OFFICE OF
INSPECTOR GENERAL
Semiannual
Report to Congress
April 1, 2019-September 30, 2019
350-R-19-004
November 2019

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Index of Reporting Requirements
Inspector General Act of 1978, as amended
Section 5(a
Significant recommendations for corrective action
13-23, 29-30, 35-36
Section 5(a
Matters referred to prosecutive authorities
25-28, 30, 43-44
61-65
Section 5(a
List of reports issued
45-46
Section 5(a
Audit, inspection and evaluation reports—questioned costs
2, 41-42, 45-46
Section 5(a
Prior audit, inspection and evaluation reports unresolved
47-48
Section 5(a
Significant management decisions with which OIG disagreed
None
Section 5(a
17-18)
Statistics on investigative reports, referrals, prosecutions, indictments
28, 41, 43-44
Section 5(a
20)
Description of whistleblower retaliation
Section 5(a
22)
Closed audits, evaluations and investigations not disclosed to public
61-65
Section 5(a
Information or assistance refused
None
Section 5(a
Any establishment attempts to interfere with independence
Section 5(a
14-16)
Peer reviews conducted
66
Section 5(a
Significant revised management decisions
None
Section 5(a
Audit, inspection and evaluation reports—funds to be put to better use 2, 41-42, 45-46
Section 5(a
Substantiated Investigations involving senior government employees
61-62
Section 5(a
Summaries of significant reports
13-24, 29-30, 35-36
Section 5(a
Reports with corrective action not completed
4-8, 49-60
Section 5(a
Requirement
Subject
Significant problems, abuses and deficiencies
Page
13-30
Abbreviations
CSB	U.S. Chemical Safety and Hazard Investigation Board
CFR	Code of Federal Regulations
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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Washington, D.C. 20460
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Message to Congress
The U.S. Environmental Protection Agency's (EPA's) Office of Inspector
General (OIG) is pleased to present this semiannual report for the period ending
September 30, 2019. Our investigative and audit activity was wide and deep—
with accomplishments helping to "move the needle." Besides our own judgment
on where best to put our energies on behalf of the public and the agency, we
considered congressional requests, hotline suggestions and thoughtful agency
ideas.
Office of Investigations Refocuses Efforts
During the reporting period, the EPA OIG s Office of Investigations underwent
new leadership and refocused its core mission to best align with its oversight
role in investigating fraud, waste and abuse of agency programs and operations. The office implemented a
staff realignment to enhance stakeholder outreach and relationship-building, and improve efficiency and
effectiveness in its operations. The Office of Investigations also reset its priorities to target areas that will
have the greatest return on investment: procurement and grant fraud, financial fraud, laboratory fraud,
serious employee misconduct, and computer intrusion. The Office of Investigations stands fully poised to
better serve the agency and taxpayer, and further the OIG's goals and objectives.
Recent significant investigations are illustrative. For example, in August 2019, a federal contractor—
ManTech Advanced Systems Internal Inc.—agreed to pay the U.S. government $750,000 in a civil
settlement, including $325,000 in restitution to the EPA. ManTech had been awarded a subcontract that
required certain tasks be performed only by individuals with Top-Secret clearances. However, ManTech "s
principal project manager, who was required to maintain a Top-
Security clearance, continued to work on the project despite that
manager's clearance having been revoked.
Spurred by our intense investigative legwork, the EPA's
Suspension and Debarment Program took 20 actions
(10 suspensions and 10 debarments) against 11 individuals
and three business entities. These actions debarred or
suspended the individuals from participating in federal
procurement and non-procurement programs ranging from
3 to 10 years and amounted to a total of 46 years. A 10-year
debarment involved a former EPA employee who was
convicted of obstructing an EPA OIG child pornography
investigation. The fonner finance director for the Yukon River
Inter-Tribal Watershed Council in Alaska and his company
were debarred for 8 years from participation in federal
procurement and non-procurement programs, and a council
accountant was sentenced to 18 months in prison and ordered
to pay $40,604 in restitution for misapplying $315,000 in EPA
funds for his personal benefit.
On another front, we issued a management report after
discovering that, for decades, a Senior Executive Service-level
Charles J. Sheehan
OIG Accomplishments
(this reporting period and fiscal year 2019)
•	Questioned costs and potential monetary
benefits (includes results from single audits)
April 1-September 30, 2019: $2.65 million
FY 2019:	$3.14 million
•	Total fines and recoveries
(includes EPA only and joint investigations)
April 1-September 30, 2019: $1.09 million
FY 2019:	$114.05 million
•	Reports issued
April 1-September 30, 2019: 33 reports
FY 2019:	46 reports
•	Investigative cases closed
April 1-September 30, 2019:	49 cases
FY 2019:	132 cases
•	Administrative actions resulting
from investigative cases
April 1-September 30, 2019: 31 actions
FY 2019:	49 actions
•	Hotline inquiries referred for action
April 1-September 30, 2019: 185 inquiries
FY 2019:	392 inquiries

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
EPA attorney had self-represented as having an active law license when the attorney's license had, in fact,
been suspended. This situation occurred because the self-certification process for EPA attorneys was
subject to abuse. As a result of our investigation, the agency issued new guidance that includes enhanced
procedures for verifying an attorney's credentials.
Listening Sessions Initiated for Communities Near Contaminated Sites
To engage the American public and take direct feedback, the EPA OIG held a series of community
listening sessions with residents living near contaminated sites regarding their concerns about potential
human health risks. Risk communication frequently has come up as a challenge in the Superfund
program. We decided that hearing from people most affected would be key. We held sessions in four
communities, at which we offered the opportunity to speak, and also distributed written surveys.
Participants expressed strong and differing opinions about the EPA's work—we heard from community
members about where the EPA could do better and where it is doing a good job. All input from these
sessions will be considered in final report findings and inform any recommendations on how the agency
can improve its risk communication efforts.
Audits Address Critical Issues
Based on numerous congressional requests and hotline complaints, we issued an audit report on the travel
of former EPA Administrator Scott Pruitt and associated staff, including his security detail. Over a
10-month period, we identified 40 trips and $985,037 in costs associated with Mr. Pruitt's travel. Of those
40 trips, 16 included travel to, or stops in, Tulsa, Oklahoma—the location of Mr. Pruitt's personal
residence. We noted issues regarding first-class travel, use of noncontract air travel and lodging costs
above per diem, and the approving and reporting of international travel. In another report, we found that
the EPA does not have an effective strategy to implement and enforce the Lead Renovation, Repair and
Painting Rule, which is intended to address hazards in disturbing lead-based paint in specific housing and
child-occupied facilities.
We also issued two management alerts spotlighting issues needing immediate attention: one involving risk
communication at the Amphenol/Franklin Power Products site in Franklin, Indiana, and the other involving
inaccurate data related to releases of hazardous substances from Publicly Owned Treatment Works. In a
review initiated as a result of a hotline complaint, we noted that EPA Region 5 needs to act on a transfer
request and citizen petition regarding Ohio's Concentrated Animal Feeding Operation permit program that
had been on hold for over 8 years. Another hotline review noted that the EPA did not implement key
oversight activities regarding its Enterprise Customer Service Solution/Customer Relationship management
system used to host its Frequently Asked Questions.
Note of Appreciation
This semiannual report marks the final achievement of Gary Sternberg, editor and teacher of editing and
clear writing principles par excellence for the OIG, and long the guiding force behind this report. The
only consolation in Gary's retirement is his having nurtured numerous OIG staff and managers to do well
what he did so well over the some 20 years the office was fortunate to have him. All wish him the best.
\J
Charles J. Sheehan
Acting Inspector General

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Table of Contents
About EPA and Its Office of Inspector General		1
Scoreboard of Results		2
FY 2019 EPA Management Challenges Issued		3
Status of OIG Unimplemented Recommendations		4
EPA OIG Implements Listening Sessions to Obtain Community Input		9
Furthering EPA's Efforts		10
Status of Whistleblower Retaliation and Interference with Independence		12
Significant OIG Activity		13
Congressionally Requested Activities		13
Human Health and Environmental Issues		15
Agency Business Practices and Accountability		21
Investigations		25
Hotline Activities		29
Other Activities		34
U.S. Chemical Safety and Hazard Investigation Board		35
Other Results of OIG Work		37
Follow-Up Is Important Aspect of OIG Efforts		37
Single Audit Reporting Efforts Make Impact		38
Agency Best Practices		39
Statistical Data		41
Profile of Activities and Results		41
Audit Report Resolution		42
Summary of Investigative Results		43
Appendices		45
Appendix 1—Reports Issued		45
Appendix 2—Reports Issued Without Management Decisions		47
Appendix 3—Reports with Corrective Action Not Completed		49
Appendix 4—Closed Investigations Not Previously Publicly Disclosed		61
Appendix 5—Peer Reviews Conducted		66
Appendix 6—OIG Mailing Addresses and Telephone Numbers		67

