud, waste or abuse in
EPA programs and operations, including mismanagement or violations of law, rules or
regulations by EPA employees or program participants. Examples of reportable
violations include contract, procurement and grant fraud; bribery and acceptance of
gratuities; significant mismanagement and waste of funds; conflict of interest; travel
fraud; abuse of authority; theft or abuse of government property; and computer crime.
As a result of hotline complaints, the OIG may conduct audits as well as investigations.
In addition to being responsible for EPA-related hotline inquiries, we are responsible for
CSB-related inquiries. Details on audit and investigative work during the semiannual
reporting period follow.
Audit Reports Initiated via OIG Hotline
EPA Did Not Use Allegedly Flawed Studies to Estimate Methane Emissions or
Set New Source Performance Standards for Oil and Natural Gas Production
Report No. 18-P-0129, issued March 16, 2018
A hotline complaint alleged that the
EPA used results from two flawed
studies to estimate methane emissions
and to make policy decisions regarding
oil and natural gas production. We did
not find the hotline complaint to be
substantiated. The Inventory of U.S.
Greenhouse Gas Emissions and Sinks
(Greenhouse Gas Inventory) reflects
the EPA's official nationwide estimate
for greenhouse gas emissions from all
man-made sources, including those
from oil and natural gas production.
We found that the EPA did not make
any methodological revisions to the
Greenhouse Gas Inventory or the
Greenhouse Gas Reporting Program
based on the two studies, and data from the studies have not been incorporated
into the inventory. In addition, the EPA did not use data from the studies to set
new source performance standards for oil and gas production.
Estimated methane emissions trends
comparison for the natural gas industry
(1990-2015)


Methane

emissions

from production

segment:
Methane
51% Increase
emissions

from other

segments:

55% Decrease
L
1
Source: OIG image derived from EPA data.
24

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Inconsistencies With EPA Policy Identified in Region 10's Biweekly Pay Cap
Waiver Process
Report No. 18-P-0068, issued January 12, 2018
Our audit generated by a hotline complaint alleging that EPA Region 10 mismanaged its
biweekly pay cap waiver process found that the region's process for approving such
waivers was not consistent with agency policy. Of the 61 instances with valid pay cap
exceedances noted during FYs 2015, 2016 and 2017 (through January 7, 2017), we
determined that 25 instances required waivers. The pay cap may be waived for employees
who earn premium pay while working during an emergency, but some waivers lacked
adequate information to determine whether there was an emergency; Region 10
subsequently provided supplemental documentation to support that an emergency existed.
We also found three instances in which Region 10 could not locate waiver requests to
support exceedances totaling $2,355. No recommendations were made because pertinent
policies and procedures were implemented by Region 10 during the audit.
Significant Investigations Initiated via OIG Hotline
Individual Indicted on Theft of Federal Funds
On February 14, 2018, Tracy Bronson of Marshall, Michigan, was indicted on five counts
of theft concerning programs receiving federal funds. Bronson was the Executive
Director of the Calhoun Conservation District in Calhoun County, Michigan. In calendar
years 2014, 2016 and 2017, the district received federal grant funds from the EPA and the
U.S. Fish and Wildlife Service. Bronson is accused of misappropriating over $500,000 of
grant funds for her own personal benefit and use.
Employee Retired While Under Investigation for Ethics Violations
On January 4, 2018, an EPA GS-13 employee retired from federal service after the EPA
advised the employee of a proposed 3-day suspension related to an ethics violation. The
employee was investigated for misrepresenting secondary employment status with a local
university. The employee had submitted the information on the U.S. Office of
Government Ethics Form 450. However, facts disclosed during the investigation
confirmed that the employee did not fully disclose the secondary employment status with
the university to the EPA on Form 450 submissions from 2011 and 2012. The
investigation also revealed that the employee used university students to perform official
EPA duties outside of an established memorandum of understanding.
Employee Resigns Prior to Removal for Inappropriate Use of Laptop
On December 21, 2017, the EPA issued a notice of proposed removal to a GS-13
employee for inappropriate conduct, lack of candor and misuse of government
25

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
equipment. The employee allegedly engaged in the inappropriate use of an EPA laptop.
The employee was arrested for stalking and unlawful surveillance offenses. The
investigation revealed that at the time of arrest, the employee was in possession of an
EPA laptop. The investigation also revealed that the employee used the laptop, the EPA's
shared drive, and an EPA email account while involved in activities related to stalking
and unlawful surveillance. The EPA issued a notice of proposed removal; however, the
day before the proposed removal date of December 29, 2017, the employee resigned.
Hotline Statistics
The following table shows EPA OIG Hotline activity regarding complaints of fraud,
waste and abuse in EPA programs and operations during the semiannual reporting period
ending March 31, 2018.
Semiannual period
(October 1,2017-
March 31, 2018)
Issues open at the beginning of the period
220
Inquiries received during the period
197
Inquiries closed during the period
123
Inquiries pending at the end of the period
294
Issues referred to others

OIG offices
170
EPA program offices
18
Other federal, state and local agencies
9
Contacts to the EPA OIG Hotline
(telephone, voicemails, emails, website and
correspondence)
5,343
26

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
The table below details the categories of inquiries the EPA OIG Hotline receives that
are retained by the EPA OIG and reviewed by investigation and audit staff. For the first
6 months of FY 2018, the hotline retained 170 of the 197 inquiries received for review
and action.
170 REFERRALS TO EPA OIG
OCTOBER 1, 2017 - MARCH 31, 2018
Computer Crimes Pi
I
Programmatic and Operations f
Contracts
Grants
Employee Ethics f" 1
Employee Misconduct
Employee Time & Attendance f
Threat & Workplace Violence
Laboratory Fraud Pi


I 10



The hotline makes it easy to report allegations of fraud, waste, abuse, mismanagement
or misconduct in the programs and operations of the EPA. Employees, as well as
contractors, grantees, program participants and members of the general public, may
report allegations to the OIG. Complaints may be submitted to the hotline by phone, fax
and U.S. mail; or electronically by using email or the OIG's online complaint form.
Hotline Confidentiality
The Inspector General Act of 1978, as amended, and other laws protect those who
make hotline complaints. For example, the Whistleblower Protection Enhancement
Act of 2012 provides protection to employees who disclose misconduct or misuse
of government resources.
Individuals who contact the hotline are not required to identify themselves and may
request confidentiality when submitting allegations. However, the OIG encourages those
who report allegations to identify themselves so that they can be contacted if the OIG has
additional questions. Pursuant to Section 7 of the Inspector General Act, the OIG will not
disclose the identity of an EPA employee who provides information unless that employee
consents or the Inspector General determines that such disclosure is unavoidable during
the course of the investigation, audit or evaluation.
27

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
As a matter of policy, the OIG will provide comparable protection to employees of
contractors, grantees and others who provide information to the OIG and request
confidentiality.
Individuals concerned about the confidentiality or anonymity of electronic
communication may submit allegations by telephone or mail.
EPA OIG Hotline
To report fraud, waste or abuse, contact us through one of the following methods:
email:	OIG Hotline@epa.gov
phone:	888-546-8740 or 202-566-2476
fax:	202-566-0814
online:	EPA OIG Hotline
write EPA OIG Hotline
1200 Pennsylvania Avenue, NW
Mailcode 2431T
Washington, DC 20460
28

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Other Activities
Legislation and Regulations Reviewed
Section 4(a) of the Inspector General Act requires the Inspector General to review
existing and proposed legislation and regulations relating to the program and operation of
the EPA and to make recommendations concerning their impact. We also review drafts of
Office of Management and Budget circulars, memorandums, executive orders, program
operations manuals, directives and reorganizations. The primary basis for our comments
are the audit, investigation and legislative experiences of the OIG, as well as our
participation on the Council of the Inspectors General on Integrity and Efficiency. During
the reporting period, we reviewed 30 proposed changes to legislation, regulations, policy,
procedures or other documents that could affect the EPA or the Inspector General, and
provided no comments.
29

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Semiannual Report to Congress
October '!, 2017—March 31, 2018
U.S. Chemical Safety and Hazard Investigation Board
The U.S. Chemical Safety and Hazard Investigation
Board (CSB) was created by the Clean Air Act
Amendments of 1990. The CSB s mission is to
investigate accidental chemical releases at facilities,
report to the public on the root causes and
recommend measures to prevent future occurrences.
In FY 2004, Congress designated the EPA Inspector General to serve as the Inspector
General for the CSB. As a result, the EPA OIG has the responsibility to audit, evaluate,
inspect and investigate the CSB's programs, and to review proposed laws and regulations
to determine their potential impact on the CSB's programs and operations. Details on our
work involving the CSB are available on the OIG's webpage about the CSB.
CSB Audit Reports
Improvements Needed in CSB's Identity and Access Management and Incident
Response Security Functions
Report No. i.vF C030, issued October 30, 2017
We rated the CSB's information security program at Level 2 (Defined)
for all five Cybersecurity Framework Security Function areas and
corresponding metric domains assessed as specified by the FY 2017
Inspector General Federal Information Security Modernization Act
Reporting Metrics. However, we found that the CSB did not include
fully defined processes for Personal Identity Verification card
technology for physical and logical access. Also, the CSB did not
include fully defined incident response processes or technologies to
respond to cybersecurity events. We worked closely with the CSB
throughout the audit to keep it apprised of our findings
Audit of the U.S. Chemical Safety and Hazard Investigation Board's
Fiscal Years 2017 and 2016 Financial Statements
Report No, 18-F-0040, issued November 15, 2017
The firm that audited the CSB's financial statements for FYs 2017 and 2016 on behalf of
the EPA OIG found the statements to be fairly presented and free of material
misstatements. The firm noted no matters involving internal controls, instances of
noncompliance or other matters that are required to be reported.

Personal Identity Verification
authentication. (EPA OIG graphic)
30

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Other Results of OIG Work
Follow-Up Is Important Aspect of OIG Efforts
It is important for an OIG to follow up on certain previously issued reports to ensure that
appropriate and effective corrective actions have been taken. The following reports issued
during the semiannual reporting period ending March 31, 2018, involved follow-up on
prior OIG reports.
Report No.
Report Title
Date
18-P-0001
Analysis of Toxics Release Inventory Data Identifies
Few Noncompliant Facilities
October 5, 2017
18-P-0030
Improvements Needed in CSB's Identity and Access
Management and Incident Response Security
Functions
October 30, 2017
18-P-0031
EPA's Information Security Program Is Established, but
Improvements Are Needed to Strengthen Its
Processes
October 30, 2017
18-P-0037
EPA Reported Its Fiscal Year 2017 Second Quarter
Financial and Award Data in Accordance With the
DATA Act
November 9, 2017
18-F-0039
EPA's Fiscal Years 2017 and 2016 Consolidated
Financial Statements
November 15, 2017
18-F-0040
Audit of the U.S. Chemical Safety and Hazard
Investigation Board's Fiscal Years 2017 and 2016
Financial Statements
November 15, 2017
18-P-0059
Self-Insurance for Companies With Multiple Cleanup
Liabilities Presents Financial and Environmental Risks
for EPA and the Public
December 22, 2017
18-P-0068
Inconsistencies With EPA Policy Identified in
Region 10's Biweekly Pay Cap Waiver Process
January 12, 2018
18-P-0074
Follow-Up Review - EPA Completed OIG
Recommendations for Superfund Site in Libby,
Montana
January 24, 2018
18-P-0079
EPA Can Better Manage State Pesticide Cooperative
Agreements to More Effectively Use Funds and
Reduce Risk of Pesticide Misuse
February 13, 2018
18-P-0080
EPA Needs to Evaluate the Impact of the Revised
Agricultural Worker Protection Standard on Pesticide
Exposure Incidents
February 15, 2018
18-P-0089
EPA Can Achieve Better Value by Complying With
Performance-Based Contract Requirements
February 20, 2018
18-P-0105
Differences in Processing Practices Could Decrease the
Reliability of Ozone Data Used for Assessing Air
Quality to Protect Public Health
February 28, 2018
31

