#• A \
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PR
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
EPA's Office of
Environmental Information
Should Improve Ariel Rios
and Potomac Yard
Computer Room Security
Controls
Report No. 12-P-0879
September 26, 2012

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Report Contributors:
Rudolph M. Brevard
Michael Goode
Sabrena Stewart
Abbreviations
EPA	U.S. Environmental Protection Agency
IT	Information technology
OEI	Office of Environmental Information
OIG	Office of Inspector General
NIST	National Institute of Standards and Technology
SP	Special Publication
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail: OIG Hotline@epa.gov	write: EPA Inspector General Hotline
phone: 1-888-546-8740	1200 Pennsylvania Avenue NW
fax:	202-566-2599	Mailcode 2431T
online:
http://www.epa.gov/oiq/hotline.htm
Washington, DC 20460

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At a Glance
Why We Did This Review
The U.S. Environmental
Protection Agency (EPA) Office
of Inspector General (OIG)
conducted this audit to assess
the security posture and
in-place environmental controls
of the computer rooms in the
EPA Ariel Rios and Potomac
Yard buildings in Washington,
DC, and Arlington, Virginia,
respectively. This audit was
conducted in support of the
audit of EPA's directory service
system authentication and
authorization servers.
This report addresses the
following EPA Goal or
Cross-Cutting Strategy:
• Strengthening EPA's
workforce and capabilities.
EPA's Office of Environmental Information
Should Improve Ariel Rios and Potomac Yard
Computer Room Security Controls
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
What We Found
The security posture and in-place environmental control review of the computer
rooms in the Ariel Rios and Potomac Yard buildings revealed numerous security
and environmental control deficiencies. These control deficiencies greatly reduce
the ability of the Office of Environmental Information (OEI) to safeguard critical
information technology assets and associated data from the risk of damage
and/or loss.
Recommendations/Planned Agency Corrective Actions
We recommended in our draft report that OEI remediate physical and
environmental control deficiencies. Following the issuance of the draft report, OEI
provided a corrective action plan with milestone dates to address agreed-upon
recommendations. In its response, OEI agreed with recommendations 1 and 2,
and stated that it had completed corrective actions for recommendation 1. OEI
did not agree with recommendations 3 and 4 because it asserts that the Office of
Administration and Resources Management bears responsibility for remediation
for these recommendations. For recommendation 5, OEI did not agree because it
stated that it is already monitoring environmental variable information which
would alert it to the presence of a computer room water leakage. During the
audit, the OIG requested policies and procedures that address limiting water
damage to IT assets. OEI did not provide any documentation in response to this
request and the OIG concluded that such policies did not exist.
We consider recommendation 1 closed with agreed-upon corrective actions
complete. Recommendation 2 is open with agreed-upon corrective actions
pending. The OIG believes that OEI bears the responsibility for addressing
recommendations 3, 4, and 5 because it is responsible for managing IT assets in
the Ariel Rios and Potomac Yard computer rooms. We consider
recommendations 3, 4, and 5 unresolved with resolution efforts in progress.
The full report is at:
www.epa.qov/oiq/reports/2012/
20120926-12-P-0879.pdf

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 26, 2012
MEMORANDUM
SUBJECT: EPA's Office of Environmental Information Should Improve Ariel Rios and
Potomac Yard Computer Room Security Controls
Report No. 12-P-0879
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the
problems the OIG has identified and corrective actions the OIG recommends. This report
represents the opinion of the OIG and does not necessarily represent the final EPA position.
Final determinations on matters in this report will be made by EPA managers in accordance with
established audit resolution procedures.
Action Required
The Office of Environmental Information (OEI) agreed with recommendations land 2 and
provided corrective action plans. OEI did not agree with recommendations 3, 4, and 5. These
recommendations remain unresolved with resolution efforts in progress. Therefore, in
accordance with EPA Manual 2750, you are required to provide a written response to this report
within 90 calendar days. You should include a corrective action plan for recommendations 3, 4,
and 5, including milestone dates. Your response will be posted on the OIG's public website,
along with our memorandum commenting on your response. Your response should be provided
as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the
Rehabilitation Act of 1973, as amended. The final response should not contain data that you do
not want to be released to the public; if your response contains such data, you should identify the
data for redaction or removal. We have no objections to the further release of this report to the
public. We will post this report to our website at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Rudolph M. Brevard,
Director, Information Resources Management Assessments, at (202) 566-0893 or
FROM: Arthur A. Elkins, Jr.
TO:
Vaughn Noga
Director, Office of Technology Operations and Planning
Office of Environmental Information