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
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., 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 effectively. OIG staff are located at EPA headquarters in Washington, D.C.;
the EPA's 10 regional offices; 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 a premier oversight organization trusted to speak the truth, promote good
governance, and contribute to improved human health and the environment.
Conduct independent audits, evaluations and investigations; make evidence-based
recommendations to promote economy, efficiency and effectiveness; and prevent and
detect fraud, waste, abuse, mismanagement and misconduct for the EPA and the CSB.
Goals
1.	Contribute to improved EPA and CSB programs and operations protecting human
health and the environment, and enhancing safety.
2.	Conduct audits, evaluations and investigations that enable the EPA and the CSB to
improve business practices and accountability.
3.	Improve OIG processes, resource allocation and accountability to meet stakeholder
needs.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Scoreboard of Results
The information below shows taxpayer return on investment for work performed by the EPA OIG during fiscal
year (FY) 2019 compared to FY 2019 annual performance goal targets. All results reported are based on goals and
plans established under the Government Performance and Results Act.
Note: A lapse in federal appropriations from December 22, 2018, to January 25, 2019, forced the OIG to
suspend operations, delaying project progress during that time.
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: 118
(60.20% of goal)
Supporting measures
8 Environmental/health improvements realized or influenced by OIG work
108 Environmental, chemical safety or business policy, practice or process change made,
or decisions implemented
2 Legislative or regulatory changes
Annual Performance Goal 2:
Recommendations, challenges, best practices or risks identified for action
Target: 460
Reported: 862
(187.39% of goal)
Supporting measures
*18 Certifications, verifications and validations
*240 Recommendations for improvement (including risk identified)
6 Referrals for agency action
*598 OIG-identified findings in external reports impacting EPA
Annual Performance Goal 3:
Return on investment: potential dollar return as percentage of OIG budget
Target: $80,427,200
(160% of budget)
Reported: $314,010,598
(390.43% of target)
Supporting measures fin millions)
OIG budget: $50.3
Potential return: $314.0
*$0,840 Questioned costs
$2,298 Potential monetary benefits identified in reports—excluding questioned costs
$181.665 Monetary actions taken or resolved prior to report issuance
$15,845 Actual cost saved identified after report issuance
$0,529 Cost avoidance savings/cost savings identified after report issuance or based on
investigative results
$1.175 Fines, penalties, settlements and restitutions resulting from EPA OIG investigations
$112.870 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: 200
Reported: 384
(192% of goal)
Supporting measures
191 Allegations disproved
5	Indictments, informations and complaints
6	Criminal convictions
3 Civil actions
27 Administrative actions taken (other than debarments or suspensions)
22 Suspension or debarment actions
130 Fraud briefings conducted
Other (no targets established)
Savings and recommendations sustained:
•	*167 sustained environmental or business recommendations (resolved or agreed-to) for action
•	*$0,042 million in sustained questioned costs
•	$2,298 million in sustained potential monetary benefits
Sources: The OIG Performance Measurement Results System and the Inspector General Enterprise Management System.
* These measures include single audits, which are audits of nonfederal entities performed by private firms.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
FY 2019 EPA Management Challenges Issued
Report No. 19-N-0235. issued July 15, 2019
Attention to agency management challenges—areas with greater vulnerability to waste,
fraud, abuse and mismanagement—could result in better protection for the public and
increased confidence in management integrity and accountability. As required by the
Reports Consolidation Act of 2000, the OIG identified the following issues as the EPA's
key management challenges for FY 2019; the first five were retained from the previous
year's report due to persistent issues that continue, while the last one is a new challenge:
•	The EPA Needs to Improve Oversight of States, Territories and Tribes
Authorized to Accomplish Environmental Goals: The EPA has made important
progress, but our work continues to identify challenges throughout agency
programs and regions, and many of our recommendations are still not fully
implemented.
•	The EPA Needs to Improve Its Workload Analysis to Accomplish Its Mission
Efficiently and Effectively: The EPA needs to identify its workload needs so that
it can more effectively prioritize and allocate limited resources to accomplish its
work.
•	The EPA Needs to Enhance Information Security to Combat Cyber Threats:
Though the EPA continues to initiate actions to strengthen or improve its
information security program, issues remain.
•	The EPA Needs to Improve on Fulfilling Mandated Reporting Requirements:
The agency faces challenges in tracking and submitting reports that are mandated
by law and that contain key program information for Congress, the EPA
Administrator and the public.
•	The EPA Needs Improved Data Quality and Should Fill Identified Data Gaps
for Program Performance and Decision-Making: Poor data quality negatively
impacts the EPA's effectiveness in overseeing programs that directly impact human
health.
•	The EPA Needs to Improve Risk Communication to Provide Individuals and
Communities with Sufficient Information to Make Informed Decisions to
Protect Their Health and the Environment: In 2018, the EPA Administrator
identified risk communication as a top priority, and our recent reports indicate risk
communication challenges across many EPA programs.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
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 as of September 30, 2019
(presented by fiscal year issued)
40
FY 2008 - FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 FY 2019
2013
For the semiannual reporting period ending September 30, 2019, the EPA cumulatively had
77 unimplemented recommendations and the CSB had one unimplemented
recommendation. The potential monetary benefits of these recommendations are
approximately $68 million for the EPA and $349,000 for the CSB.
The table below shows the status of the recommendations, which fall into six categories.
The CSB report is included in the "Management and Operations" category.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category
Total
No. of
recommendations
Potential
monetary benefits
(in $000s)
1. Management and Operations
34
$37,501
2. Water Issues
5
0
3. Environmental Contamination and Cleanup
11
27,800
4. Toxics, Chemical Safety and Pesticides
9
0
5. Air Quality
14
2,905
6. Research and Laboratories
5
0
Total
78
$68,206
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.
Category 1—Management and Operations
The 34 unimplemented recommendations in this category were issued within the following
14 reports and offer the potential for more effective and efficient operations, as well as
potential monetary benefits of $37.5 million:
• Improve oversight of:
o Water Infrastructure Finance and Innovation Program internal controls
(Report No 19-P-0045).
o Law Enforcement Availability Pay controls processes (Report No. 19-P-0001).
o Assessment of threats to identify the proper level of protection for the EPA
Administrator (Report No. 18-P-0239).
o Purchase Card and Convenience Check program controls to prevent improper
purchases (Report No. 18-P-0232). The potential monetary benefit of this
unimplemented recommendation is $152,000.
o Operational efficiencies of the EPA's human resources shared service centers
(Report No. 18-P-0207).
o Companies with multiple cleanup liabilities that self-insure
(Report No. 18-P-0059).
o Consolidated financial statements (Report Nos. 17-F-0046 and 16-F-0040).
o CSB future leasing with the General Services Administration
(Report No. 16-P-0179). The potential monetary benefit of this unimplemented
recommendation is $349,000.
o Grants execution in the U.S. Virgin Islands (Report No. 15-P-0137).
The potential monetary benefit of this unimplemented recommendation is
$3 7 million.
o Emergency and Rapid Response Contracts (Report No. 14-P-0109).
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
•	Institutionalize the Lean program to reap cost and time benefits
(Report No. 17-P-0346).
•	Implement better processes for information technology regarding:
o Individual Personal Identify Verification cards and access to computer
equipment (Report No. 19-F-0003).
o Incident Tracking System controls to protect personal information
(Report No. 18-P-0298).
Category 2—Water Issues
The five unimplemented recommendations in this category were issued within the
following three reports and offer the potential for improved human health and the
environment, as well as more effective and efficient operations:
•	Strengthen oversight of state drinking water programs to improve response to
drinking water contamination emergencies such as in Flint, Michigan
(Report No. 18-P-0221).
•	Provide leadership and better guidance to improve fish advisory risk
communications (Report No. 17-P-0174).
•	Revise outdated or inconsistent EPA/state clean water memorandums of agreement
(Report No. 10-P-0224).
Category 3—Environmental Contamination and Cleanup
The 11 unimplemented recommendations in this category were issued within the following
five reports and offer the potential for improved human health and the environment, more
effective and efficient operations, and potential monetary benefits of $27.8 million:
•	Implement more efficient and effective methods to assess the impact of unregulated
pollutants in land-applied biosolids (Report No. 19-P-0002).
•	Finish prioritization and resource allocation methodologies for abandoned uranium
mine sites on or near Navajo lands (Report No. 18-P-0233).
•	Revise risk management inspection guidance to recommend minimum inspection
scope and provide detailed examples of minimum reporting
(Report No. 13-P-0178).
•	Improve management of the Oil Pollution Prevention program
(Report No. 12-P-0253).
•	Make better use of Stringfellow Superfund Special Accounts
(Report No. 08-P-0196). The potential monetary benefit of this unimplemented
recommendation is $27.8 million.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category 4—Toxics, Chemical Safety and Pesticides
The nine unimplemented recommendations in this category were issued within the
following five reports and have the potential for improved human health and the
environment:
•	Improve measures and management controls over the pesticide emergency
exemption process (Report No. 18-P-0281).
•	Implement controls over the use of unverified results within the Presidential Green
Chemistry Challenge Awards program (Report No. 18-P-0222).
•	Better manage state pesticide cooperative agreements to more effectively use funds
and reduce risk of pesticide misuse (Report No. 18-P-0079).
•	Reduce risks from illegal pesticides by effectively identifying imports for
inspection and sampling (Report No. 17-P-0412).
•	Manage pesticide funds more efficiently (Report No. 17-P-0395).
Category 5—Air Quality
The 14 unimplemented recommendations in this category were issued within the following
six reports and have the potential for improved human health and the environment, as well
as potential monetary benefits of $2.9 million:
•	Collect additional performance data from states to better assess the effectiveness of
vehicle inspection and maintenance programs (Report No. 18-P-0283).
•	Strengthen the process for revising air quality dispersion models that predict impact
of pollutant emissions (Report No. 18-P-0241).
•	Improve controls to address strategic risks in the light-duty vehicle compliance
program and achieve compliance with mobile source regulations
(Report No. 18-P-0181).
•	Improve data and oversight to assure compliance with the standards for benzene
content in gasoline (Report No. 17-P-0249).
•	Meet certain statutory requirements to identify environmental impacts of the
Renewable Fuel Standard (Report No. 16-P-0275).
•	Provide a verifiable and enforceable remedy to reduce diesel emissions in the
Baton Rouge ozone nonattainment area (Report No. 13-R-0297). The potential
monetan> benefit of this unimplemented recommendation is $2.9 million.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category 6—Research and Laboratories
The five unimplemented recommendations in this category were issued within the
following two reports and have the potential for improved human health and the
environment, as well as more effective and efficient operations:
•	Develop a comprehensive vision and strategy for citizen science that aligns with
the agency's strategic objectives on public participation (Report No. 18-P-0240).
•	Review the Community-Focused Exposure and Risk Screening Tool and develop
an action plan with time frames to address issues identified, including
considerations on whether to retain the tool (Report No. 17-P-0378).
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
EPA OIG Implements Listening Sessions to
Obtain Community Input
The EPA OIG conducted a series of listening sessions to solicit input from community
members regarding the EPA's communication with residents about potential health risks at
contaminated sites. The listening sessions were held in nearby communities for four sites:
•	Anaconda Co. Smelter Site, Anaconda, Montana.
•	USS Lead Site, East Chicago, Indiana.
•	Coakley Landfill Site, North Hampton, New Hampshire.
•	Amphenol/Franklin Power Products Site, Franklin, Indiana.
hi addition, a team of OIG auditors, evaluators and public
affairs specialists visited the contaminated sites, toured the
communities, and met with local leaders and community
groups.
Risk communication has frequently come up as a challenge
for the EPA, including the Superfimd and Resource
Conservation and Recovery Act programs. The listening
sessions were part of a nationwide audit of the agency's
communication of sampling results or other indicators of
human health risk at select sites in Office of Land and
Emergency Management programs. The ongoing audit
includes eight sites, of which the OIG visited the four sites
noted above plus a tribal community. Generally, between
35 and 50 members of the public attended each session.
Of note, during the course of the
listening sessions, the OIG discovered
that the EPA's Cleanups in My
Communis public website did not
depict the most up-to-date risk
information for the Amphenol site in
Franklin. We issued a management
alert report (Report No. 19-N-0217) on
June 27, 2019, to notify the agency.
Our full report on risk communication
is currently being developed.
The EPA OIG team makes a presentation at the
listening session for the Coakley Landfill Site,
North Hampton, New Hampshire. (EPA OIG photo)
The EPA OIG team obtains input at the listening session
for the USS Lead Site, East Chicago, Indiana. (EPA OIG
photo)
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Furthering EPA's Efforts
When conducting our audit work during the second half of FY 2019, we considered the EPA's key areas of effort.
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
Management Alert: Certain Toxic
Release Inventory Data Disclosed to the
Public Are Inaccurate
19-N-0115