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Single Audit Reporting Efforts Make Impact
In accordance with the Single Audit Act of 1984 and Office of Management and Budget
guidance, nonfederal entities that expend more than $750,000 in federal funds (usually in the
form of grants) are required to have a comprehensive annual audit of their financial
statements and compliance with major federal program requirements. The entities receiving
the funds include states, local governments, tribes and nonprofit organizations. The act
provides that grantees are subject to one annual comprehensive audit of all their federal
programs versus a separate audit of each federal program, hence the term "single audit."
The audits are usually performed by private firms. Federal agencies rely upon the results of
single audit reporting when performing their grants management oversight of these entities.
The OIG provides an important customer service to the EPA by performing technical
reviews of single audit reports, and issues memos to the EPA for audit resolution and
corrective action. These memos recommend that EPA action officials confirm that
corrective actions have been taken. If the corrective actions have not been implemented,
the EPA needs to obtain a corrective action plan, with milestone dates, for addressing the
findings in a single report. A summary of single audit reporting actions during the
semiannual reporting period ending March 31, 2018, follows.
Summary of single audit activity for semiannual period ending March 31, 2018
No. of single
No. of single
Questioned
No. of quality
Deficiency
audit memos
audit findings
costs
reviews of single
letters issued to
issued to
reported to
reported to
audits reports
single auditors
EPA
EPA
EPA
done by OIG
by OIG
126
258
$73,802
3
1
Source: OIG analysis.
The OIG also provides technical assistance and advice to the EPA, single auditors and
others involved with the single audit process. For example, cross-cutting single audit
issues that were raised by several state single audit organizations were elevated by the
OIG to the EPA. Those issues involved EPA grants policies. The EPA reviewed the
issues and provided guidance to the state audit organizations.
32

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Agency Best Practices
During the semiannual reporting period, two OIG reports highlighted agency
best practices that have potential value and applicability to other components
in the EPA:
•	The EPA's telework program is consistent with U.S. Office of Personnel
Management guidance. The EPA's telework policies have resulted in nearly all
managers being trained to supervise their teleworking employees.
(Report No. 18-P-0024)
•	In 2016, the EPA released a marine sanitary survey mobile application based on
the agency's routine marine beach sanitary survey form. The mobile application
provides managers of marine beaches with an innovative and consistent approach
for identifying sources of beach pollution in the field. Additionally, the Office of
Water published a non-technical guide on how to develop predictive tools in the
context of an overall beach monitoring and notification program.
(Report No. 18-P-0071)
33

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Statistical Data
Profile of Activities and Results
OIG audits

October 1,2017-
March 31, 2018
($ millions)
Questioned costs
Potential monetary benefits*
Reports issued by OIG
$0
$374,664
18
Investigative operations
($ in millions)

October 1,2017-


March 31, 2018



($ millions)


EPA OIG



only
Joint**
Total
Total fines and recoveries
$0,000
$0,499
$0,499
Cost savings
$0,539
$0,000
$0,539
Civil settlements
$0,000
$0,000
$0,000
Cases open during period
57
7
64
Indictments/lnformations/Complaints
1
2
3
Cases closed during period
46
8
54
Convictions
0
1
1
Civil judgments/settlements/filings
0
0
0
* Questioned costs and potential monetary benefits are subject to change
pending further review in the audit resolution process.
** With another federal agency.
34

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Audit Report Resolution
Table 1: OIG-issued reports with questioned costs for semiannual period ending March 31, 2018
($ in thousands)
Report category
No. of
reports
Questioned
costs *
Unsupported
costs
A.
For which no management decision was made by
October 1, 2017**
8
$6,327
$3,579
B.
New reports issued during period
16
0
0
Subtotals (A + B)
24
6,327
3,579
C.
For which a management decision was made during
the reporting period:
20
250
227

(i) Dollar value of disallowed costs

24
226

(ii) Dollar value of costs not disallowed

226
1
D.
For which no management decision was made by
March 31, 2018
21
1,232
79
* Questioned costs include unsupported costs.
** Any difference in number of reports and amounts of questioned costs between this report and our previous
semiannual report results from corrections made to data in our audit tracking system.
Table 2: OIG-issued reports with recommendations that funds be put to better use for
semiannual period ending March 31, 2018 ($ in thousands)
Report Category
No. of
reports
Dollar
Value
A.
For which no management decision was made by October 1, 2017 *
16
$127,070
B.
New reports issued during the reporting period
16
0
Subtotals (A + B)
32
127,070
C.
For which a management decision was made during the reporting period:
20
21,335
(i) Dollar value of recommendations from reports that were
agreed to by management

10,229
(ii) Dollar value of recommendations from reports that were
not agreed to by management

11,106
D.
For which no management decision was made by March 31, 2018
21
386,709
* Any difference in number of reports and amounts of funds put to better use between this report and our previous
semiannual report results from corrections made to data in our audit tracking system.
Audits with no final action as of March 31, 2018, over 365 days past the date of the accepted
management decision (including audits, inspections and evaluations in appeal)
Audits
Total
Percentage
Program
43
83%
Assistance agreements
2
13%
Financial statement
7
4%
Total
52
100%
35

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Summary of Investigative Results
Summary of investigative activity during reporting period
Cases open as of October 1, 2017 *
197
Cases opened during period
64
Cases closed during period
54
Cases pending as of March 31, 2018
207
Complaints open as of October 1, 2017
26
Complaints opened during period
56
Complaints closed during period
59
Complaints pending as of March 31, 2018
23
* Adjusted from prior period.
Results of prosecutive actions

EPA OIG only
Joint *
Total
Criminal indictments/informations/complaints **
1
2
3
Convictions
0
1
1
Civil judgments/settlements/filings
0
0
0
Criminal fines and recoveries
$0
$499,123
$499,123
Civil recoveries
$0
$0
$0
Prison time
0 months
30 months
30 months
Prison time suspended
0 months
0 months
0 months
Home detention
0 months
6 months
6 months
Probation
0 months
60 months
60 months
Community service
0 hours
160 hours
160 hours
*With another federal agency.
** Sealed indictments are not included in this category.
Administrative actions

EPA OIG only
Joint *
Total
Suspensions
0
0
0
Debarments
0
3
3
Other administrative actions
36
4
40
Total
36
7
43
Administrative recoveries
$27,503
$0
$27,503
Cost savings
$538,912
$0
$538,912
* With another federal agency.
36

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Semiannual Report to Congress	October 1, 2017—March 31, 2018
Summary of investigative reports issued and referrals *
Number of investigative reports issued
14
Number of persons referred to U.S. Department of Justice for criminal prosecution
15
Number of persons referred to state and local authorities for criminal prosecution
0
Number of criminal indictments and informations resulting from any prior referrals to
prosecutive authorities
2
* Investigative reports are comprised of final reports of investigation, final summary reports, interim reports of
investigation and supplemental reports of investigation. In calculating the number of referrals, corporate entities were
counted as "persons."
Employee integrity cases*

Political
appointees
SES
GS-14/15
GS-13 and
below
Misc.
Total
Pending 10/1/18
2
9
61
72
7
151
Opened*
1
1
3
14
1
20
Closed*
0
3
11
19
3
36
Pending 3/31/18**
3
8
53
68
4
136
* Integrity investigation cases involve allegations of criminal activity or serious misconduct by agency employees that
could threaten the credibility of the agency, the validity of executive decisions, the security of personnel or business
information entrusted to the agency, or financial loss to the agency (such as abuse of government bank cards or theft of
agency funds). Allegations against former employees are included under "Misc."
** Pending amounts as of 3/31/18 may not add up due to investigative developments resulting in subjects being added
or changed.
The chart below provides a breakdown by grade and number of employees who are the subject of employee integrity
investigations.
Employee integrity cases: Breakdown by grade and number of employees
¦ Political Appointees
¦ 13 arid below
37

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Appendices
Appendix 1—Reports Issued
The Inspector General Act of 1978, as amended, requires a listing, subdivided according to subject matter, of each report issued by
the OIG during the reporting period. For each report, where applicable, the Inspector General Act also requires a listing of the dollar
value of questioned costs and the dollar value of recommendations that funds be put to better use.
All reports listed below were performed in accordance with generally accepted government auditing standards.
Questioned Costs
Report No.
Report
Date
	 Potential
Monetary
Ineligible Unsupported Unreasonable Benefits
FINANCIAL STATEMENT AUDIT REPORTS
18-F-0039	EPA's Fiscal Years 2017 and 2016 Consolidated Financial
Statements
18-F-0040	Audit of the U.S. Chemical Safety and Flazard Investigation
Board's Fiscal Years 2017 and 2016 Financial Statements
TOTAL FINANCIAL STATEMENT AUDIT REPORTS = 2
11/15/2017
11/15/2017
0
$0
0
$0
0
$0
0
$0
PERFORMANCE AUDIT REPORTS
18-P-0001	Analysis of Toxics Release Inventory Data Identifies Few	10/5/2017
Noncompliant Facilities
18-P-0024	EPATelework Program Is Consistent With U.S. Office of	10/16/2017
Personnel Management Guidance
18-P-0030	Improvements Needed in CSB's Identity and Access Management 10/30/2017
and Incident Response Security Functions
18-P-0031	EPA's Information Security Program Is Established, but	10/30/2017
Improvements Are Needed to Strengthen Its Processes
18-P-0036	EPA Paid $1.5 Million for Subsidized and Unoccupied Parking	11/8/2017
Spaces Over a 2-Year Period
18-P-0037	EPA Reported Its Fiscal Year 2017 Second Quarter Financial	11/9/2017
Award Data in Accordance With the DATA Act
18-P-0038	Improved Acquisition Planning Will Help EPA Reduce Hundreds of 11/15/2017
Millions of Dollars in High-Risk Contracts
18-P-0059	Self-Insurance for Companies With Multiple Cleanup Liabilities	12/22/2017
Presents Financial and Environmental Risks for EPA and the
Public
18-P-0068	Inconsistencies With EPA Policy Identified in Region 10's Biweekly 1/12/2018
Pay Cap Waiver Process
18-P-0071	EPA Has Not Reported to Congress on BEACH Act Progress as	1/18/2018
Statutorily Required or Fully Documented Budget Decisions
18-P-0074	Follow-Up Review: EPA Completed OIG Recommendations for	1/24/2018
Superfund Site in Libby, Montana
18-P-0079	EPA Can Better Manage State Pesticide Cooperative Agreements	2/13/2018
to More Effectively Use Funds and Reduce Risk of Pesticide
Misuse
18-P-0080	EPA Needs to Evaluate the Impact of the Revised Agricultural	2/15/2018
Worker Protection Standard on Pesticide Exposure Incidents
18-P-0089	EPA Can Achieve Better Value by Complying With	2/20/2018
Performance-Based Contract Requirements
18-P-0105	Differences in Processing Practices Could Decrease the Reliability 2/28/2018
of Ozone Data Used for Assessing Air Quality to Protect Public
Health
18-P-0129	EPA Did Not Use Allegedly Flawed Studies to Estimate	3/16/2018
Methane Emissions or Set New Source Performance Standards
for Oil and Natural Gas Production
TOTAL PERFORMANCE AUDIT REPORTS = 16
$0
$0
0
0
0
0
0
0
0
0
0
0
0
0	0
0
373,140,113
0	0
$0 $374,664,113
0
0
0
1,524,000
0
0
0
0
0
0
0
TOTAL REPORTS ISSUED -18
$0
$0
$0 $374,664,113
38