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brevard.rudv@epa.gov; or Michael Goode, Project Manager, at (202) 566-0354 or
goode.michael@epa.gov.

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EPA's Office of Environmental Information	12-P-0879
Should Improve Ariel Rios and Potomac Yard
Computer Room Security Controls
		Table of 	
Purpose		1
Background		1
Scope and Methodology		1
Findings		1
Lack of Monitoring, Oversight, and Procedures Increases Risk of
Unauthorized Computer Room Access		2
Uninterruptible Power Supply Lacks Ability to Automatically
Shut Down Critical IT Assets		3
Lack of Key Environmental Controls Increases Risk of
Water Damage to Critical IT Assets		3
Recommendations		4
Agency Comments and OIG Evaluation		5
Status of Recommendations and Potential Monetary Benefits		6
Appendices
A Agency Response to Draft Report	 7
B Distribution	 11

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Purpose
The U.S. Environmental Protection Agency (EPA) Office of Inspector General
(OIG) conducted this audit to assess the security posture and in-place
environmental controls of EPA's Office of Environmental Information (OEI)
Ariel Rios computer room in Washington, DC, and Potomac Yard computer room
in Arlington, Virginia. This audit was conducted in support of the audit of EPA's
directory service system authentication and authorization servers
Background
OEI supports the Agency's mission to protect public health and the environment
by integrating quality environmental information to make it useful for informing
decisions, improving management, documenting performance, and measuring
success. The Ariel Rios and Potomac Yard computer rooms house information
technology (IT) assets that are used for Agency user authentication and
authorization, Internet connectivity, and data storage.
Scope and Methodology
We performed this audit from January 2011 through May 2012 in accordance
with generally accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient and appropriate evidence
to provide a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
We conducted the on-site review of the computer room security posture and in-
place environmental controls at the Ariel Rios and Potomac Yard computer
rooms in Washington, DC, and Arlington, Virginia, respectively, in April 2011.
The criteria used for the review were derived from the National Institute of
Standards and Technology (NIST) Special Publication (SP) 800-53,
Recommended Security Controls for Federal Information Systems and
Organizations, "Physical and Environmental Protection Security" control family.
We evaluated the computer rooms through inquiry, observation, and review of
documentation.
We had no prior report recommendations for follow up during this audit for
these two specific sites.
Findings
The Ariel Rios and Potomac Yard computer room control deficiencies greatly
reduce the ability of OEI to safeguard critical IT assets and associated data from
the risk of unauthorized access, damage, and/or loss. In particular, physical access
controls were not in place to monitor access to critical IT assets, and the server
12-P-0879
1