X




Regional Research Programs Address
Agency Needs but Could Benefit from
Enhanced Project Tracking
19-P-0123




X



Corrective Actions and Additional
Guidance Have Improved EPA's Fiscal
Responsibility over Superfund
Interagency Agreements
19-P-0146







X
EPA Region 5 Needs to Act on Transfer
Request and Petition Regarding Ohio's
Concentrated Animal Feeding Operation
Permit Program
19-N-0154



X




Actions Needed to Strengthen Controls
over the EPA Administrator's and
Associated Staffs Travel
19-P-0155





X

X
EPA Overpaid Invoices Due to
Insufficient Contract Management
Controls
19-P-0157







X
Insufficient Practices for Managing
Known Security Weaknesses and
System Settings Weaken EPA's Ability to
Combat Cyber Threats
19-P-0158





X

X
EPA Complied with Improper Payments
Legislation but Stronger Internal Controls
Are Needed
19-P-0163





X


EPA Demonstrates Effective Controls for
Its On-Road Heavy-Duty Vehicle
Compliance Program; Further
Improvements Could Be Made
19-P-0168
X




X


Quality Assurance Review of EPA OIG
Audit Assignments Completed in Fiscal
Year 2018
19-N-0167








Pesticide Registration Fee, Vulnerability
Mitigation and Database Security
Controls for EPA's FIFRAand PRIA
Systems Need Improvement
19-P-0195



X



X
EPA Needs to Improve Oversight of the
Senior Environmental Employment
Program
19-P-0198







X
EPA Complied with Applicable Laws and
Rules for the July 2017 Superfund Task
Force Report but Could Improve
T ransparency
19-P-0201







X
EPA Effectively Screens Air Emissions
Data from Continuous Monitoring
Systems but Could Enhance Verification
of System Performance
19-P-0207
X







Fiscal Years 2017 and 2016 (Restated)
Financial Statements for the Pesticides
Reregistration and Expedited Processing
Fund
19-F-0214







X
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
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
Fiscal Years 2017 and 2016 (Restated)
Financial Statements for the Pesticide
Registration Fund
19-F-0215







X
Management Alert: Certain Risk
Communication Information for
Community Not Up to Date for
Amphenol/Franklin Power Products Site
in Franklin, Indiana
19-N-0217


X





EPA's Fiscal Year 2019 Management
Challenges
19-N-0235
X
X
X
X
X
X
X
X
EPA Region 6 Quickly Assessed Water
Infrastructure after Hurricane Harvey but
Can Improve Emergency Outreach to
Disadvantaged Communities
19-P-0236

X




X
X
More Effective EPA Oversight Is Needed
for Particulate Matter Emissions
Compliance Testing
19-P-0251
X







EPA's 2017 Glider Vehicle Testing
Complied with Standard Practices
19-P-0252
X




X


EPA Exceeded the Deregulatory Goals
of Executive Order 13771
19-P-0267





X


EPA Needs to Determine Strategies and
Level of Support for Overseeing State
Managed Pollinator Protection Plans
19-P-0275



X




EPA Office of Research and
Development Needs to Address Barriers
to Gathering External Feedback
19-P-0277




X



EPA Oversight over Enterprise Customer
Service Solution Needs Improvement
19-P-0278







X
EPA's Use of Administratively
Determined Positions is Consistent with
Its Authority Under the Safe Drinking
Water Act
19-P-0279





X

X
Follow-Up Audit: EPA Took Steps to
Improve Records Management
19-P-0283







X
EPA Not Effectively Implementing the
Lead-Based Paint, Renovation, Repair
and Painting Rule
19-P-0302



X




Risk Assessment Determines that Travel
Card Program Merits an Audit Next Year
Because Internal Controls Not Adequate
19-P-0307







X
EPA Must Improve Oversight of Notice to
the Public on Drinking Water Risks to
Better Protect Human Health
19-P-0318

X



X


11

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
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 reporting 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 September 30, 2019. No officials were found to have engaged in retaliation.
Interference with Independence
Section 5(a)(21) of the Inspector General Act of 1978, as amended, requires a detailed
description of any attempt by the establishment to interfere with the independence of the
EPA OIG. This description includes budget constraints designed to limit the OIG's
capabilities, as well as incidents where the agency resisted OIG oversight or delayed OIG
access to information. Generally, we will defer reporting incidents of delayed access to
information experienced in an ongoing audit or investigation until the semiannual period
report in which the audit or investigation closed. (The actual audit or investigation may,
when issued prior to the end of the semiannual period, report any interference with OIG
independence.) There were no reportable attempts by the EPA to interfere with the OIG's
independence within the semiannual period ending September 30, 2019.
12

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Significant OIG Activity
Congressionally Requested Activities
Actions Needed to Strengthen Controls over the EPA Administrator's and
Associated Staff's Travel
Report No. 19-P-0155, issued May 16, 2019
The OIG identified 40 trips and $985,037 in costs associated with
the travel of former EPA Administrator Scott Pruitt for
the 10-month period from March 1, 2017, to December 31, 2017.
This time frame covered 34 completed and six canceled trips and included costs incurred
not only by Pruitt but by his Protective Service Detail and other staff. Of the 40 trips,
16 included travel to, or had stops in, Tulsa, Oklahoma—the location of Pruitt's personal
residence. We estimated excessive costs of $123,942 regarding the former Administrator's
and accompanying Protective Service Detail agents" use of first/business-class travel,
which was authorized without sufficient justification to support the security concerns that
the agency claimed necessitated such travel. We also noted issues regarding granting
first/business-class exceptions, use of noncontract air carriers, approval of lodging costs
above per diem, and approving and reporting of international travel. Ten of our
14 recommendations, including a recommendation to recover the $123,942 and others to
improve controls to prevent future inappropriate actions, were unresolved.
Total costs incurred for all travel
Trip type
No.
trips
Former
Admini-
strator
Staff
Protective
Service
Detail
Other*
Totals
Trips Taken:






Domestic
32
$85,131
$203,443
$301,865
$65,692
$656,131
International
2
26,629
91,544
67,962
36,069
222,205
Subtotal
34
$111,761
$294,987
$369,827
$101,761
$878,336
Canceled:

Domestic
4
$731
$3,633
$4,179
-
$8,543
International
2
1,995
41,273
54,889
-
98,158
Subtotal
6
$2,726
$44,907
$59,069
-
$106,701
% for canceled trips**
2.6%
42.1%
55.4%

100%
Total
40
$114,487
$339,894
$428,896
$101,761
$985,037
% of Total

11.6%
34.5%
43.5%
10.3%
100%
Source: OIG analysis of travel data from the EPA's Compass Data Warehouse.
Note: Numbers in italics slightly off due to rounding.
* Other costs represent military and chartered flight costs.
** Costs for each category (Former Administrator, Staff, Protective Service Detail, Other) as a
percentage of total costs for all canceled trips.
A pod cast on the
Administrator's travel
report is available.
13

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
EPA's 2017 Glider Vehicle Testing Complied with Standard Practices
Report No. 19-P-0252, issued July 31, 2019
In response to two congressional requests, we conducted an audit to examine the
selection, acquisition and testing of glider vehicles at the EPA"s National Vehicle and
Fuel Emissions Laboratory, as well as the EPA's planning for this testing. A glider
vehicle is a truck that uses a previously owned powertrain (including the engine,
transmission and usually the rear axle) but has new body parts. We found that the EPA's
selection and testing of the donated glider vehicles in 2017
were consistent with Clean Air Act authority, standard EPA
practices, and relevant policies and procedures. Also, we
confirmed that necessary approvals for testing were obtained,
and we found no evidence that documentation was deleted or
that ethics restrictions were violated. We did note that the
EPA did not fully adhere to its delegation of authority related
to the acceptance of donated property, and more direction
	 was needed on soliciting and accepting donations. The EPA
The back of a heavy-duty chassis dynamometer agreed to take sufficient corrective actions on the
used for testing glider vehicles. (EPA OIG photo) recommendations made.
Follow-Up Audit: EPA Took Steps to Improve Records Management
Report No. 19-P-0283. issued August 27, 2019
The EPA completed all corrective actions for 13 past audit recommendations from three
prior OIG reports related to the agency's records management and Freedom of
Information Act practices. Actions taken involved issuing an agencywide Freedom of
Information Act policy and procedure. The agency agreed with our new recommendation
that the General Counsel update the Freedom of Information Act policy and procedure to
reflect some 2016 statute changes.
Briefings, Requests and Inquiries
During this reporting period, the OIG provided eight briefings to Congress on the OIG's
work. Specific ongoing OIG work receiving considerable congressional interest included
projects related to former Administrator Fault s and associated staff's travel and our
audit examining the selection, acquisition and testing of glider vehicles at the EPA's
National Vehicle and Fuel Emissions Laboratory. During the reporting period, the OIG
also received nine congressional requests.
14

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Human Health and Environmental Issues
EPA Mot Effectively Implementing the Lead-Based Paint Renovation, Repair and
Painting Rule
Report No. 19-P-0302, issued September 9, 2019
House with
renovation.
We found that the EPA did not have an effective strategy to implement and enforce the
Lead Renovation, Repair and Painting Rule, intended to address hazards associated with
the disturbing of lead-based paint in specific housing and child-
occupied facilities. To adequately determine whether the program
is meeting its intended purpose, the agency should update the
current program guidance, establish oversight controls, and
establish a forum for the regions to share best practices. Also,
coordination and communication must be improved between the
Office of Chemical Safety and Pollution Prevention and the Office
of Enforcement and Compliance Assurance, the two program
offices tasked with overseeing the lead rule program. Of our six
recommendations, two are resolved with corrective actions
pending and four are unresolved.
lead paint undergoing
(EPA photo)
EPA Must Improve Oversight of Notice to the Public on Drinking Water Risks to
Better Protect Human Health
Report No. 19-P-0318, issued September 25, 2019
DRINKING WATER WARNING
f. coli h present in [Water System NameJ's water
BOIL YOUR WATER BEFORE USING
Part of an EPA public notice template for where
E. coli bacteria were found in a water supply.
Forty-nine states, five territories and the
Navajo Nation are responsible for
overseeing whether public water systems
meet federal requirements, including
providing consumers with public notice
of certain situations regarding their
drinking water. Elsewhere, EPA regions
have these oversight responsibilities. We found that some EPA regions and states did not
fulfill their public notice responsibilities. Specifically, some did not consistently record
violations, and some did not track the need for the
issuance of public notices. As a result, the EPA does
not have complete information on public water system
compliance with public notice requirements. Without
reliable information, consumers cannot make informed
health decisions, and the EPA cannot provide effective
oversight. Of our nine recommendations, the agency
agreed with six and three are unresolved.
Promising Practice:
Online Tool for Generating Public Notices
In Colorado, public water systems can use an
online tool to generate notices that comply
with public notice regulations. Colorado also
created an online video that assists public
water systems in using this tool.
15

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Semiannual Report to Congress	April 1,2019—September 30, 2019
Management Alert: Certain Risk Communication Information for Community
Not Up to Date for Amphenol/Franklin Power Products Site in Franklin, Indiana
Report No. 19-N-0217, issued June 27, 2019
We issued a management alert informing the EPA _	,
°	The purpose of the Cleanups in
that the Cleanups in My Community public website Mv Community website is to put
was not depicting the most up-to-date risk	all cleanup information in one
information for the Amphenol/Franklin Power	place and provide easy access,
Products site in Franklin, Indiana. Milestones on the a better understanding, and
improved analysis of sites in
EPA s website show both the human health exposure „
r	one s community.
and contaminated groundwater migration as
"controlled" when EPA officials had information since 2018 that they should no longer
be identified as such. The EPA should convey the most accurate, reliable and up-to-date
information on matters related to public health.
EPA Exceeded the Deregulatory Goals of Executive Order 13771
Report No. 19-P-0267, issued August 9, 2019
In FYs 2017 and 2018, the EPA exceeded deregulatory expectations and savings goals
under Executive Order 13771. The order, issued January 30, 2017, requires agencies to
eliminate two regulations for every new one issued. However, the agency did not develop
internal guidance or management goals to implement the executive order, relying on
guidance from the Office of Management and Budget. We recommended that the EPA
enhance transparency in the decision-making process and reach out to stakeholders. The
agency either disagreed with our recommendations or did not provide sufficient
corrective actions; thus, and all recommendations remain unresolved.
16
Deregulatory
actions
savings:
.5 million
Regulatory action
10
Deregulatory
actions
.t savings:
.1 million
Regulatory actions
FY 20 17
FY 2 0 18
16

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
EPA Region 6 Quickly Assessed Water Infrastructure after Hurricane Harvey but
Can Improve Emergency Outreach to Disadvantaged Communities
Report No. 19-P-0236. issued July 16, 2019
EPA Region 6, in coordination with the Texas Commission of Environmental Quality,
successfully conducted reviews and on-site assessments of drinking water and wastewater
facilities to determine and track their operational status in the aftermath of Hurricane
Harvey. However, the EPA could improve its outreach to vulnerable communities. We
made four recommendations related to environmental justice outreach, including
preparing emergency-related materials in the prevalent languages of an impacted region.
All four recommendations are resolved with corrective actions pending.
Availability of translated EPA information pamphlets after Hurricane Harvey
Pamphlet title
Spanish
Vietnamese
Online
Print
Online
Print
Emergency Disinfection of Drinking Water
Yes
Yes
No
Yes
Private Weils - What to Do After a Flood
No
No
No
Yes
Septic Systems - What to Do After a Flood
No
No
No
Yes
Source: OIG analysis of Region 6 emergency response website and pamphlets provided by region.
EPA Needs to Determine Strategies and Level of Support for Overseeing
State Managed Pollinator Protection Plans
Report No. 19-P-0275, issued August 15, 2019
The EPA plays a supportive role in overseeing the development, ^ ..,-.rir
implementation and measurement of the states' Managed	report on Managed
Pollinator Protection Plans. Managed pollinators Pollinator Protection
H	Plans is available.
are generally honey bees that beekeepers contract	
A	IH Qui to growers for their pollination services. Our audit found that the
EPA does not have a strategy to evaluate the national impact of the plans
or its support of states as they implement the plans. In addition,
stakeholders were concerned that the EPA focuses on acute risks to
®	R	managed pollinators and may limit efforts to address other concerns,
I	such as chronic contact with pesticides and native pollinator protection
A honey bee hive. (U.S. Fish and activities. The agency agreed with our five recommendations and
Wildlife Service photo)	provided acceptable corrective actions.
Management Alert: Certain Toxic Release Inventory Data Disclosed to the
Public Are Inaccurate
Report No. 19-N-Q115, issued April 8, 2019
While conducting an audit of Toxic Release Inventory data, we decided to issue an
immediate management alert informing the agency that the data pertaining to releases of
hazardous substances from Publicly Owned Treatment Works were inaccurate. Such data
17