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Appendix 2—Reports Issued Without Management Decisions
For Reporting Period Ended March 31, 2018
Section 5(a)(10)(B) of the Inspector General Act of 1978, as amended, requires a summary of each audit, inspection
and evaluation report issued during the reporting period for which no establishment comment was returned within
60 days of providing the report to the establishment. The literal language of Section 5(a)(10)(B) requests the OIG to
track reports issued prior to commencement of the reporting period. However, given that this provision was intended
to codify the February 27, 2015, semiannual requests from Senators Grassley and Johnson, the OIG interprets this
provision to apply to reports within the semiannual period.
Section 5(a)(10)(A) of the Inspector General Act of 1978, as amended, requires a summary of each audit, inspection
and evaluation report issued before the commencement of the reporting period for which no management decision
had been made by the end of the reporting period, an explanation of the reasons such management decision had not
been made, and a statement concerning the desired timetable for achieving a management decision on each such
report. Office of Management and Budget Circular A-50 requires resolution within 6 months of a final report being
issued. In this section, we report on audits and evaluations with no management decision or resolution within
6 months of final report issuance. In the summaries below, we note the agency's explanation of the reasons a
management decision had not been made as of March 31, 2018.
Office of Air and Radiation
Report No. 17-P-0249, Improved Data and EPA Oversight Are Needed to Assure Compliance With the
Standards for Benzene Content in Gasoline, June 8, 2017
Summary: The EPA could improve the effectiveness of its oversight processes and controls for the benzene fuels
program to better assure that refineries and importers report accurate and complete data, and comply with the
gasoline benzene standards. We reviewed all batch and annual benzene reports for the period 2011 through 2014.
Reported annual volumes and/or annual average benzene concentrations did not match supporting batch reports for
over 25 percent of the regulated facilities. We identified potential noncompliance with the benzene standards at
40 facilities. For 16 of these facilities, EPA staff had never reviewed these facilities for compliance using its
compliance assessment tool, conducted an on-site compliance audit as of the time of our review, or reviewed the
facilities prior to the year in which we identified the potential noncompliance. According to data reported to the EPA at
the time of our review, these 16 facilities produced or imported over 13 billion gallons of gasoline during 2011 through
2014, which potentially did not meet applicable benzene standards for gasoline (about 3 percent of total U.S. volume
during that period). We made 10 recommendations for the EPA to improve data quality and completeness, and
review instances of potential noncompliance. Two recommendations remain unresolved pending the EPA providing
completion dates for the corrective actions.
Agency Explanation: The agency provided a response to the final report on October 19, 2017. Discussion regarding
acceptance of the response is ongoing within the OIG.
Office of the Administrator
Report No. 17-P-0378, Management Alert: EPA Should Promptly Reassess Community Risk Screening Tool,
September 7, 2017
Summary: Our review substantiated some hotline allegations about the Community-Focused Risk Screening Tool,
known as C-FERST. We found that the EPA's Office of Research and Development took 8 years to develop a tool
that is different from its intended purpose, requires effective training to use, overlaps with other EPA tools, and
had not been widely used in the approximately 9 months after it was publicly released. Without metrics to measure
performance, it is unclear whether the Community-Focused Risk Screening Tool is being used for its intended
purpose or meets user needs. Further, having multiple agency mapping tools that perform similar functions can
confuse potential users. One recommendation—for the Deputy Administrator to examine all of the EPA's web-based
screening and mapping tools to ensure the need for each tool and to avoid potential overlap, duplication and waste—
is unresolved.
Agency Explanation: The OIG received the EPA's response. The agency and the OIG continue to have discussions
about the unresolved recommendation.
39

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Office of the Chief Financial Officer
Report No. 17-P-0410, Management Alert: Controls Failed to Prevent Employee From Receiving Payment in
Excess of Statutory Limit, September 27, 2017
Summary: Internal controls failed to prevent an unauthorized overpayment to a Protective Service Detail agent,
causing the agent's 2016 salary to exceed the annual statutory pay cap. The agent's biweekly pay for the period
ending January 7, 2017, included an adjustment of $23,413. According to the agent, the additional payment was for
work hours not compensated in 2016. The agent believed that payment for these hours was not issued in 2016
because of the biweekly pay cap. Neither the EPA nor the agency's payroll provider could provide the OIG with an
explanation for this unauthorized payment until July 2017, when the OIG was informed that the payment was for
hours worked by the agent in 2016, but the EPA payroll provider could not process those hours until January 2017.
Since the payment was not processed until the next calendar year, the payroll provider's system did not detect the
agent exceeding the 2016 annual pay cap. If not for the actions of the agent, this overpayment may have remained
undetected. According to the EPA payroll provider, this payment was unauthorized.
Agency Explanation: The OIG is reviewing the EPA's response. The OIG and the agency continue working to
resolve the report's recommendations.
Region 1—Regional Administrator
Report No. 17-P-0368, Improved Management of the Brownfields Revolving Loan Fund Program Is Required
to Maximize Cleanups, August 23, 2017
Summary: Approximately $10.9 million available to clean up brownfields was not being used as intended.
Contaminated brownfield properties were not being cleaned up and redeveloped for 10 of the 20 closed Brownfields
Revolving Loan Fund cooperative agreements reviewed. The recipients of the cooperative agreements have not
re-loaned or spent program income collected after the closeout agreement was signed. We found confusion
among EPA regions and Revolving Loan Fund recipients, and dissimilarities in terms and conditions, leading to
inconsistencies in program application. Program income was not maximized by depositing funds into an interest-
bearing account, and sources of program income were excluded from the terms and conditions of cooperative
agreements and closeout agreements. Another source of confusion was knowing when post-closeout program
income was used, and when a closeout agreement can be terminated. These issues resulted in inconsistencies that
could potentially affect the long-term sustainability of the Brownfields Revolving Loan Fund Program. We questioned
over $2.7 million that three Brownfields Revolving Loan Fund recipients received.
Agency Explanation: The OIG has not received a response from the EPA.
Region 2—Regional Administrator
Report No. 17-P-0053, Additional Measures Can Be Taken to Prevent Deaths and Serious Injuries From
Residential Fumigations, December 12, 2016
Summary: Since 2002, at least 11 deaths and two serious injuries occurred during residential fumigations in the two
U.S. states with the most fumigation treatments—California and Florida. Compliance with current pesticide use
requirements does not always prevent adverse impacts. We identified multiple factors that contributed to these
adverse impacts, including: (1) no requirement to secure tenting around structures undergoing fumigation;
(2) ineffective devices used to detect pesticide levels inside of structures and (3) failure to attend mandatory training
by residential pesticide applicators who conduct fumigations. A recommendation remains unresolved regarding
Region 2 needing to include additional requirements in a cooperative agreement with Puerto Rico regarding an
investigation and evaluation of sulfuryl fluoride usage and whether misuse has occurred.
Agency Explanation: No official EPA response has been received. Discussions about the recommendations are
ongoing within the OIG.
40

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Region 8—Regional Administrator
Report No. 2007-4-00078, Cheyenne River Sioux Tribe Outlays Reported Under Five EPA Assistance
Agreements, September 24, 2007
Summary: The tribe did not comply with the financial and program management standards under the Code of
Federal Regulations and Office of Management and Budget Circular A-87. We questioned $3,101,827 of the
$3,736,560 in outlays reported. The tribe's internal controls were not sufficient to ensure that outlays reported
complied with federal cost principles, regulations and grant conditions. In some instances, the tribe also was not able
to demonstrate that it had completed all work under the agreements and had achieved the intended results.
Agency Explanation: The OIG has not received a response from the EPA.
Total reports issued before reporting period for which
no management decision had been made as of March 31, 2018 = 6
41

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Appendix 3—Reports With Corrective Action Not Completed
In compliance with reporting requirements of Sections 5(a)(3) and 5(a)(10)(C) of the Inspector General Act of 1978, as amended, we
are to identify each significant recommendation described in previous semiannual reports on which corrective action has not been
completed, and a summary of each audit, inspection and evaluation report for which there are any outstanding unimplemented
recommendations. We are also to identify the aggregate potential monetary benefits of the unimplemented recommendations.
This appendix contains separate tables of unimplemented recommendations for the EPA and CSB from 2001 to March 31, 2018.
There is a total of 114 current and unimplemented recommendations for the EPA with total potential monetary benefits of $860 million,
of which $0 was sustained by the agency. Sustained cost is the dollar value of questioned costs or monetary benefits identified by
the OIG during an audit/evaluation and agreed to in whole or in part by the agency. There were $0,402 million of monetary benefits
for the CSB.
Below is a listing of the responsible EPA offices to which recommendations included in the following tables are directed. While a
recommendation may be listed as unimplemented, the agency may be on track to complete agreed-upon corrective actions by the
planned due date.
Responsible EPA Offices:
OA
Office
of the Administrator
OAR
Office
of Air and Radiation
OARM
Office
of Administration and Resources Management
OCFO
Office
of the Chief Financial Officer
OCSPP
Office
of Chemical Safety and Pollution Prevention
OECA
Office
of Enforcement and Compliance Assurance
OEI
Office
of Environmental Information
OLEM
Office
of Land and Emergency Management
OP
Office
of Policy (within the Office of the Administrator)
ORD
Office
of Research and Development
OW
Office
of Water
Region 1


Region 2


Region 6


Region 9


42

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Semiannual Report to Congress	October 1, 2017—March 31, 2018
EPA Reports With Unimplemented Recommendations
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)
EPA Can Better Reduce Risks From
Illegal Pesticides by Effectively
Identifying Imports for Inspection and
Sampling
17-P-0412
09/28/17
OECA
1.	Establish national compliance monitoring goals
based on assessment and consideration of
available regional resources.
2.	Implement internal controls to monitor and
communicate progress on regional goals.
3.	Develop agency guidance and training for EPA
regions on how to use the Automated Commercial
Environment system for regional targeting of
importers, manufacturers and pesticide products.
4.	Direct each EPA region to develop guidance or
protocols that define how the region will coordinate
with local U.S. Customs and Border Protection
offices on illegal pesticides that are imported
without Notices of Arrival.
09/30/19
09/30/19
09/30/18
09/30/18

EPA Needs to Improve Oversight of
Its Audio Conference Services
17-P-0408
09/26/17
OEI
2. Design and implement internal controls that allow
EPA program offices and regions to monitor audio
conference activities to prevent unauthorized use
and waste.
09/30/18
$66


3. Increase the EPA's internal customer awareness
of the Working Capital Fund Policy Standard's
mandatory services requirements, and establish
controls that require EPA program offices and
regions to comply with the requirements.
09/30/18
$264
Region 2 Needs to Improve Its Internal
Processes Over Puerto Rico's
Assistance Agreements
17-P-0402
09/25/17
Region 2
1.	Train Project Officers to follow the EPA's Grants
Policy lssuance-02-02 guidance, and require that
programmatic baseline reviews include confirmation
of equipment purchases and use during the post-
award phase.
2.	Require Project Officers and Grant Management
Specialists to take specific, annual training on grant
file management.
3.	Require Project Officers to take specific, annual
training on conducting baseline monitoring reviews,
to include reviews of the EPA's financial system for
drawdown information.
09/30/18
03/31/18
09/30/18
$207