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room lacked environmental controls to protect these assets from potential loss or
damage due to power outages and water leaks. NIST prescribes the selection and
implementation of appropriate security controls for an information system, which
represent the management, operational, and technical safeguards or
countermeasures employed to protect the confidentiality, integrity, and
availability of the system and its information. If OEI does not correct identified
weaknesses, it faces potential disruption of its operations.
Lack of Monitoring, Oversight, and Procedures Increases Risk of
Unauthorized Computer Room Access
The OIG was unable to determine if OEI has any policies and procedures in place
to ensure that computer room access is only granted to authorized employees. The
OIG was also unable to determine if OEI maintains a listing of employees
authorized to access the computer room. OEI indicated that they randomly review
the authorized employee access list, but the OIG was not provided with any
documentation to support that assertion. OEI's Ariel Rios and Potomac Yard
computer room visitor logs had not been used or reviewed. This lack of computer
room access controls increases the risk that unauthorized individuals may gain
entry into the computer room and damage critical IT assets.
NIST SP 800-53 states that an organization must do the following:
•	Develop, disseminate, and review/update a formal, documented
physical and environmental protection policy that addresses
purpose, scope, roles, responsibilities, management commitment,
coordination among organizational entities, and compliance
•	Develop and keep current a list of personnel with authorized access
to the facility where the information system resides
•	Review and approve the access list and authorization credentials,
removing from the access list personnel no longer requiring access
•	Maintain visitor access records to the facility where the
information system resides
•	Review visitor access records
OEI must establish physical access policies and procedures to ensure that access
to facilities containing critical IT assets is documented and regularly reviewed by
management. OEI must also utilize and review visitor access logs for computer
rooms. These steps are essential to mitigating the risk of damage to critical IT
assets.
12-P-0879
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Uninterruptible Power Supply Lacks Ability to Automatically Shut
Down Critical IT Assets
In emergency situations, OEI has only a limited ability to shut down the Ariel
Rios and Potomac Yard computer room IT assets in an orderly fashion. The
possibility of an orderly shutdown is hindered by the following conditions:
•	Lack of generator to provide emergency power
•	Lack of around-the-clock staff presence in computer rooms
•	Short duration of existing uninterruptible power supply to provide
backup power
•	Lack of uninterruptible power supply capable of automatically
shutting down IT assets
NIST SP 800-53 states that an organization should provide a short-term
uninterruptible power supply to facilitate an orderly shutdown of the information
system in the event of a primary power source loss.
In the Potomac Yard computer room, authorized personnel have only 1 hour and
30 minutes from the time power is lost to get to the computer room and manually
shut down the IT equipment; in the Ariel Rios computer room, we were told that
the length of time is only 3 minutes. These short periods during which backup
power is available, combined with the lack of dedicated around-the-clock staff
manning the computer rooms and the lack of an emergency generator and
automatic shutdown capabilities, increase the likelihood that personnel will not be
able to perform an orderly shutdown of IT assets in the event of a power loss.
Lack of Key Environmental Controls Increases Risk of Water Damage
to Critical IT Assets
Ariel Rios and Potomac Yard computer room IT assets are at risk of damage due
to accidental water leakage. Server cabinets containing the IT assets are located
directly under the computer rooms' overhead sprinklers, and the fire suppression
systems within the rooms are fully charged. Fully charged fire suppression
systems maintain water pressure at all times. These pipes could leak, especially at
points where the sprinkler heads connect to the water pipes. The computer rooms
also did not have compensating controls, such as leak shields, to protect these
assets from potential water damage.
Where there is a fully charged fire suppression system, the risk of water damage
from leaks may be mitigated by not placing IT assets directly under sprinkler
heads or pipes when possible. When it is not possible to relocate IT assets to areas
not directly under sprinkler heads and pipes, other compensating controls such as
leak shields attached to or above the cabinets should be utilized.
12-P-0879
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The Ariel Rios and Potomac Yard computer rooms also did not have formal
procedures related to monitoring for water leaks in the computer room or for
actions to be taken in the event of a water leak. In addition, the Ariel Rios and
Potomac Yard computer rooms did not have master shutoff valves for the water
pipes running through the computer rooms or water detectors on the floor of the
computer rooms to alert personnel and permit them to take timely action in the
case of a water leak.
The U.S. Government Accountability Office Federal Information System
Controls Audit Manual specifies that environmental controls exist to help ensure
that building plumbing lines do not endanger the computer facility or, at a
minimum, that shutoff valves and procedures exist and are known. NIST SP
800-53 stipulates that an organization should protect information systems from
damage resulting from water leakage by providing master shutoff valves that are
accessible, working properly, and known to key personnel.
Recommendations