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
consist of information about toxic chemical releases and pollution prevention activities
reported by industrial and federal facilities. As a result of the inaccuracies, the public was
not receiving complete and timely information affecting human health.
EPA Effectively Screens Air Emissions Data from Continuous Monitoring
Systems but Could Enhance Verification of System Performance
Report No. 19-P-Q207, issued June 27, 2019
The EPA's automated screening of facility-reported
continuous emissions monitoring systems data worked
as intended and was effective in verifying the quality of
reported data. However, we found a small number of
inaccuracies and inconsistencies in the data. The
validity of reported data can only be fully established
when the process is supplemented with on-site field
audits to verify that monitoring
Data from continuous
emissions monitoring systems
are used to determine
whether sources, such as
power plants, comply with
emissions limits designed to
improve air quality and
achieve environmental and
public health goals.
Stack testers performing a Relative Accuracy
Test Audit. (EPA photo)
requirements were met, but the
EPA and states conducted a limited number of these audits. While
the instances noted had no impact on whether the data met quality
assurance requirements, inaccurate data could have a negative
impact by providing inaccurate or misleading information. The
EPA can prevent these problems by adding specific screening
checks to its existing reporting software and by developing a
streamlined field audit procedure that state and local agencies can
use when conducting other on-site visits at facilities. The agency
agreed with our recommended corrective actions.
More Effective EPA Oversight Is Needed for Particulate Matter Emissions
Compliance Testing
Report No. 19-P-0251. issued July 30, 2019
State and local agencies in Washington state
did not always conduct effective oversight
of stack tests gauging whether stationary
sources of air emissions—such as refineries
and power plants—complied with
smokestack emission limits for particulate
matter. These agencies did not always
(1)	review stack test reports to verify that
EPA-approved test methods were followed,
(2)	require stack testers to submit adequate
supporting documentation to assess data
Health impacts of exposure
to particulate matter
According to the EPA, scientific studies
have linked particle pollution exposure to
various human health concerns, including:
•	Premature death in people with heart
or lung disease.
•	Nonfatal heart attacks.
•	Irregular heartbeat.
•	Aggravated asthma.
•	Decreased lung function.
•	Increased respiratory symptoms, such
as irritation of the airways, coughing
or difficulty breathing.
18

-------
Semiannual Report to Congress
April 1, 2019—September 30, 2019
quality in the stack test reports, or (3) observe stack tests. Ineffective oversight could
impact the reliability of the stack test results and the determination of whether a facility
complies with its emission limits. The agency agreed with our recommendations and
provided acceptable corrective actions.
Regional Research Programs Address Agency Needs but Could Benefit from
Enhanced Project Tracking
Report No. 19-P-0123. issued April 18, 2019
The Office of Research and Development's support of regional research programs helped
EPA regions address high-priority research needs, positively impacting the EPA's mission,
operations and decision-making. The EPA could, however, better document the progress,
outputs and impacts of individual projects, helping the agency to better document and
communicate the benefits of its regional research programs overall. The agency agreed
with our five recommendations and has already completed corrective actions for one.
Examples of how regional research projects impacted agency operations and decision-making
Region 4
Region 7
NE
MO
KS
KY
NC
sc
RARE Project
1963 produced
data used for
assessing
damage from oil
spills and
choosing future
sites for nutrient
screening
projects.
RARE Project 1878
influenced decisions
about sensors to be
incorporated into
current sensor pod
designs for EPA's
development of its
Sensor Loan
Program.
RARE Project 1965 influenced the agency's
decision to include a Superfund site on the
National Priorities List and to work
innovatively with states in the region.
RESES Project
provided
regional and
municipal
partners with
new
knowledge of
air quality
conditions for
future
placement of
air monitors.
RARE Project 1877
developed metrics to
evaluate how different
soils and climatic
conditions may
influence the design
and performance of
similar green
infrastructure projects.
Source: OIG analysis of Office of Research and Development and regional data.
RARE: Regional Applied Research Effort RESES: Regional Sustainability and Environmental Sciences
EPA Office of Research and Development Needs to Address Barriers to
Gathering External Feedback
Report No. 19-P-0277, issued August 19, 2019
The EPA Office of Research and Development faces a key barrier in that it is significantly
limited in surveying non-federal external customers when collecting data to support its
strategic measure regarding whether research products meet customer needs. Under the
19

-------
Semiannual Report to Congress
April 1, 2019—September 30, 2019
Paperwork Reduction Act, the office cannot survey more than nine non-federal external
customers without approval from the Office of Management and Budget. The Office of
Research and Development is aware of this barrier and is developing an information
collection request seeking permission from the Office of Management and Budget to
survey more customers.
EPA Office of Research and Development criteria for meeting customer needs
Criteria
Description
Quality
The extent to which a research product meets scientific and technical standards,
is rigorous and transparent, and advances the state of knowledge for a particular
topic.
Usability
The degree to which a research product is suited for and easily applied to
actions within EPA's mission.
Timeliness
Whether a product is delivered within a time frame appropriate for customer use.
Source: Office of Research and Development's strategic measures (May 4, 2018).
EPA Demonstrates Effective Controls for Its On-Road Heavy-Duty Vehicle
Compliance Program; Further Improvements Could Be Made
Report No. 19 0168, issued June 3, 2019
The internal controls within the EPA's heavy-duty vehicle
compliance program are effective at detecting and
preventing noncompliance. However, the agency should
define measures to assess program performance; conduct a
formal program risk assessment; and strengthen some
existing controls, such as how compliance issues are
tracked and referred for enforcement. Of our eight
recommendations, the agency has completed two and has
corrective actions underway for the remaining six.
EPA Complied with Applicable Laws and Rules for the July 2017
Superfund Task Force Report but Could Improve Transparency
Report No. 19-P-0201. issued June 24, 2019
The EPA created and preserved documentation on the Superfund Task Force in accordance
with applicable requirements. In May 2017, the Administrator established the task force to
provide recommendations for improving cleanups and promoting redevelopment, and the
task force issued its report in July 2017. We concluded that experienced EPA staff
prepared the report, and we found no instances of unsolicited influence from outside
sources. We did find that the report could have been more transparent regarding the
process used and the qualifications of the personnel involved. Hie agency agreed with our
recommendation to publish additional task force information on its website.
Heavy-duty vehicles. (EPAOIG photos)
20

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Agency Business Practices and Accountability
Insufficient Practices for Managing Known Security Weaknesses and
System Settings Weaken EPA's Ability to Combat Cyber Threats
Report No. 19-P-0158, issued May 21, 2019
EPA personnel did not manage plans of action and
milestones for remediating security weaknesses within the
agency's information security weakness tracking system as
required. This happened because the office responsible for
identifying vulnerabilities relies on other agency offices to
enter the information in the tracking system. Missing plans of
action and milestones data and incorrect security settings
limit the EPA's ability to manage enterprise risk and
strengthen its security posture. Additionally, the EPA's information security weakness
tracking system lacked controls to prevent unauthorized changes to key data fields and to
record these changes in the system's audit logs. The agency agreed with all our
recommendations and provided acceptable corrective actions.
A "plan of action and
milestones" identifies
tasks that need to be
accomplished to
remediate known
weaknesses in an
information system or
program.
EPA Needs to Improve Oversight of the Senior Environmental Employment
Program
Report No. 19-P-0198, issued June 24, 2019
The EPA needs to improve its oversight of cooperative agreements related to the Senior
Environmental Employment program, which provides opportunities for workers at least
55 years old to assist the agency. The program is implemented though cooperative
agreements with several organizations. Specifically, we found that the EPA did not
timely comply with requirements to document program monitoring reviews, document
oversight of grantee organizations' quarterly reports, provide adequate communications
on guidance, or update a 2010 pay scale for minimum and maximum hourly wages. The
agency agreed to take the recommended corrective actions.
Senior Environmental Employment obligations and enrollees, FYs 2015-2017
Obligations and enrollees
FY 2015
FY 2016
FY 2017
Obligated
$50,621,126
$41,934,566
$43,497,241
Number of enrollees
1,111
1,061
972
Source: EPA Senior Environmental Employment program.
21

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
EPA's Use of Administratively Determined Positions Is Consistent with Its
Authority Under the Safe Drinking Water Act
Report No. 19-P-0279, issued August 21, 2019
The agency's use of administratively determined positions is consistent with the authority
provided by statute. Under the Safe Drinking Water Act, the Administrator can appoint
personnel to fill not more than 30 scientific, engineering, professional, legal and
administrative positions, referred to as administratively determined positions. Between
January 2009 and August 2018, Administrators made 119 such appointments. We did
identify a shift, beginning in 2017, to use such positions to facilitate the hiring of political
appointees. However, because the Safe Drinking Water Act does not specify how
administratively determined appointments are to be used, we made no recommendations.
119 Total Appointments to Administratively
Determined Positions
(January 2009-August 2018)