4. Determine whether the cooperative agreements
under Grant Numbers 99206921 and 99206922
have the proper support for the fringe benefit costs
requested for car allowances.
03/31/18
$10
EPA's Distribution of Superfund
Human Resources Does Not Support
Current Regional Workload
17-P-0397
09/19/17
OLEM
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.
09/30/18

43

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)


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.
03/31/18



3. Implement a national prioritization of all sites
including risk and other factors in the prioritization
and regularly distribute regional full-time equivalents
according to the national prioritization.
09/30/18



4. Obtain information from the regions necessary to
carry out Recommendations 2 and 3.
12/31/17

Management Alert: EPA Should
Promptly Reassess Community Risk
Screening Tool
17-P-0378
09/07/17
ORD
Deputy
Administrator
1.	Review the Community-Focused Exposure and
Risk Screening Tool and develop an action plan
with timeframes to address issues identified,
including considerations on whether to retain the
tool. If retained:
a.	Develop metrics for measuring the tool's
performance and establish a regular schedule for
performance evaluations.
b.	Survey users to obtain feedback on tool
utilization and any needed improvements.
2.	Develop policies and procedures for planning,
developing, implementing and monitoring the
performance of web-based research tools. Policies
and procedures could build on the draft guidance
for web-based tools developed by the National
Exposure Research Laboratory, and should ensure
that any new Office of Research and Development
research tool stems from a clear project proposal
that includes ongoing monitoring metrics and
outcome measures, and vetting to ensure there is a
need and no overlap with other tools.
3.	Review new and existing Office of Research and
Development research tools to determine the
applicability of the agency's information technology
requirements.
4.	Work with agency offices responsible for other
geospatial mapping tools to develop a decision
support matrix for when to use certain tools and for
what purposes.
5.	Examine all of the EPA's web-based risk
screening and mapping tools to ensure the need for
each tool and to avoid potential overlap, duplication
and waste.
09/30/19
09/30/18
09/30/19
09/30/19

44

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)
EPA Needs to Increase Oversight of
Leave Bank Program to Improve
Efficiency and Reduce Risk of Misuse
17-P-0374
08/28/17
OARM
1. Develop and implement official policies and
procedures to administer the Voluntary Leave Bank
Program, to include:
a.	Governing the Leave Bank Board's decision-
making, including documenting those decisions.
b.	Requiring Office of Administration and Resources
Management staff to conduct annual trend analyses
of recent years' data to assess the bank's solvency
and identify any appropriate adjustments to hours
allowed to be drawn or minimum to be contributed
by members.
c.	Rotating the Leave Bank Board members to
adequately staff the board for appropriate amounts
of time.
d.	Requiring the Office of Human Resources to
prepare and submit an annual report on program
performance and activity.
e.	Establishing adequate controls for assessing and
verifying the validity of medical certifications, to
include researching best practices and tools used
by other federal agencies.
f.	Requiring leave bank staff to annually assess,
identify and dispose of records that meet disposal
criteria.
16. Issue guidance to and train supervisors on the
leave bank and leave transfer programs and their
roles and responsibilities for approving and attesting
timesheets of employees using the leave programs.
03/15/18
06/30/18

Improved Management of the
Brownfields Revolving Loan Fund
Program Is Required to Maximize
Cleanups
17-P-0368
08/23/17
OLEM
1.	Develop a policy to reduce balances of available
program income of Brownfields Revolving Loan
Funds being held by recipients. The policy should
establish a timeframe for recipients to use or return
the funds to the EPA.
2.	Develop a policy to require a recipient's
balance(s) of Brownfields Revolving Loan Fund
program income be used before awarding additional
funds, as required by regulation.
05/31/18
$10,900


3. Create a policy to require any new amendments
to cooperative agreements include the term and
condition to deposit program income into an
interest-bearing account.
05/31/18
$77


4. Develop a policy to require any new closeout
agreements include the term and condition to
deposit program income into an interest-bearing
account.
05/31/18



5. Develop a plan and implement a policy that
requires all recipients to maintain program income
and requires revolving loan funds to be maintained
in interest-bearing accounts.
05/31/18

45

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)


6. Develop a policy to require any new closeout
agreements to include a program income definition
that is consistent with the Revolving Loan Fund
Grant Program Administrative Manual.
05/31/18



7. Develop and implement a policy that provides an
explicit definition of program income for regions to
distribute to existing recipients.
05/31/18



8. Develop and implement required training for all
regional Brownfields Revolving Loan Fund staff.
Have the training include all program policy and
guidance relating to maintaining a Brownfields
Revolving Loan Fund after the cooperative
agreement is closed if program income exists.
09/30/18



9. Track staff completion of required training.
09/30/18



10. Require any new closeout agreement to include
a standard term and condition describing the
requirements that need to be met to terminate the
agreement, and discontinue the agreed-to, post-
closeout Brownfields Revolving Loan Fund
activities.
05/31/18



11. Develop and implement a methodology that will
align recipients with the same termination terms and
conditions.
09/30/18



12. Provide an explicit definition of "expenditure" for
EPA regions to distribute to recipients.
12/31/17



13. Require regional project officers, through a
policy, to be assigned and maintain information on
all closed cooperative agreements with pre- and
post-program income.
05/31/18



14. Develop and implement a method for the Office
of Brownfields and Land Revitalization to track
closed cooperative agreements with pre- and post-
program income.
09/30/18



15. Develop a policy to require terms and conditions
in the cooperative agreement and/or the closeout
agreement to require all recipients to report
program income.
05/31/18



16. Create a method for the Office of Brownfields
and Land Revitalization, and EPA regional
managers, to track compliance with reporting
requirements for closed cooperative agreements.
06/30/18

46

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)


17. Train regional Brownfields Revolving Loan Fund
project officers and managers on the Office of
Grants and Debarment's Assistance Agreement
Almanac, Chapter 4.5, titled "Compliance and
Performance Issues," to include the roles and
responsibilities of the project officer and instruction
on enforcement actions available to the EPA if a
recipient does not comply.
09/30/18


Region 1
20.	Question unsupported use of $1,983,198 in
EPA Brownfields Revolving Loan Fund program
income reported by Bridgeport, Connecticut, and
recover remaining program income.
21.	Place Bridgeport, Connecticut, on a
reimbursement basis for all EPA grants and
agreements.
06/30/18
12/31/17
$1,983


22. Question unsupported use of an estimated
$608,712 in EPA Brownfields Revolving Loan
Funds by the Rhode Island Economic Development
Corporation and recover remaining program
income.
06/30/18
$609


23. Place the Rhode Island Economic Development
Corporation on a reimbursement basis for all EPA
grants and agreements.
12/31/17

EPA's Voluntary WaterSense Program
Demonstrated Success
17-P-0352
08/01/17
OW
1.	Share WaterSense program practices in program
design, implementation and reporting with the
agency's Program Management Improvement
Officer.
2.	Evaluate the appropriateness of adopting water
savings as a program measure for WaterSense in
the EPA's fiscal year 2019 National Program
Guidance for the Office of Water.
3.	Develop and implement controls for WaterSense
partners to periodically reconfirm their commitment
to the program.
4.	Revise annual WaterSense program partner
reporting to incorporate the following: b. If the
program continues, improve the rate of reporting for
all partners.
09/30/18
09/30/17
09/30/17
03/31/18

EPA Needs to Institutionalize Its
"Lean" Program to Reap Cost and
Time Benefits
17-P-0346
07/31/17
OP
1.	Implement a strategy for institutionalizing the
Lean Government Initiative within the agency by
integrating the application of Lean practices and
business process improvement approaches.
2.	Develop policies that specify how to plan, design,
oversee and implement Lean practices within the
agency.
3.	Develop a process for monitoring, tracking and
measuring quantifiable results, including cost
savings, for Lean projects.
06/30/18
06/30/18
01/31/18

47

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)


4.	Develop a process for a) vetting projects that
have the potential for standardized implementation
across the agency and b) collaborating on projects
to maximize the application of Lean, as well as
sharing experiences and lessons learned
agencywide.
5.	Develop and implement a consistent and
standardized Lean training effort for the EPA's staff.
06/30/18
06/30/18

EPA Should Assess Needs and
Implement Management Controls to
Ensure Effective Incorporation of
Chemical Safety Research Products
17-P-0294
06/23/17
OCSPP
1.	Conduct a needs assessment that identifies and
addresses the challenges, timeframes, training and
resources necessary to effectively incorporate
Office of Research and Development products into
Office of Chemical Safety and Pollution Prevention
programs.
2.	Develop and implement management controls
that formalize the Office of Chemical Safety and
Pollution Prevention's processes for collaborating
with the Office of Research and Development to
maintain current products and develop future
products.
05/31/18
05/31/18

EPA Can Strengthen Its Oversight of
Herbicide Resistance With Better
Management Controls
17-P-0278
06/21/17
OCSPP
1.	Consider requiring mechanisms of action be
included on relevant herbicide labels.
2.	Determine whether synergistic effects data
should be required for the pesticide registration
process and document the results of that
determination.
3.	Improve data collection and reporting by
developing an efficient system for the agency to
collect and share herbicide resistance data using a
standardized reporting format.
4.	Determine what performance metrics are suitable
to document the progress of the EPA's actions
related to slowing herbicide resistance.
5.	Establish a procedure to increase communication
with government agencies, industry, academia,
growers and other stakeholders regarding herbicide
resistance. The procedure should include specific
details concerning increased communication and
collaboration with extension agents.
06/30/19
06/30/19
03/31/18
09/30/18
03/31/18

Improved Data and EPA Oversight Are
Needed to Assure Compliance With
the Standards for Benzene Content in
Gasoline
17-P-0249
06/08/17
OAR
1. Improve controls over the reporting system to
assure facility submitted data are of the quality
needed to assess compliance with the regulations.
These controls should provide reasonable
assurance that the following occurs:
a.	Volumes and average benzene concentrations in
facilities' annual benzene reports match those
calculated based on their batch reports.
b.	Benzene concentrations in facility batch reports
and annual benzene reports contain two decimal
places.


48

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)


c.	Production dates match the compliance year in
facility reports.
d.	Facilities use only valid product codes in their
reports.
e.	Only valid company and facility identification
numbers are used.
f.	Maximum average benzene concentrations for the
second compliance period and beyond match the
corresponding annual average benzene
concentrations.
g.	Import companies aggregate their facilities and
submit just one annual benzene report.
h.	All required reports are submitted.




2. Consult with the Office of Enforcement and
Compliance Assurance to determine whether
additional reporting controls are needed to enable
enforcement staff to more efficiently conduct
compliance assurance activities. Document the
decisions made.
06/30/18



3. Revise the benzene regulations to require that
attest engagements verify annual average benzene
concentrations and volumes with batch reports, to
ensure that credits needed or generated are
correct.
09/30/20



6. Ensure the integrity of benzene credit trading by
developing and implementing a process to verify the
annual average benzene concentration and total
volume values that facilities input into the trading
database are supported by batch reports.




9. Revise the annual benzene report so that
facilities must report the number of benzene deficits
or credits at the end of the current reporting year.
09/30/20

Over $774 Million of Puerto Rico State
Revolving Funds at Risk
17-P-0186
04/26/17
Region 2
1. Evaluate options to restore the viability of Puerto
Rico's Clean Water State Revolving Fund and
Drinking Water State Revolving Fund or implement
new strategies better suited to the financial,
programmatic, public health and environmental
needs of the government of Puerto Rico.