We recommend that the Director, Office of Technology and Operations Planning,
Office of Environmental Information:
1.	Develop and implement computer room policies and procedures that
ensure that computer room access is only grant to authorized employees
and that visitor access is approved, documented, and reviewed.
2.	Acquire and implement an uninterruptible power supply that will
automatically perform an orderly shutdown of IT assets without manual
intervention in the event of a long-term loss of power.
3.	Move the server racks so that they are not directly under sprinkler heads or
water pipes, or, if that is not possible, install leak shields on or above the
server racks directly under sprinkler heads or water pipes.
4.	Install a master shutoff valve for the water pipes that flow through the
computer room.
5.	Develop and implement policies and procedures that address limiting
water damages to IT assets in the computer room that include:
a.	24 hours/day, 7 days/week monitoring
b.	Timely actions to be taken in the event of a water leak in the
computer room
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Agency Comments and OIG Evaluation
Following the issuance of the draft report, OEI provided a corrective action plan
with milestone dates to address agreed-upon recommendations. In its response,
OEI agreed with recommendations 1 and 2, but did not agree with
recommendations 3, 4, and 5. OEI did not agree with recommendations 3 and 4
because it asserts that the Office of Administration and Resources Management
bears responsibility for remediation for these recommendations. For
recommendation 5, OEI did not agree because it stated that it is already
monitoring environmental variable information which would alert it to the
presence of a computer room water leakage. OEI also stated that it has completed
corrective actions for recommendation 1.
We consider recommendation 1 closed with agreed-upon corrective actions
complete. Recommendation 2 is open with agreed-upon corrective actions
pending. The OIG believes that OEI bears the responsibility for recommendations
3 and 4 because it is responsible for managing IT assets in the Ariel Rios and
Potomac Yard computer rooms. Therefore, OEI needs to ensure that corrective
actions are carried out for recommendations 3 and 4. During the audit, the OIG
requested any policies and procedures that address limiting water damage to IT
assets. OEI did not provide any documentation for this request and the OIG
concluded that such policies did not exist. Therefore, recommendation 5 was
made to OEI. We consider recommendations 3, 4, and 5 unresolved with
resolution efforts in progress.
12-P-0879
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
Claimed
Amount
Agreed-To
Amount
4 Develop and implement computer room policies
and procedures that ensure that computer room
access is only grant to authorized employees and
that visitor access is approved, documented, and
reviewed.
4 Acquire and implement an uninterruptible power
supply that will automatically perform an orderly
shutdown of IT assets without manual intervention
in the event of a long-term loss of power.
4 Move the server racks so that they are not directly
under sprinkler heads or water pipes, or, if that is
not possible, install leak shields on or above the
server racks directly under sprinkler heads or
water pipes.
4 Install a master shutoff valve for the water pipes
that flow through the computer room.
Develop and implement policies and procedures
that address limiting water damages to IT assets in
the computer room that include:
a.	24 hours/day, 7 days/week monitoring
b.	Timely actions to be taken in the event of a
water leak in the computer room
Director, Office of
Technology and Operations
Planning, Office of
Environmental Information
Director, Office of
Technology and Operations
Planning, Office of
Environmental Information
Director, Office of
Technology and Operations
Planning, Office of
Environmental Information
Director, Office of
Technology and Operations
Planning, Office of
Environmental Information
Director, Office of
Technology and Operations
Planning, Office of
Environmental Information
1 0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is unresolved with resolution efforts in progress
12-P-0879
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Appendix A
Agency Response to Draft Report
June 29, 2012
MEMORANDUM
SUBJECT: Follow-on Responses to Audit: EPA's Office of Environmental Information
Should Improve Ariel Rios and Potomac Yard Computer Room Security Controls,
Report Project No. OMS-FY11-0007
FROM: MajaLee
Acting Director, Enterprise Desktop Solutions Division
Office of Technology Operations and Planning
THRU: V aughn N oga,
Director, Office of Technology Operations and Planning and
Chief Technology Officer
TO:	Rudolph M. Brevard
Director, Information Resources Management Assessments
Office of the Inspector General
The purpose of this memorandum is to provide a response to the subject draft report and provide
additional clarification regarding the Office of Environmental Information's (OEI) security
controls at the Ariel Rios and Potomac Yard Server Room facilities.
OEI appreciates the OIG's desire to ensure EPA has adequate security controls in place.
Attached is a detailed response to the draft report and a Corrective Action Plan for the actions
which the Office of Technology Operations and Planning (OTOP) has the lead.
If you have any questions regarding this response, please contact me at 202-566-0300.
Attachments
Cc: Anne Mangiafico
MajaLee
12-P-0879
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Office of Environmental Information
Corrective Action Plan
As of 07/11/12
Auditing Group: OIG
Audit No.: OMS-FY11-0007
Report Date: May 31, 2012
OEI Lead Office: OTOP/EDSD
Audit Title: Draft Report - EPA's Office of Environemtnal
Information Should Improve Ariel Rios and Potomac Yard
Computer Rooms Security Controls
OEI Lead and Phone: James Freeman 703-305-8186
Recommendation
OIG Revised
Corrective
Planned
Status / Actions