¦

















13
8
12
8
6
8 5


11
¦
1 _
¦
1 ¦ 1
¦ ¦


1
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
(Jan -
Aug)
Between January 2009 and August 2018, EPA Administrators have used the authority
under the Safe Drinking Water Act to appoint 119 personnel to administratively
determined positions. (EPA OIG image)
Pesticide Registration Fee, Vulnerability Mitigation and Database Security
Controls for EPA's FIFRA and PRIA Systems Need Improvement
Report No. 19-P-0195, issued June 21, 2019
The EPA has adequate controls over the posting of financial transactions related to
pesticide registrations into the agency's accounting system. However, EPA staff
manually post pesticide registration fee data from the agency's accounting system into
the agency's pesticide registration information system, and the EPA needs to improve
controls over that process to prevent errors. Also, the EPA needs to strengthen the
security of its pesticide registration information system by remediating identified
vulnerabilities and managing passwords, patches and user roles per EPA and federal
standards. The agency already completed four of our seven recommendations, and
corrective actions are pending for the remaining three recommendations.
22

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
OIG Renders Opinions for Two Pesticide Funds
The EPA receives funding from fees paid by pesticide manufacturers and amounts
appropriated by Congress, and it deposits those monies in the Pesticides Reregistration
and Expedited Processing Fund and the Pesticide Registration Fund. The OIG annually
audits the financial statements for both funds, and for the FY 2017 statements for both
funds we rendered modified opinions, meaning that, except for the possible effects of the
agency's inability to support payroll accruals and related expenses for the funds in
FY 2016, the FY 2017 statements were fairly presented. For the FY 2016 statements for
both funds, we rendered disclaimers of opinion due to the aforementioned issues with
payroll accruals and related expenses. Also, for the Pesticide Registration Fund, we found
an internal control weakness regarding the EPA not retaining supporting documentation
for $369,779 in transactions. We did not find any internal control weaknesses for the
other fund. The reports we issued are as follows:
•	Fiscal Years 2017 and 2016 (Restated) Financial Statements for the
Pesticides Reregistration and Expedited Processing Fund
Report No. 19-F-0214. issued June 28, 2019
•	Fiscal Years 2017 and 2016 (Restated) Financial Statements for the
Pesticide Registration Fund
Report No. 19-F-0215. issued June 28, 2019
EPA Complied with Improper Payments Legislation but
Stronger Internal Controls Are Needed
Report No. 19-P-0163, issued May 31, 2019
The EPA complied with the Improper Payments Elimination and Recovery Act of 2010
in that it reported all required information on improper payments, but the EPA can
improve the accuracy and completeness of the information. We believe that the improper
payment amount reported for FY 2018 was understated because our review of
25 payments, totaling $4,418,774, identified an additional $1,912,275 in payments as
improper due to insufficient, or a lack of, documentation. Improving processes for
preventing and detecting improper payments will aid in the better use of funds for
environmental and supporting programs. The agency agreed with our recommended
corrective actions.
23

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Risk Assessment Determines that Travel Card Program Merits an Audit
Next Year Because Internal Controls Not Adequate
Report No. 19-P-0307. issued September 19, 2019
Our annual assessment of the EPA's travel card
program determined that the risk for illegal,
improper and erroneous purchases was high
enough to warrant an audit in FY 2020.
Sufficient oversight of internal controls was not
established and put in place when the EPA
transitioned from the SmartPay2 to SmartPavS
contract on November 30, 2018. The new online
system was not working as intended. This report
contains no recommendations.
|l
SmartPayS United States of America
suspected, call (800) «xx-xx»
w
| 1234 Sb7fl TD12 3M5b
1	mm. 12/31/26
2	JOHN SMITH
Sample government travel card. (Photo
from U.S. General Services Administration)
Corrective Actions and Additional Guidance Have Improved EPA's Fiscal
Responsibility over Superfund Interagency Agreements
Report No. 19-P-0146, issued May 7, 2019
The EPA improved its fiscal management over its more than $3 billion in active
interagency agreements with the U .S. Army Corps of Engineers for Superfund work. The
agency completed all corrective actions in response to a 2007 audit of these interagency
agreements. The EPA also issued additional guidance regarding the management of
interagency agreements. Further, the EPA adequately documents justifications when
awarding projects to the Army Corps of Engineers and effectively monitors these projects
in terms of time, cost and outcomes. As a result, we made no recommendations.
FISCAL
RESPONSIBILITY
TIME
IMPROVED
COST s/
OUTCOMES
By implementing effective controls over time, costs
and outcomes, the EPA improved its fiscal
responsibility over U.S. Army Corps of Engineers
interagency agreements. (EPA OIG image)
24

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Investigations
Management Implication Report
Management Implication Report Concerning the EPA's Process for Certifying
that EPA Attorneys Possess an Active Bar Membership
Issued June 20, 2019
We issued a management implication report for a control issue we identified concerning
how an Senior Executive Service (SES)-level EPA attorney had for decades self-
represented as having an active law license when the attorney's license in fact had been
suspended. Specifically, the attorney was hired by the EPA in 1979 and worked until
retirement in 2017 even though the person's law license was suspended in 1985 and
never reinstated. We determined that this happened because the annual self-certification
process used by the EPA to ensure licensing compliance allowed attorneys to self-certify
maintenance of an active law license by simply filling out a form. We notified the agency
of this control weakness so that it could take whatever steps it deems necessary to correct
the issue. In July 2019, in response to the OIG's report, the EPA issued new guidance
addressing its process for annual attorney self-certification of active law licenses, which
includes enhanced verification procedures.
Significant Investigations
Settlement Made with Contractor After Fraud Allegations
On August 15, 2019, ManTech Advanced Systems International Inc., a federal contractor,
agreed to pay the U.S. government $750,000 in a civil settlement, including $325,000
returned to the EPA. The settlement was reached in a coordinated effort between the
U.S. Attorney's Office for the Eastern District of Virginia and the OIG. ManTech was
awarded a subcontract on an EPA contract that required certain tasks be performed only
by individuals with a Top-Secret clearance. ManTech represented the principal project
manager for the contract as having the required Top-Secret clearance. However, when the
ManTech project manager's clearance was revoked, ManTech failed to inform the EPA.
In a proposal to extend ManTech's contract with the EPA, ManTech again represented
that the same project manager had a Top-Secret clearance when the person did not.
ManTech is in the process of implementing changes in its processes and controls to
ensure that such a failure does not occur again. These include personnel changes, the
creation of several new security-related roles, new or revised security protocols, security-
related training, and consultation with industry experts on security matters.
25

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Penalty Levied Against EPA Recipient for Lab Fraud
On August 16, 2019, the Arizona Department of Health Services levied a $275,000 civil
penalty against Xenco Laboratories, an environmental testing lab headquartered in
Stafford, Texas. The Arizona Department of Health Services is an EPA grant recipient
that licensed Xenco to perform drinking water testing in Arizona. The lab violated
acceptable professional practices established by the EPA. Xenco manipulated quality
control checks involving instrument calibration verification samples, quantitation limits,
and recovery of surrogate compounds to make the analyses appear correct and reliable.
In addition to the financial penalty, the Arizona Department of Health Services required
Xenco to conduct quarterly third-party audits for up to 18 months, as well as send a letter
to all the laboratory's Arizona customers who potentially had data affected by the
inappropriate laboratory practices.
The investigation leading to these outcomes was conducted jointly by the EPA OIG, the
Arizona Department of Health Services and the Arizona Office of the Attorney General.
Tribal Council Director Debarred After Being Sentenced for Theft
On September 13, 2019, David McGraw, former accountant and finance director for the
Yukon River Inter-Tribal Watershed Council in Anchorage, Alaska, and his company,
DKM Enterprises, LLC, were debarred for 8 years from participation in federal
procurement and non-procurement programs. Earlier in 2019, McGraw had been
sentenced in the U.S. District Court for the District of Alaska to 18 months"
imprisonment and ordered to pay $40,604 in restitution for theft and filing a false tax
return. In 2018, McGraw was indicted for theft and money laundering associated with
work he performed while employed by the council. Each fiscal year from 2010 through
2014, the council was awarded federal grant money in excess of $1 million, and McGraw
willfully misapplied a total of about $315,000 of these funds for his personal benefit.
The investigation leading to these outcomes was conducted jointly by the EPA OIG, the
Federal Bureau of Investigation, the National Science Foundation OIG and the Internal
Revenue Service.
Man Sentenced to Jail for Disassembling Bridge Which Damaged
EPA Water Monitors
On September 5, 2019, Kenneth Morrison of Indiana was sentenced in the U.S. District
Court for the Northern District of Indiana to 2 years" imprisonment, followed by 2 years
of supervised release, and ordered to pay over $54,000 in restitution. In 2015, Morrison
was arrested by the Indiana Department of Natural Resources Police Department for
illegally disassembling a city rail bridge and stealing the scrap metal for resale. The
disassembly of the bridge resulted in the collapse of the bridge into the Grand Calumet
26