$774,000
EPA Needs to Provide Leadership and
Better Guidance to Improve Fish
Advisory Risk Communications
17-P-0174
04/12/17
OW
1.	Provide updated guidance to states and tribes on
clear and effective risk communication methods for
fish advisories, especially for high-risk groups. This
guidance could recommend posting fish advisory
information at locations where fish are caught and
using up-to-date communication methods that
include social media, webinars, emails, newsletters,
etc.
2.	Working with states and tribes, develop and
disseminate best practices they can use to evaluate
the effectiveness of fish advisories in providing risk
information to subpopulations, such as subsistence
fishers, tribes and other high fish-consuming groups.
Draft 09/30/18
Final 03/31/20
Draft 09/30/18
Final 03/30/20

49

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)

ORD
3.	Develop and implement methods to ensure that
tribal members receive current fish advisory
information.
4.	Conduct an assessment for methylmercury to
determine whether the reference dose requires
updating, as indicated by the Integrated Risk
Information System, and as proposed in the
system's 2012 and 2015 agendas.
09/30/18
12/31/18

Fraud Controls for EPA's Contract
Laboratory Program Are Adequate, but
Can Be Strengthened With Formal
Risk Assessment and Investigative
Information Sharing
17-P-0119
03/06/17
OECA
2. Require the Criminal Investigation Division to
share pertinent information from laboratory fraud
findings with relevant EPA program and regional
offices. Pertinent information includes the fraudulent
method or technique used to commit fraud.
06/30/18

Backlog of Leaking Underground
Storage Tank Cleanups in Indian
Country Has Been Reduced, but EPA
Needs to Demonstrate Compliance
With Requirements
17-P-0118
03/06/17
OLEM
2.	Once a process and criteria for prioritizing are
documented, develop a tool or mechanism to track
each Leaking Underground Storage Tank site in
Indian Country according to the EPA's prioritization
criteria.
3.	If EPA determines that it is not feasible or
affordable to use the database for this purpose, the
EPA will develop an alternative method to track the
funding decisions for Leaking Underground Storage
Tank Trust-funded sites.
09/30/18
09/30/18

Congressionally Requested Audit: EPA
Needs to Improve Processes for
Preserving Text Messages as Federal
Records
17-P-0062
12/21/16
OEI
5.	Develop a plan to replace any phones not
technically compatible with the new mobile device
management solution identified during market
research in response to Recommendation 6. Also,
develop a process to approve waivers for any office
that identifies a significant business need to keep
the existing device and identifies an alternative
solution for records management for that existing
device.
6.	Formalize a plan with milestone dates to conduct
market research to determine whether an enterprise
mobile device management solution can manage
text message communications to help the agency
meet its record-keeping responsibilities. Document
a management decision if a new solution is
appropriate for the implementation and, if needed,
create a project plan with milestone dates for
implementing the new solution.
09/30/18
09/30/18

Additional Measures Can Be Taken to
Prevent Deaths and Serious Injuries
from Residential Fumigations
17-P-0053
12/12/16
OCSPP
2. Provide label language that clearly defines the
criteria for meeting the applicator stewardship
training requirement, including the frequency of
training.
05/31/18

EPA's Fiscal Years 2016 and 2015
Consolidated Financial Statements
17-F-0046
11/15/16
OCFO
2. Modify the accounting model in Compass
Financials to properly record all special account
receivables and collections as unearned revenue,
and reduce the unearned revenue and recognize
earned revenue as expenses are incurred.
09/28/18

50

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)


3. Prepare a comprehensive quarterly reconciliation
of Superfund special accounts general ledger
balances to the special accounts database detail.
09/28/18



9. Work with the Compass Financials service
provider to establish controls for creating and
locking administrative accounts.
09/30/21



10. Work with the Compass Financials service
provider to develop and implement a methodology
to monitor accounts with administrative capabilities.
09/30/21

Management Alert: Drinking Water
Contamination in Flint, Michigan,
Demonstrates a Need to Clarify EPA
Authority to Issue Emergency Orders
to Protect the Public
17-P-0004
10/20/16
OECA
1.	Update the Final Guidance on Emergency
Authority under Section 1431 of the Safe Drinking
Water Act (1991) to:
a.	Include the most relevant examples of Safe
Drinking Water Action Section 1431 orders
nationwide and examples of state actions that
would be considered timely and protective.
b.	Reflect the current delegations of authority to
both the Regional Administrators and the Assistant
Administrator for Enforcement and Compliance
Assurance.
c.	Establish checklists for when both the Regional
Administrators and the Assistant Administrator for
Enforcement and Compliance Assurance should
consider emergency action under the Safe Drinking
Water Act Section 1431.
2.	Train, in cooperation with the Assistant
Administrator for Water, all relevant EPA drinking
water and water enforcement program management
and staff on the Safe Drinking Water Act Section
1431 authority and updated guidance.
05/30/18
05/30/18

Religious Compensatory Time Is
Subject to Abuse
16-P-0333
09/27/16
OCFO
4. Modify the EPA's payroll and time and
attendance system to include the enhanced internal
controls, preventing employees from accumulating
Religious Compensatory Time hours inconsistent
with revised policies and procedures.
09/30/18

EPA Needs a Risk-Based Strategy to
Assure Continued Effectiveness of
Hospital-Level Disinfectants
16-P-0316
09/19/16
OCSPP
2. Develop a risk-based antimicrobial testing
strategy to assure the effectiveness of public health
pesticides used in hospital settings once products
are in the marketplace. At a minimum, the strategy
should:
a.	Include a framework for periodic testing to assure
products continue to be effective after resignation.
b.	Define a program scope that is flexible and
responsive to current and relevant public health
risks.
c.	Identify risk factors for selecting products to test.
d.	Identity the method to be used for obtaining
samples for testing.
e.	Designate a date to commence risk-based
post-registration testing.
11/30/18

51

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)
EPA Regional Offices Need to More
Consistently Conduct Required Annual
Reviews of Clean Water State
Revolving Funds
16-P-0222
07/07/16
OW
8. Evaluate regional approaches to conducting the
annual reviews of Clean Water State Revolving
Fund programs and address issues to ensure
regions perform consistent reviews in accordance
with the annual review guidance.
09/30/16

Hawaii Department of Health Needs to
Reduce Open Grants and Unspent
Funds
16-P-0218
06/28/16
Region 9
1. Re-evaluate the status of the fundable projects
and the Hawaii Department of Health's progress on
implementing the corrective action plan items prior
to awarding the FY 2016 allotment of $8,312,000
and any future award. The re-evaluation should
continue until the Hawaii Department of Health
meets the agency's funding utilization target.
07/31/17
$8,312
EPA Region 9 Needs to Improve
Oversight Over Guam's Consolidated
Cooperative Agreements
16-P-0166
05/09/16
Region 9
2.	Verify the program income received by the Guam
Legislature for Guam Environmental Protection
Agency-generated activities from 2010 to when the
Guam Legislature relinquishes control. Take
appropriate action to recover program income
funding still controlled by the Guam Legislature up
to $2,015,719.
3.	For the period from FY 2010 to when the Guam
Legislature relinquishes control, obtain and review
detailed Guam Environmental Protection Agency
transactions for program income receipts and
expenditures for all program income funds to verify
expenditures are allowable costs per 40 CFR Part
31, and take appropriate action to recover
unallowable costs.
04/30/18
09/30/17
$2,015
EPA Needs to Assess Environmental
and Economic Benefits of Completed
Clean Water State Revolving Fund
Green Projects
16-P-0162
05/02/16
OW
2.	Implement a process (through a grant
requirement or otherwise) for routine collection of
Green Project Reserve benefits of completed
projects as part of the EPA's regular oversight of
state programs.
3.	Report collected environmental and economic
benefits information to the public, in collaboration
with states and Green Project Reserve loan
recipients, and determine how Green Project
Reserve funds could be efficiently used in
accordance with Government Performance and
Results Act standards for measuring program
performance.
03/31/18
09/30/18

EPA Has Not Met Statutory
Requirements for Hazardous Waste
Treatment, Storage and Disposal
Facility Inspections, but Inspection
Rates Are High
16-P-0104
03/11/16
OECA
1. Implement management controls to complete the
required Treatment, Storage and Disposal Facility
inspections.
CA-1: Formalize existing process for prioritizing
Research Conservation and Recovery Act
Treatment, Storage and Disposal Facility
inspections based on the risks posed to human
health and the environment.
CA-2: Revise Office of Enforcement and
Compliance Assurance policies and procedures
to clarify those facilities that properly fall within
the definition of a Treatment, Storage and
Disposal Facility.
06/29/18
09/28/18

52

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)


CA-3: Strategically prioritize inspections,
addressing hazardous waste management
facilities that present the greatest concerns. The
EPA will approach the Office of Management and
Budget about whether a clarification to the statute
is appropriate or necessary.
08/28/18

EPA Can Strengthen Its Reviews of
Small Particle Monitoring in Region 6
to Better Ensure Effectiveness of Air
Monitoring Network
16-P-0079
12/17/15
OAR
3. Develop a process for ensuring that state and
local monitoring agencies are provided with updated
data analysis tools for future network assessments.
09/30/18

EPA Needs to Improve the
Recognition and Administration of
Cloud Services for the Office of
Water's Permit Management Oversight
System
15-P-0295
09/24/15
OW
4. Develop and implement an approved system
authorization package (i.e., a risk assessment,
System Security Plan and Authorization to Operate)
and perform annual security assessments for the
Permit Management Oversight System application.
05/31/16

Incomplete Contractor Systems
Inventory and a Lack of Oversight
Limit EPA's Ability to Facilitate IT
Governance
15-P-0290
09/21/15
OEI
5. Implement the recommendation of the EPA's
Information Security Task Force to manage the
vulnerability management program.
09/30/18

EPA's Oversight of State Pesticide
Inspections Needs Improvement to
Better Ensure Safeguards for Workers,
Public and Environment Are Enforced
15-P-0156
05/15/15
OECA
2. Ensure that required Federal Insecticide,
Fungicide, and Rodenticide Act project officer
training is conducted periodically and the above
guidance is included in the training.
CA-4: Convert 3-day training content to
E-learning module to post online and make
available to Federal Insecticide, Fungicide, and
Rodenticide Act project officers.
12/30/18

Conditions in the U.S. Virgin Islands
Warrant EPA Withdrawing Approval
and Taking Over Management of
Some Environmental Programs and
Improving Oversight of Others
15-P-0137
04/17/15
Region 2
13. To improve oversight of the Underground
Storage Tank/Leaking Underground Storage Tank
program, establish an updated Underground
Storage Tank/Leaking Underground Storage Tank
Memorandum of Agreement with the U.S. Virgin
Islands that reflects changes and new provisions
results from the Energy Policy Act of 2005. The
memorandum of agreement should also outline
roles, responsibilities and expectations.
09/30/18



18. Develop a plan to address currently
uncompleted tasks and activities, and develop a
schedule for reprogramming grant funds to
accomplish these tasks if the U.S. Virgin Islands
does not or cannot complete them. Upon
completion of the financial management corrective
actions, follow the Office of the Chief Financial
Officer's Resource Management Directive System
2520-03 to determine whether any of the current
unspent funds of approximately $37 million under
the U.S. Virgin Islands' assistance agreements
could be put to better use.
09/30/18
$37.0
53