Recommendations
Action
Completion
Date
Taken
1. Develop and

Completed

Memorandum title:
implement

Policies and

Request for Access to
computer room

procedures are

Secure Areas (Data
policies and

currently in

Center/LAN closet)
procedures that

place to ensure

creation date June
ensure that

that computer

8,2011
computer room

room access is


access is only

only granted to


granted to

employees with


employees with

authorization


authorization and

and that visitor


that visitor access

access is


is approved,

approved,


documented, and

documented


reviewed.

and reviewed.


2. Acquire and

Concur As part
Dec. 31,
POAM's will be
implement an

of the Federal
2012
created in ASSERT to
uninterruptible

Government's

track the installation
power supply that

data

of the new power
will automatically

consolidation

source for Potomac
perform an

initiative, the

Yard and the Federal
orderly shutdown

Ariel Rios

Government data
of IT assets

computer room

center consolidation
without manual

will be closed

initiative that will
intervention in the

and the servers

affect computer
event of a long-

migrated to

rooms at EPA
term loss of

Potomac Yard.

headquarters.
power.

Efforts are
underway with
GS A to install a
backup
generator at the


12-P-0879
8

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Recommendation
OIG Revised
Corrective
Planned
Status / Actions

Recommendations
Action
Completion
Taken



Date



Potomac Yard




facility. The




generator will




provide 24/7




backup power




to the computer




room and in the




event of a




prolonged




power outage,




sufficient




notification




would enable




an orderly




shutdown of IT




assets.


3 Move the server

Non-Concur


racks so that they

As part of the


are not directly

Federal


under sprinkler

Government's


heads or water

data


pipes, or, if that is

consolidation


not possible,

initiative, the


install leak shields

Ariel Rios


on or above the

computer room


server racks

will be closed


directly under

and the servers


sprinkler heads or

migrated to


water pipes.

Potomac Yard.




Water damage




cannot be




avoided if the




sprinkler




system is




activated and




operates per




specifications




(i.e. sprays




water).




Refer to




OARM-


12-P-0879
9

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Recommendation
OIG Revised
Recommendations
Corrective
Action
Planned
Completion
Date
Status / Actions
Taken


OARM is
responsible for
the facility and
water
sprinklers.


4. Install a master
shutoff valve for
the water pipes
that flow through
the computer
room.

Non-Concur
Refer to
OARM -
OARM is
responsible for
the facility,
water pipes and
shut off valves.


5. Develop and
implement
policies and
procedures that
address limiting
water damages to
IT assets in the
computer room
that include a) 24
hours/day, 7
days/week
monitoring; and
(2) timely actions
to be taken in the
event of a water
leak in the
computer room.

Non-Concur
Monitoring of
environmental
variable
information
such as water,
fire,
temperature,
humidity,
power, and
smoke is part of
the current
standard
procedures, is
monitored 24/7
and issues are
reported to an
identified group
by text message
and email.

EPA monitors
environmental
variable information
through HP Openview
with e-mail and text
message notifications
to personnel in order
to address any
reported issues.
12-P-0879
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator for Environmental Information and Chief Information Officer
Principal Deputy Assistant Administrator for Environmental Information
and Senior Information Official
Director, Office of Technology Operations and Planning, Office of Environmental Information
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Senior Agency Information Security Officer, Office of Environmental Information
Audit Follow-Up Coordinator, Office of Environmental Information
12-P-0879
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