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
River. The OIG investigation found that, as a result of the bridge collapse, several EPA-
owned water monitors were damaged. In addition, the debris removal process delayed a
$12 million EPA dredging project. In 2018, Morrison was convicted of interstate
transportation of stolen goods.
This investigation was conducted jointly with the EPA Criminal Investigation Division.
Former Contractor Pleads Guilty to Charge Related to Theft
On August 12, 2019, a former EPA contractor pleaded guilty in the Superior Court of the
District of Columbia to a charge relating to the theft of multiple EPA-owned laptop
computers. The theft of the laptops was discovered when inconsistencies were found
during an inventory check. The individual was sentenced to 90 days in jail (which was
suspended) and supervised release for 5 years and was ordered to pay $15,100 in
restitution.
This investigation was conducted jointly by the EPA OIG and the U.S. Department of
Homeland Security's Federal Protective Service.
Former Contractor Pleads Guilty to Theft of Laptop
On May 24, 2019, a former EPA contractor pleaded guilty in the Superior Court for
Pierce County, Washington, to the theft of an EPA laptop computer. The individual was
subsequently sentenced to 304 days of suspended jail time, 30 days of home detention,
30 days of community service, 2 years of supervised release, and $1,233 in restitution to
the EPA. The laptop was reported missing from an EPA storage room following an
inventory of equipment.
Reports of Investigation—Employee integrity
A Report of Investigation documents the facts and findings of an OIG investigation and
generally involves an employee integrity matter. When the OIG's Office of Investigations
issues a Report of Investigation that has at least one "supported" allegation, it requests
that the entity receiving the report—whether it is an office within the EPA or the CSB, or
an office within the OIG—provide a notification to the OIG within 60 days regarding the
administrative action taken or proposed to be taken in the matter. This section provides
information on how many Reports of Investigation with at least one supported allegation
were issued to the agency and/or to the OIG, and for how many of those Reports of
Investigation a response was not received within a 60-day period.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
For the reporting period ending September 30, 2019, the Office of Investigations issued
six Reports of Investigation and received no responses outside the 60-day window for the
six that were received:
Agency and OIG Reports of Investigation
No. of Reports of
Agency

OIG

Investigation issued
response*
Awaiting
response*

during reporting period
received after
agency
received
Awaiting OIG
with findings
60 days
response
after 60 days
response
6
0
0
0
0
* Agency or the OIG will or will not take an action, or will conduct a supplemental investigation.
28

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Hotline Activities
The Inspector General Act of 1978, as amended, requires each OIG to manage a hotline.
The purpose of the hotline is to receive complaints of fraud, waste or abuse in EPA and
CSB programs and operations, including mismanagement or violations of law, rules or
regulations by agency employees or program participants. The hotline also encourages
suggestions for assessing the efficiency and effectiveness of agency programs.
Complaints and requests may be submitted by anyone, including EPA and CSB
employees, participants in EPA and CSB programs, Congress, organizations, and the
public. As a result of these contacts, the OIG may conduct audits, evaluations and
investigations. Details on our work during the semiannual reporting period follow.
Audit Reports Initiated via OIG Hotline
EPA Region 5 Needs to Act on Transfer Request and Petition Regarding
Ohio's Concentrated Animal Feeding Operation Permit Program
Report No. 19-N-0154. issued May 15, 2019
Our review regarding a hotline complaint found that EPA Region 5 had not made a
decision regarding a request by Ohio to transfer the Concentrated Animal Feeding
Operation portion of its National Pollutant Discharge Elimination System permit program
from the Ohio Environmental Protection Agency to the Ohio
Department of Agriculture. The complainants also petitioned
EPA Region 5 to withdraw the Concentrated Animal Feeding
Operation program from the Ohio Environmental Protection
Agency's authority. Although EPA Region 5 began an
informal investigation of allegations raised in a 2011 citizen
petition to commence withdrawal proceedings, more than
8 years after the 2011 submission it still had not made a
determination about the petition. Region 5 officials began to
take corrective actions on our recommendations regarding
making decisions.
EPA Overpaid Invoices Due to Insufficient Contract Management Controls
Report No, 19-P-0157. issued May 20, 2019
In response to an anonymous hotline complaint, we sought to determine whether the
EPA's administration of Contract No. EP-W-11-019, Task Order 12, had effective
controls. Although the contract, for information technology services, ended in 2017, it
was still open and payments were being made. We found that management controls were
insufficient. Required contractor reports were not finalized, there were no official
A dairy Concentrated Animal Feeding
Operation. (EPA OIG photo)
29

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
modifications for some changes, and periodic invoice reviews were not always
performed. Our limited review noted $5,158 in overbillings. The agency agreed to take
all recommended corrective actions.
EPA Oversight over Enterprise Customer Service Solution Needs Improvement
Report No. 19-P-0278, issued August 19, 2019
As a result of an anonymous hotline complaint, we
looked at how the EPA implemented an Enterprise
Customer Service Solution/Customer Relationship
Management system used to host its Frequently
Asked Questions and inquiries for the agency's
public website. We found that the EPA did not
implement key oversight activities, including
documenting the agency's business justification,
having the required plans, and doing a user satisfaction survey. Further, the system was
not classified in the correct information technology investment category. Of our six
recommendations, the agency agreed to take sufficient corrective actions for four of
them, but the other two were unresolved.
In addition to the reports in this section above, two congressionally requested reports
included in our "Congressional Activities" section also involved hotline complaints:
•	Actions Needed to Strengthen Controls over the EPA Administrator's and
Associated Staff s Travel, Report No. 19-N-0155. issued May 16, 2019.
•	Follow-Up Audit: EPA Took Steps to Improve Records Management,
Report No. 19-P-0283. issued August 27, 2019.
Significant Investigations Initiated via OIG Hotline
Former Employee Debarred Related to Child Pornography Charges
On July 11, 2019, a former EPA employee was debarred for 10 years from participation
in federal procurement and non-procurement programs for obstructing an OIG child
pornography investigation. In 2018, the former employee pleaded guilty to the charge and
was sentenced in the U.S. District Court for the Northern District of Illinois to 38 months
in prison followed by 3 years of supervised release. In 2016, the former employee was
indicted for possession of child pornography, conversion of government property and
obstructing justice. The EPA OIG investigation determined that the former employee had
downloaded unauthorized software onto the employee's EPA-issued laptop and deleted
files relevant to the investigation.
A Customer Relationship
Management application
maintains a centralized view of
all interactions and improves the
outreach experience to those
contacting and engaging with the
EPA through various methods.
30

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Hotline Statistics
The OIG Hotline receives complaints of fraud, waste, abuse, mismanagement and
misconduct in EPA and CSB programs and operations. The figures below detail the
number and type of complaints that the hotline received and referred for review by OIG
investigation and audit staff, EPA program offices, and other government agencies during
the second half of FY 2019 and the complete FY 2019 period.
450
400
350
300
250
200
150
100
50
0
Number of Hotline Complaints Received and Referred
392









185






















Semiannual Period (April 1, 2019 -
September 30, 2019)
Annual Period (October 1, 2018 -
September 30, 2019)
Number of Hotline Complaints Referred
(October 1, 2018 - September 30, 2019)
350
300
250
200
150
100
50
0
293












108










17
OIG Offices
EPA Program Offices
Other Federal and State/Local
Agencies
Note: Hotline complaints may be referred to more than one entity, so the total number of referrals
may be higher than the total number of complaints.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Categories of Hotline Complaints Referred Within the OIG
Whistleblower-Related	2
Unethical Conduct	4
Threats and Workplace Violence	17
Stolen Credentials and/or Government Equipment	10
Programmatic and Operational Issues	17
Misuse of Funds/Credit Card	2
Mismanagement	14
Misconduct	3
Lost Credentials and/or Government Equipment	7
Lab Fraud	14
Impersonation	3
Harassment	8
22
Fraud
Falsifying Official Documents
False Statements
Environmental - Water Pollution Control Act
Environmental - Toxic Substances Control Act
Environmental - Safe Drinking Water Act
Environmental - Resource Conservation Recovery Act ¦ 1
Environmental - Other	25
Environmental - Clean Air Act	5
Employee Time/Attendance	2
Employee Misconduct	25
Employee Ethics	6
Employee Alcohol/Drug Use/Sales ¦ 1
Employee - Personnel Action Fraud	3
Employee - Other	10
Contract Improprieties - Other	3
Contract Fraud	12
Conflict of Interest	13
Computer Crimes
Computer - Security
Abuse of Power	17
0	5	10	15	20	25	30
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Hotline Confidentiality
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 an investigation, audit or evaluation. 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 U.S. mail.
EPA OIG Hotline


To report fraud, waste or abuse, contact us through one of the following methods:
email:
OIG Hotline(3).epa.qov
write:
EPA OIG Hotline
phone:
888-546-8740 or 202-566-2476