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)
Audit of EPA's Fiscal Years 2014 and
2013 (Restated) Consolidated
Financial Statements
15-1-0021
11/17/14
OCFO
5.	Improve and maintain support for how EPA lab
renovation projects are funded.
6.	Review funding sources of all current and future
lab renovations to ensure correct funding is utilized.
7.	Develop policies and procedures for capital
improvements/betterments to real property,
specifically, to address EPA lab renovations which
could bulk purchases of equipment and funding
from agency program appropriations other than the
Buildings & Facility appropriation.
07/31/18
07/31/18
07/31/18

Nutrient Pollution: EPA Needs to Work
with States to Develop Strategies for
Monitoring the Impact of State
Activities on the Gulf of Mexico
Hypoxic Zone
14-P-0348
09/03/14
OW
1. Work with the state and federal Task Force
members in the Mississippi River Watershed to
develop and enhance monitoring and assessment
systems that will track the environmental results of
state nutrient reduction activities, including their
contribution to reducing the size of the Gulf of
Mexico hypoxic zone.
06/01/17

Cloud Oversight Resulted in
Unsubstantiated and Missed
Opportunities for Savings, Unused and
Undelivered Services, and Incomplete
Policies
14-P-0332
07/24/14
OEI
4. Prior to entering into any future Infrastructure-as-
a-Service contracts, perform a formal documented
analysis to determine whether such contracts are in
the EPA's best interest that includes the
investments the EPA would have to make to
address integration requirements, obstacles and
gaps identified as a result of the current
I nfrastructure-as-a-Service contract.
10/16/17

Internal Controls Needed to Control
Costs of Emergency and Rapid
Response Services Contracts, as
Exemplified in Region 6
14-P-0109
02/04/14
Region 6
3. Direct Contracting Officers to require that the
contractor adjust all its billings to reflect the
application of the correct rate to team subcontract
Other Direct Costs.
09/30/24

EPA Did Not Conduct Thorough
Biennial User Fee Reviews
14-P-0129
03/04/14
OW
5. Apply federal user fee policy in determining
whether to (a) charge fees for issuing federal
National Pollutant Discharge Elimination System
permits in which the EPA is the permitting authority,
or (b) request an exception from the Office of
Management and Budget to charging fees.
10/01/17
$17.8
Air Quality Objectives for the Baton
Rouge Ozone Nonattainment Area
Not Met Under EPA Agreement
2A-96694301 Awarded to the
Railroad Research Foundation
13-R-0297
06/20/13
Region 6
1. Recover federal funds of $2,904,578 unless the
foundation provides a verifiable and enforceable
remedy to reduce diesel emissions in the Baton
Rouge ozone nonattainment area, as required by
the cooperative agreement.
CA2: Two of the five rebuilt locomotives will
continue to operate in the Baton Rouge
nonattainment area.
CA3: The remaining three rebuilt locomotives will
continue to operate in Baton Rouge and New
Orleans until economic conditions in Baton Rouge
necessitate moving as many locomotives as
possible back to the Baton Rouge non-attainment
area.
09/30/20
09/30/20
$2,905
54

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)


CA5: Railroad Research Foundation will provide
locomotive location data to the EPA on a
quarterly basis showing where the five
locomotives were operated.
09/30/20



CA6: As a penalty for noncompliance, the
Railroad Research Foundation will remit to the
EPA $4,841 for each locomotive for each month
any of the five locomotives are operated outside
of the restricted area for more than 10-plus
consecutive days outside the Baton Rouge non-
attainment area and the exception area (for other
than maintenance).
09/30/20



CA7: Each of the five locomotives will operate in
the Baton Rouge area or the exception area for
10 years after the date each engine was placed
back into service.
09/30/20

Improvements Needed in EPA Training
and Oversight for Risk Management
Program Inspections
13-P-0178
03/21/13
OLEM
7.	Coordinate with the Assistant Administrator for
Enforcement and Compliance Assurance to revise
inspection guidance to recommend minimum
inspection scope for the various types of facilities
covered under the program and provide detailed
examples of minimum reporting.
8.	Coordinate with the Assistant Administrator for
Enforcement and Compliance Assurance to develop
and implement an inspection monitoring and
oversight program to better manage and assess the
quality of program inspections, reports, supervisory
oversight and compliance with inspection guidance.
02/28/19
02/28/20

EPA Needs to Improve Air Emissions
Data for the Oil and Natural Gas
Production Sector
13-P-0161
02/20/13
OAR
2. Prioritize and update existing oil and gas
production emission factors that are in greatest
need of improvement and develop new emission
factors for key oil and gas production processes
that do not currently have emission factors.
CA2.3 - The EPA will revise the Electronic
Reporting Tool to accommodate those
non-traditional measurement techniques identified
in the cross-office strategy and fully developed by
the 4th quarter of FY 2017.
CA2.4 - The EPA will set forth procedures for
developing emissions factors based on data
collected with non-traditional measurement
techniques and incorporate those procedures into
the Web Information Retrieval System
(WebFIRE).
9/30/18
9/30/19

Review of Hotline Complaint
Concerning Cost and Benefit
Estimates for EPA's Lead-Based Paint
Rule
12-P-0600
07/25/12
OCSPP
1. Consistent with a retrospective and flexible EPA
regulatory culture, re-examine the estimated costs
and benefits of the 2008 Lead Rule and the 2010
amendment to determine whether the rule should
be modified, streamlined, expanded or repealed.


55

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)


CA1-3: Draft information and analysis submitted
to OMB for interagency review as part of the
Action Development Process.
CA1-4: Work practice and cost information is
published as part of proposed rule.
3/31/15
9/30/15

Controls Over State Underground
Storage Tank Inspection Programs in
EPA Regions Generally Effective
12-P-0289
02/15/12
OLEM
1. Require the EPA and states to enter into
memorandums of agreement that reflect program
changes from the 2005 Energy Policy Act and
address oversight of municipalities conducting
inspections.
10/13/18

EPA Needs to Further Improve How It
Manages Its Oil Pollution Prevention
Program
12-P-0253
02/06/12
OLEM
1. Improve oversight of facilities regulated by the
EPA's oil pollution prevention program by:
d. Producing a biennial public assessment of the
quality and consistency of Spill Prevention,
Control, Countermeasure Plans and Facility
Response Plans based on inspected facilities.
CA1 -2: A summary of findings will be developed
by October 2013. These findings will help to
identify areas where additional guidance and
outreach are needed to improve the quality and
consistency of Spill Prevention, Control,
Countermeasure Plans.
CA1-3: The model developed for the Spill
Prevention, Control, Countermeasure program
will then be used to develop a review protocol for
Facility Response Plan by September 2013 to
examine Facility Response Plan inspections
conducted during the FY 2013 inspection cycle.
CA1 -4: A summary of findings will be developed
by October 2014. These findings will help to
identify areas where additional guidance and
external outreach are needed to improve the
quality and consistency of Facility Response
Plans.
06/30/20
06/30/20
06/30/20
06/30/20

EPA Should Update Its Fees Rule to
Recover More Motor Vehicle and
Engine Compliance Program Costs
11-P-0701
09/23/11
OAR
1. Update the 2004 fees rule to increase the amount
of Motor Vehicle and Engine Compliance Program
costs it can recover.
12/31/18
$13,000
EPA Should Revise Outdated or
Inconsistent EPA-State Clean Water
Memoranda of Agreement
10-P-0224
09/14/10
OECA
2-2. Develop a systematic approach to identify
which states have outdated or inconsistent
memorandums of agreements; renegotiate and
update those Memorandums of Agreements using
the Memorandum of Agreements template; and
secure the active involvement and final,
documented concurrence of headquarters to ensure
national consistency.
09/28/18

56

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
EPA Needs a Coordinated Plan to
Oversee Its Toxic Substances Control
Act Responsibilities
10-P-0066
02/17/10
OCSPP
2-4 Establish criteria and procedures outlining what
chemical or classes of chemicals will undergo risk
assessments for low-level and cumulative
exposure. Periodically, update and revise risk
assessment tools and models with the latest
research and technology developments.
12/31/17

Audit of EPA's Fiscal 2009 and 2008
(Restated) Consolidated Financial
Statements
10-1-0029
11/16/09
OCFO
27. Ensure that all new financial management
systems (including the Integrated Financial
Management System replacement system) and
those undergoing upgrades include a system
requirement that the fielded system include an
automated control to enforce separation of duties.
CA27.9 - The Office of Technology Solutions will
modify Compass user profiles to create specific
security roles to allow Compass Security Officers
to better manage user access.
CA27.10 - The Office of Technology Solutions will
enhance the Access Request Form application to
add additional controls and automatic logic to
check for approved waivers on file to prevent
users from submitting security options that violate
the separation of duties policy.
12/31/18
12/31/18

Making Better Use of Stringfellow
Superfund Special Accounts
08-P-0196
07/09/08
Region 9
2. Reclassify or transfer to the Trust Fund, as
appropriate, $27.8 million (plus any earned interest
less oversight costs) of the Stringfellow special
accounts in annual reviews, and at other milestones
including the end of Fiscal Year 2010, when the
record of decision is signed and the final settlement
is achieved.
12/31/12
$27,800
Total



$859,985
57

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Semiannual Report to Congress	October 1, 2017—March 31, 2018
CSB Reports With Unimplemented Recommendations
Report Title/No./Date
Office
Unimplemented Recommendation
Planned
Completion
Date
Potential
Monetary
Benefits
Recommended
(in $000s)
CSB Needs to Continue to Improve
Agency Governance and Operations
16-P-0179
05/23/16
CSB
6. Include the General Services Administration in
any future office leasing plans and revisit office
needs for a potential adjustment or supplement to
the Washington, D.C., and Denver office leases to
reduce space within the General Services
Administration benchmarks.
D.C.
10/20/22
Denver
11/30/19
$0,402
Total



$0,402
58

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Appendix 4—Closed Investigations Not Publicly Disclosed
For Reporting Period Ended March 31, 2018
Section 5(a)(19) of the Inspector General Act of 1978, as amended, requires detailed descriptions of each
investigation involving a senior government employee (at least at the GS-15 level) where allegations of
misconduct were substantiated. Section 5(a)(22) requires detailed descriptions of each investigation
conducted by the OIG involving a senior government employee that was closed and not disclosed to the
public, and detailed descriptions of the particular circumstances of each inspection, evaluation and audit
conducted by the OIG that was closed and not publicly disclosed.
Details on each investigation conducted by the OIG involving both senior and non-senior employees closed
during the semiannual reporting period ending March 31, 2018, are provided below. We also include a
separate listing of investigations conducted by the OIG and closed during the semiannual reporting period
involving non-employees such as grant recipients, contractors and former EPA employees.
Investigations Involving Presidential Appointees Not Publicly Disclosed
There were no closed investigations involving presidential appointees during this semiannual reporting period.
Investigations Involving Senior Employees Not Publicly Disclosed
CASE NUMBER: QI-HQ-2016-ADM-0012
An EPA GS-15 Special Agent in Charge in the EPA's Criminal Investigation Division allegedly engaged in
inappropriate conduct toward another EPA employee and was under the influence of alcohol while on duty.
The employees provided conflicting accounts of what happened. The allegations were not supported.
CASE NUMBER: QI-HQ-2015-ADM-0113
An EPA GS-15 Special Agent in Charge in the EPA's Criminal Investigation Division allegedly used an EPA
laptop to access pornographic internet sites. A forensic analysis of the laptop yielded images of suspected child
pornography. An outside entity examined the images and revealed it could not be determined with medical
certainty that the people depicted in the images were under 18. The employee retired from the EPA during the
investigation. No administrative action was taken.
CASE NUMBER: QI-HQ-2015-ADM-0133
An EPA GS-15 employee allegedly engaged in time-and-attendance fraud, provided an EPA username and
password to a subordinate employee, and retaliated against a subordinate employee. EPA management and
the EPA's Office of Human Resources, Labor and Employee Relations Division, addressed the allegation of
retaliation. The allegation of time-and-attendance fraud was not supported. The allegation involving the
username and password was supported. The GS-15 employee's action was a violation of EPA information
technology security procedures. EPA management issued a letter of reprimand to the employee.
CASE NUMBER: QI-HQ-2017-ADM-0083
An EPA GS-15 employee allegedly failed to monitor the EPA's Office of Civil Rights Title VI email account,
representing misconduct. The investigation supported the allegation, finding that the employee did not monitor
the email account for approximately 1 year. EPA management issued a letter of counseling to the employee.
CASE NUMBER: QI-HQ-2016-ADM-0075
Management officials in the EPA's Office of Civil Rights External Compliance and Complaints Program
(established under Title VI of the Civil Rights Act of 1964) allegedly were involved in misconduct and
mismanagement of the office's email account. The investigation supported the allegations, finding that
management officials did not monitor the Title VI email account for approximately 1 year, and failed to comply
with regulation by not acknowledging email complaints within 5 days of receipt. The investigation also supported
an allegation that the Office of Civil Rights issued an acknowledgment letter to a complainant over a year after
59

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Semiannual Report to Congress
October 1, 2017—March 31, 2018
the complainant had sent an email to the Office of Civil Rights Title VI email account. Case number OI-HQ-
2017-ADM-0083 is related. Another related OIG investigation, involving a Senior Executive Service-level
employee, was reported in the OIG's November 2017 Semiannual Report to Congress.
CASE NUMBER: QI-SE-2015-ADM-0051
An EPA GS-15 employee allegedly failed to file Confidential Financial Disclosure Report forms since 2008,
drank alcohol at work and misused authority as a government purchase card approving official. The
investigation did not support the allegations.
CASE NUMBER: QI-HQ-2017-ADM-0066
An EPA GS-15 employee allegedly was converted from an administratively determined position to a permanent
position without following applicable Office of Personnel Management and EPA policies. The investigation
determined that the employee filed the proper paperwork and followed the appropriate procedures to gain the
permanent position. The allegation was not supported.
Investigations Involving Non-Senior Employees Not Publicly Disclosed
CASE NUMBER: QI-HQ-2017-ADM-0092
An EPA GS-14 employee allegedly resided in and teleworked from another state while claiming a Washington,
D.C., area address on official telework and medical telework agreements, and while collecting Washington,
D.C., locality pay. The allegations were supported. The employee resigned before administrative action could
be taken.
CASE NUMBER: OI-RTP-2018-QTH-0002
An EPA GS-14 employee lost an EPA laptop while on personal travel. All indications were that the laptop was
stolen from an airport waiting area. Airport security cameras were unable to detect the theft. There was no
evidence indicating the EPA employee intentionally caused the loss.
CASE NUMBER: QI-SA-2017-ADM-0139
An EPA GS-14 employee allegedly did not exercise due diligence in the authorization and approval of a
subordinate employee's timecards. The investigation supported the allegation. EPA management issued the
employee a warning letter for negligent performance of duties.
CASE NUMBER: QI-CH-2017-THT-0137
An EPA GS-13 employee made statements to another EPA employee indicating that the GS-13 employee was
contemplating suicide. An investigation was conducted to determine whether the GS-13 employee posed a
threat to other EPA employees. The investigation determined there was no credible threat against other EPA
employees.
CASE NUMBER: QI-HQ-2015-ADM-0064
An EPA GS-13 employee allegedly committed travel fraud by taking unnecessary business trips to Asia. The
investigation revealed that all of the international trips taken by the employee were in support of the EPA's
mission in the Guangdong Agricultural Pollution Control Project in the People's Republic of China, the Global
Methane Initiative in Indonesia, and other countries in Asia and Europe. The investigation did not support the
allegation.
CASE NUMBER: OI-BQ-2016-ADM-0110
An EPA GS-13 employee allegedly viewed pornographic material on the EPA network while on duty.
Investigative activities that included an interview with the employee and a forensic examination of the
employee's work computer supported the allegation. EPA management initiated a "last chance" agreement with
the employee and took additional action that included a demotion in pay grade, a 4-week suspension, moving
the employee's workspace to a more public and heavily traveled area, and requiring the employee to complete
information technology security and ethics training.
CASE NUMBER: QI-NE-2014-ADM-0039
An EPA GS-13 employee allegedly returned to a previous EPA work location and destroyed official agency
records. The investigation determined that the employee made a request through management to return to the
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
prior work location to retrieve personal items; however, the investigation was unable to determine whether the
employee had destroyed any official agency records. The allegation was not supported.
CASE NUMBER: QI-HQ-2015-ADM-0115
An EPA GS-13 Special Agent in the EPA's Criminal Investigation Division allegedly engaged in inappropriate
conduct with a subject under investigation. The investigation supported the allegation. EPA management issued
the employee a 14-day suspension, which the employee served.
CASE NUMBER: QI-PH-2017-CAC-0086
An EPA GS-13 employee allegedly caused a possible breach of personally identifiable information by backing
up information from an EPA laptop to a personally owned device. The investigation did not support the
allegation.
CASE NUMBER: QI-HQ-2017-ADM-0104
An EPA GS-13 employee allegedly allowed contractors to include commute times for the hours they were
supposed to be on-site working at an EPA Superfund site. The investigation supported the allegation. EPA
management issued the employee a warning letter and provided the employee with additional training and
enhanced supervision. In addition, the contractors reimbursed the EPA for funds that were received but had not
been stipulated within the terms of the contract.
CASE NUMBER: QI-NE-2014-ADM-0094
An EPA GS-13 employee allegedly performed activities related to an outside position while on duty at the EPA.
The employee had been informed that no official duty time could be used in conjunction with outside
employment. Facts disclosed during the investigation supported the allegation that the employee had spent
official duty time on outside employment. The employee resigned during the course of the investigation. The
agency issued a debt letter to the employee seeking reimbursement for time owed. The employee paid the debt.
CASE NUMBER: QI-HQ-2017-ADM-0061
An EPA GS-13 employee allegedly directed a U.S. Department of Transportation employee to make false
official statements. The investigation concluded that no evidence of an administrative or criminal violation took
place. This investigation was conducted jointly with the U.S. Department of Transportation OIG.
CASE NUMBER: QI-HQ-2018-ADM-0022
An EPA GS-13 Special Agent in the EPA's Criminal Investigation Division allegedly engaged in employee
misconduct by filing false workers' compensation claims, and lost access to the use of assigned agency-issued
firearms and vehicle due to the misuse of prescription medication. The investigation did not support the
allegations.
CASE NUMBER: OI-HQ-2017-ADM-00Q4
An EPA GS-12 employee allegedly touched an EPA employee inappropriately. The GS-12 employee admitted
to touching the second employee. As a result of a previous management inquiry, EPA management relocated
the GS-12 employee to a workstation farther away from the second employee.
CASE NUMBER: QI-AT-2018-ADM-0027
An EPA GS-12 employee allegedly was arrested by local authorities on domestic violence offenses. The OIG
investigation confirmed that the employee was charged with three felony and three misdemeanor criminal
offenses related to a domestic complaint involving the employee and the employee's family. Records related to
the incident were provided to EPA management for administrative review.
CASE NUMBER: QI-HQ-2017-ADM-0091
An EPA GS-12 employee allegedly made a threatening hand gesture to an EPA manager. The subject
acknowledged that the gesture was made but stated it was not meant as a threat of violence. The allegation was
not supported.
CASE NUMBER: QI-AR-2015-ADM-0065
An EPA GS-12 employee allegedly misused a government credit card. The investigation supported the
allegation that the employee used a government travel card for personal purchases, and that the employee
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
provided false information to investigators and EPA management. A notice of proposed removal was issued to
the employee, but the employee resigned prior to removal action.
CASE NUMBER: QI-RTP-2017-ADM-0125
An EPA GS-12 employee allegedly resided in and teleworked from a state outside the Washington, D.C., area
while collecting D.C.-area locality pay. The employee allegedly failed to notify management of the move.
The allegations were supported. The employee was on full-time medical telework under a reasonable
accommodation agreement. The relocation was discovered when the employee submitted the Annual
Recertification Application for Medical FlexiPlace form, on which the employee listed the new home address.
The employee claimed to be unaware of the need to obtain prior authorization to relocate to a new area if there
was a change in the locality pay rate. EPA management issued the employee a warning letter for violation of
Office of Personnel Management guidelines regarding locality pay and failure to follow proper time-and-
attendance procedures. In addition, the wage overpayment was deducted from the employee's pay and returned
to the EPA.
CASE NUMBER: QI-HQ-2014-ADM-0019
An EPA GS-11 employee allegedly engaged in time-and-attendance fraud by improperly accounting for time
worked while in telework status. The investigation revealed that the employee was conducting personal
business while in telework status. The allegation was supported, and the employee was removed from federal
service.
CASE NUMBER: QI-HQ-2017-ADM-0116
The Office of Personnel Management issued an alert to the OIG alleging potential misconduct by an EPA GS-11
employee. The alert detailed multiple felony offenses committed by the employee, possibly during work hours.
The OIG conducted investigative actions to determine whether any of the felony offenses were conducted
during work hours or while using EPA resources. The investigation did not support an allegation of potential
misconduct.
CASE NUMBER: QI-RTP-2013-ADM-0103
An EPA GS-9 employee allegedly engaged in time-and-attendance fraud, claiming overtime that was not
worked. The investigation found that the allegation was supported. The agency terminated the employee for lack
of candor during the investigation, inaccurate reporting of time and being absent without leave. The employee
was ordered to pay $6,973 in restitution. The EPA collected the funds.
CASE NUMBER: OI-SA-2017-ADM-010Q
An EPA GS-8 employee allegedly engaged in time-and-attendance fraud, claiming time that was not worked.
The allegation was supported and the employee was terminated by the EPA.
Investigations Involving Non-Employees Not Publicly Disclosed
CASE NUMBER: OI-AT-2016-CFR-00Q4
An environmental organization that receives Clean Water Act grant funds and one of its subcontractors were
allegedly reimbursed for services not performed. In addition, the director of the organization allegedly violated
ethics rules. The investigation did not support the allegations.
CASE NUMBER: OI-RTP-2018-CFD-00Q5
A security contracting company that provides security at an EPA facility allegedly violated the terms of its
contract. Investigators reviewed the statement of work for the contract, which sets forth the requirements,
training and qualifications under the contract. The allegations were not supported.
CASE NUMBER: QI-RTP-2014-CAC-0027
A South Carolina company's handling of the cleanup of two leaking underground storage tank sites allegedly
used a cheaper, inferior product than specified in the bid solicitation. The use of this product reduced the
effectiveness of the remedial efforts and resulted in a greater expenditure to complete the cleanup. In addition,
the use of the cheaper, inferior product gave the company an unfair advantage. The cleanup projects were
supposed to be funded with American Recovery and Reinvestment Act funds, but were funded by the South
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Carolina State Underground Petroleum Environmental Response Bank. The allegation was supported, and the
owner of the company pleaded nolo contendere to obtaining signature or property by false pretenses valued at
$2,000 or less. The individual was fined $200 and suspended from the South Carolina underground storage
tank program.
CASE NUMBER: QI-CH-2017-CAC-0101
The OIG discovered a post on a social media site, directed toward the EPA Administrator, that could be
interpreted as intimidating and potentially threatening. The subject was interviewed and admitted to posting the
message, but ultimately it was determined not to be a direct threat in violation of federal or state statutes.
CASE NUMBER: QI-DA-2017-CAC-0102
The OIG was notified of a threatening email received by a U.S. Senator. The email allegedly also was a
potential threat to the lives of the EPA Administrator, the President, the Vice President and other members of
Congress. Investigators coordinated efforts with federal, state and local law enforcement agencies. The subject
was interviewed and admitted to sending the email threats. The allegations were supported, but the U.S.
Attorney declined the case for prosecution. The agency issued a notice barring the individual from entering EPA
facilities.
CASE NUMBER: QI-DE-2014-CFR-0046
An acting Tribal Environmental Director allegedly misused an EPA-funded tribal vehicle, committed timecard
fraud and submitted false documents to the EPA. Investigators determined that the director only used the
EPA-funded tribal vehicle to conduct business on tribal land and during business hours. The director was paid
one salary from separate grant funds. The investigation did not support the allegations.
CASE NUMBER: QI-SA-2017-ADM-0103
An EPA contractor allegedly misused an EPA-funded, General Services Administration-leased vehicle and its
registered highway toll tag. The investigation supported the allegation that the EPA contractor misused the EPA-
leased vehicle during work and non-work hours. The EPA contractor was terminated, and the agency was
reimbursed $4,677.50 for unauthorized mileage on the vehicle and unauthorized use of the toll tag.
CASE NUMBER: QI-SA-2017-CAC-0089
A company allegedly sold various items embossed with the EPA logo via its website. The sales were not
approved or sponsored by the EPA. The investigation supported the allegation and found that the company
allowed customers to upload symbols, seals and other images to be printed on various products, such as shirts,
bags and cups. The investigation showed the person involved with the sales was operating with an Internet
Protocol address from an overseas location. The company received approximately $3,700 in profits from the
sales. Since sales were no longer ongoing, the agency determined that the matter was resolved.
CASE NUMBER: QI-WI-2014-CAC-0031
A technician working for an EPA grantee allegedly falsified 37 laboratory samples by using an editing program
to manipulate laboratory reports. The investigation supported the allegation. The technician falsified laboratory
data for monetary gain from a third party. The individual was debarred from participating in federal procurement
and assistance activities for 3 years. The U.S. Attorney's Office declined the case for prosecution.
CASE NUMBER: QI-CH-2018-THT-0015
An individual allegedly left a threatening voicemail message directed to the EPA Administrator and EPA
employees. Investigators were not able to identify a subject, and there was no evidence of a credible threat. The
investigation was closed.
CASE NUMBER: QI-HQ-2017-CCR-0142
A General Services Administration contractor allegedly entered a locked and alarmed EPA OIG office
unescorted. The investigation revealed that there appeared to be an absence of guidance regarding contractor
access to OIG space and a lack of standardized procedure for the Federal Protective Service to respond to
activated alarms in OIG space. The investigation revealed no evidence of criminal wrongdoing.
CASE NUMBER: QI-HQ-2017-CAC-0119
An EPA laptop allegedly was stolen from an EPA employee's car. Investigators were unable to locate the laptop
or develop additional leads. The investigation was closed.
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
CASE NUMBER: OI-NE-2017-ADM-009Q
A company allegedly used the official EPA seal on video advertisements related to the marketing of a dental
waterline purification unit. The videos were posted on YouTube in various languages. Investigators reviewed the
videos and determined that the allegation was supported. The matter was referred to the agency for resolution.
CASE NUMBER: QI-AR-2016-CAC-0065
An unknown individual allegedly posed as an EPA employee and demanded cash from an elderly person for
environmental violations. The investigation supported the allegation. The elderly person was a victim of a
fraudulent scheme perpetrated by a woman who resided with the victim at the time. The subject received $300
from the victim and allegedly told the victim she had paid an EPA employee to resolve environmental violations.
However, the investigation found that the subject fabricated the EPA's involvement. The subject admitted to her
involvement in the scheme and pleaded guilty to a theft of less than $1,000. She received an 18-month jail
sentence and 5 years of supervised probation.
CASE NUMBER: QI-DA-2017-CAC-0019
A worker assigned to two EPA contracts at a private company allegedly was not working on the contracts and
was possibly no longer employed by the company. In addition, the company allegedly violated the Small
Business Innovation Research program requirements. After conducting a background investigation and
interview, the employee was found to be currently employed by the company and working on both EPA
contracts. The investigation also found that the company was not in violation of any reporting requirements set
forth by the EPA contracting officer. The investigation did not support the allegations.
CASE NUMBER: QI-HQ-2017-ADM-0131
An enrollee in the EPA's Senior Environmental Employment Program allegedly possessed a counterfeit EPA
Personnel Access and Security System identification badge. An EPA security guard seized the badge and
turned it over to the EPA's Security Management Division. Investigators determined that the badge was
counterfeit. The enrollee's participation in the program was terminated.
CASE NUMBER: QI-HQ-2017-ADM-0132
An enrollee in the EPA's Senior Environmental Employment Program allegedly possessed a counterfeit EPA
Personnel Access and Security System identification badge. An EPA security guard seized the badge and
turned it over to the EPA's Security Management Division. Investigators determined that the badge was
counterfeit. The enrollee's participation in the program was terminated.
CASE NUMBER: QI-HQ-2018-ADM-0031
Property damage to an outside window was discovered at the EPA headquarters building in Washington, D.C.
The window appeared to have been damaged by a brick and a piece of cobblestone found outside the window.
No subject was identified. The investigation was closed.
CASE NUMBER: QI-AT-2018-THT-0053
An EPA employee claimed that his wife's co-worker at a local university made threats directed at a regional EPA
office building and its occupants. The investigation determined that the complainant and the subject had never
met or communicated. The allegation was not supported.
CASE NUMBER: QI-AT-2018-THT-0054
A Tennessee homeowner threatened to kill a Tennessee Department of Environment and Conservation
employee while the employee was performing official duties. The employee was working on an EPA-delegated
program. The homeowner contacted the Tennessee Department of Environment and Conservation by telephone
after learning that it was placing a lien on his home related to unpaid fines from an environmental enforcement
action that occurred 10 years earlier. During the call, the homeowner said he had been lied to by the employee,
and he threatened the employee's life. This case was declined for prosecution by the U.S. Attorney's Office.
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Appendix 5—Peer Reviews Conducted
Audits
The Social Security Administration OIG conducted the most recent external peer review of the
EPA OIG audit organization, covering the fiscal year ended September 30, 2014, and issued a
report on June 12, 2015. The review was conducted in accordance with guidelines established by
the Council of the Inspectors General on Integrity and Efficiency. The external peer review stated
that the EPA OIG audit organization's system of quality control was suitably designed and
complied with to provide the EPA OIG with reasonable assurance of performing and reporting in
conformity with applicable professional standards in all material respects. The EPA OIG received
a rating of pass.
The U.S. Department of Defense OIG is currently conducting an external peer review of the EPA
OIG audit organization covering the fiscal year ended September 30, 2017.
The EPA OIG is currently conducting an external peer review of the audit organization of the
U.S. Department of Homeland Security OIG. The review is being conducted in accordance with
guidelines established by the Council of the Inspectors General on Integrity and Efficiency. We
are examining the audit function for the fiscal year ended September 30, 2017.
Investigations
The Federal Deposit Insurance Corporation OIG completed the most recent mandated Council of
the Inspectors General on Integrity and Efficiency quality assurance review of the EPA OIG
Office of Investigations and issued its report on December 2, 2014. The Federal Deposit
Insurance Corporation OIG identified no deficiencies and found internal safeguards and
management procedures compliant with quality standards.
The U.S. General Services Administration OIG completed a mandated Council of the Inspectors
General on Integrity and Efficiency quality assurance review of the EPA OIG Office of
Investigations in March 2018. The final report is forthcoming.
On February 24, 2017, the EPA OIG completed its report on a quality assessment review of the
U.S. Department of the Interior OIG's Office of Investigations in effect for the 1-year period
ending April 30, 2016. We found that the Department of the Interior OIG's system of internal
safeguards and management procedures for the investigative function for the period reviewed
was in compliance with the applicable quality standards.
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Semiannual Report to Congress
October 1, 2017—March 31, 2018
Appendix 6—OIG Mailing Addresses and Telephone Numbers
Headquarters
U.S. Environmental Protection Agency
Office of Inspector General
1200 Pennsylvania Ave., NW (2410T)
Washington, DC 20460
(202) 566-0847
Atlanta
U.S. Environmental Protection Agency
Office of Inspector General
61 Forsyth Street, SW
Atlanta, GA 30303
Audit/Evaluation: (404) 562-9830
Investigations: (404) 562-9857
Boston
U.S. Environmental Protection Agency
Office of Inspector General
5 Post Office Square, Suite 100 (OIG15-1)
Boston, MA 02109-3912
Audit/Evaluation: (617) 918-1470
Investigations: (617) 918-1466
Chicago
U.S. Environmental Protection Agency
Office of Inspector General
77 West Jackson Boulevard
13th Floor (IA-13J)
Chicago, IL 60604
Audit/Evaluation: (312) 353-2486
Investigations: (312) 886-7167
Cincinnati
U.S. Environmental Protection Agency
Office of Inspector General
26 West Martin Luther King Drive
Cincinnati, OH 45268-7001
Audit/Evaluation: (513) 487-2363
Investigations: (312) 353-2507
Offices
Dallas
U.S. Environmental Protection Agency
Office of Inspector General (60IG)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Audit/Evaluation: (214) 665-6621
Investigations: (214) 665-2249
Denver
U.S. Environmental Protection Agency
Office of Inspector General
1595 Wynkoop Street, 4th Floor
Denver, CO 80202
Audit/Evaluation: (303) 312-6969
Investigations: (303) 312-6868
Kansas City
U.S. Environmental Protection Agency
Office of Inspector General
11201 Renner Boulevard
Lenexa, KS 66219
Audit/Evaluation: (913) 551-7878
Investigations: (312) 886-7167
New York
U.S. Environmental Protection Agency
Office of Inspector General
290 Broadway, Suite 1520
New York, NY 10007
Audit/Evaluation: (212) 637-3049
Investigations: (212) 637-3033
Philadelphia
U.S. Environmental Protection Agency
Office of Inspector General
1650 Arch Street, 3rd Floor
Philadelphia, PA 19103-2029
Audit/Evaluation: (215) 814-5800
Investigations: (212) 637-3033
Research Triangle Park
U.S. Environmental Protection Agency
Office of Inspector General
Mail Drop N283-01
Research Triangle Park, NC 27711
Audit/Evaluation: (919) 541-2204
Investigations: (919) 541-1027
San Francisco
U.S. Environmental Protection Agency
Office of Inspector General
75 Hawthorne Street (IGA-1-2)
8th Floor
San Francisco, CA 94105
Audit/Evaluation: (415) 947-4527
Investigations: (415) 947-4507
Seattle
U.S. Environmental Protection Agency
Office of Inspector General
Mail Code OIG-173
1200 Sixth Avenue, Suite 155
M/S OIG-173
Seattle, WA 98101-3140
Audit/Evaluation: (206) 553-6906
Investigations: (206) 553-1273
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