1200 Pennsylvania Avenue, NW
fax:
202-566-0814

Mail Code 2431T
online:
EPA OIG Hotline

Washington, DC 20460
EPA Whistleblower Protection Coordinator


To contact the EPA Whistleblower Coordinator:


phone:
202-566-1513
online:
EPA Whistleblower Protection
33

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Other Activities
Quality Assurance Review of EPA OIG Audit Assignments Completed in
Fiscal Year 2018
Report No. 19-N-0167, issued June 4, 2019
The EPA OIG complied with generally accepted government auditing standards for audit
assignments completed in FY 2018. However, the OIG needs to improve how it estimates
and approves project time frames and cost estimates, which were issues identified in the
prior year's Quality Assurance Review. When reports are not timely and current, their
relevance and usefulness can be diminished. Also, the OIG needs to maintain personal
impairment forms, which are evidence of its auditors" independence, for record-keeping
purposes. OIG corrective actions included changes to our internal Project Management
Handbook and more training for audit staff.
34

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
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.
Fiscal Year 2019 U.S. Chemical Safety and Hazard Investigation Board
Management Challenges
Report No. 19-N-0156, issued May 20, 2019
The five-member CSB had two vacancies as of May 2019, and if no new members are
appointed by August 2020 the board's governing body will have no members and thus
the CSB may not be able to complete its mission or meet its goals. The terms of the three
current board members are set to expire in December 2019, February 2020 and August
2020. Because it took an average of 10.5 months to confirm the three current board
members, action needs to be taken soon by the President and Senate to appoint and
confirm new members. We noted an additional challenge in that the CSB has not
sufficiently developed guidance on board member responsibilities.
CSB Audit Reports
CSB Still Needs to Improve Its "Incident Response" and "Identity and Access
Management" Information Security Functions
Report No. 19-P-0147, issued May 9, 2019
We assessed the maturity of the CSB's information security program and determined that
policies, procedures and strategies were established at a "Defined" level overall, meaning
they were formalized and documented but not consistently implemented. However, we
noted that the CSB's information security program needed improvements in Incident
Response, where it had neither identified nor defined its processes for incident handling,
and in Identity and Access Management, where it did not fully define or implement
processes for the use of Personal Identity Verification cards for physical and logical

35

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
access. As a result, unauthorized access to agency systems could occur. The agency
agreed to take the recommended corrective actions.
CSB Purchase Card Program at Low Risk for Unauthorized Purchases
During Fiscal Year 2018
Report No. 19-P-0245, issued July 26, 2019
The CSB's purchase card program, through which the agency spent $326,859 in
FY 2018, is at low risk for unauthorized purchases. We reviewed a sample of 26 purchase
card transactions and one convenience check transaction, and found that all were
legitimate and adequately supported. We noted that in May 2018 the CSB increased its
micro-purchase threshold, as allowed by statute, to $10,000, and we advised the CSB to
update Board Order 24 to reflect that policy change.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
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 September 30, 2019, involved follow-up
on prior OIG reports.
Report no.
Report Title
Date
19-P-0307
Risk Assessment Determines that Travel
Card Program Merits an Audit Next Year
Because Internal Controls Not Adequate
September 19, 2019
19-P-0283
Follow-Up Audit: EPA Took Steps to Improve
Records Management
August 27, 2019
19-P-0278
EPA Oversight over Enterprise Customer
Service Solution Needs Improvement
August 19, 2019
19-P-0245
CSB Purchase Card Program at Low Risk
for Unauthorized Purchases During Fiscal
Year 2018
July 26, 2019
19-F-0215
Fiscal Years 2017 and 2016 (Restated)
Financial Statements for the Pesticide
Registration Fund
June 28,2019
19-F-0214
Fiscal Years 2017 and 2016 (Restated)
Financial Statements for the Pesticides
Reregistration and Expedited Processing
Fund
June 28,2019
19-P-0168
EPA Demonstrates Effective Controls for Its
On-Road Heavy-Duty Vehicle Compliance
Program; Further Improvements Could Be
Made
June 3, 2019
19-P-0163
EPA Complied with Improper Payments
Legislation but Stronger Internal Controls
Are Needed
May 31, 2019
19-P-0158
Insufficient Practices for Managing Known
Security Weaknesses and System Settings
Weaken EPA's Ability to Combat Cyber
Threats
May 21, 2019
19-P-0147
CSB Still Needs to Improve Its "Incident
Response" and "Identity and Access
Management" Information Security Functions
May 9, 2019
19-P-0146
Corrective Actions and Additional Guidance
Have Improved EPA's Fiscal Responsibility
over Superfund Interagency Agreements
May 7, 2019
37

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
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 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 to be
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 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 memorandums to the EPA for audit resolution
and corrective action. These memorandums recommend that EPA action officials confirm
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. The following is a summary of single audit reporting actions
during the semiannual reporting period ending September 30, 2019.
Summary of single audit activity in FY 2019

April 1, 2019-
September 30, 2019
Total for FY 2019
No. of single audit memorandums issued to EPA
185
283
No. of single audit findings reported to EPA
466
686
Questioned costs reported to EPA
$611,733
$710,723
No. of quality reviews of single audits reports
done by OIG
3
4
Source: EPA OIG analysis.
The OIG also provides technical assistance and advice to the EPA, single auditors and
others involved with the single audit process.
38

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Agency Best Practices
During this semiannual reporting period, OIG reports highlighted agency best practices
that have potential value and applicability to other components in the EPA or elsewhere:
•	The EPA oversees its Managed Pollinator Protection Plan by helping states
develop, implement and measure their own plans. The EPA worked with a
subcommittee of the American Pesticide Control Officials Committee to provide
guidance and outline best management practices for Managed Pollinator
Protection Plan development. The subcommittee's Final Guidance for State Lead
Agencies for the Development and Implementation of Managed Pollinator
Protection Plans includes numerous "critical elements" for states to consider
while developing their plans. (Report No. 19-P-0275)
•	Our report on EPA Region 6's response to Hurricane Harvey noted that regional
staff from the Office of Communities, Tribes, and Environmental Assessment
conducted outreach to communities that may be vulnerable to future natural
disasters. For instance, regional staff disseminated materials that described how to
disinfect drinking water. We also noted that Region 6 held an environmental
justice forum that included presentations from federal, state and local officials, and
during these discussions Region 6 identified four recommendations for improving
environmental justice outreach during disasters. (Report No. 19-P-0236)
•	During our audit of the EPA Office of Research and Development's support of
regional research programs, we noted several effective practices applied by some
Regional Science Councils that could be applied in other regions. For example,
the Region 4 council's charter includes a concise, one-page table describing each
regional research program. The Region 7 council includes state and tribal
partners. The Region 8 council has a robust intranet site and extensive resources,
such as a form that helps connect regional scientists with headquarters staff doing
similar work. (Report No. 19-P-0123)
In addition to these agency best practices, during our audit on whether the EPA
adequately ensures that public drinking water systems notify the public per regulations
authorized by the Safe Drinking Water Act, we found several promising practices applied
by states. Specifically:
•	Pennsylvania requires public water systems to consult with state officials within
1 hour of learning of a situation that will require public notice within 24 hours;
this early coordination improves communication to consumers on actions they
need to take.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
•	In Colorado, public water systems can use an online tool to generate notices that
comply with public notice regulations. Colorado also created and posted online a
video that assists public water systems in using this tool.
•	The state of Washington translates four basic drinking water messages into
27 languages. By offering these translations online, water systems in the state of
Washington and across the country can readily use the statements in their public
notices, increasing the likelihood that more of their consumers will receive
important information about the quality of drinking water.
By applying these promising practices, other states can better protect their residents
against human health risks presented by unsafe levels of contamination in drinking water.
(Report No. 19-P-0318)
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Statistical Data
Profile of Activities and Results
OIG audits


($ in millions)


April 1,2019, to
FY
September 30, 2019
2019
Questioned costs
$0,129
$0,129
Potential monetary benefits *
$1,912
$2,298
Audit reports issued by OIG **
27
35
* Section 5(a)(22) requires detailed descriptions of the particular
circumstances of each inspection, evaluation and audit conducted
by the OIG that was closed and not publicly disclosed. There were
no instances of inspections, evaluations or audits that were closed
and not publicly disclosed during the semiannual period ending
September 30, 2019. Investigations that were closed but not
previously publicly disclosed are found in Appendix 4.
** Only includes performance and financial audits conducted in
accordance with generally accepted government auditing
standards. Appendix 1 lists all reports issued.
Investigative operations
($ in millions)

April 1,2019, to
September 30, 2019
FY 2019

EPA OIG
only
Joint*
Total
EPA OIG
only
Joint*
Total
Total fines and recoveries
$0,017
$0,329
$0,346
$0,425
$0,370
$0,795
Cost savings
$0,003
$0,112
$0,115
$0,417
$0,112
$0,529
Civil settlements
$0,750
$0,000
$0,750
$0,750
$112,500
$113,250
Cases opened during period
42
8
50
82
14
96
Cases closed during period
36
13
49
104
28
132
Indictments/informations/complaints
2
0
2
3
2
5
Convictions
3
1
4
3
3
6
Civil judgments/settlements/filings
1
0
1
1
2
3
* With one or more federal agencies.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Audit Report Resolution
Table 1: OIG-issued reports with questioned costs for semiannual period ending
September 30, 2019 ($ in thousands)
Report category
No. of
reports
Questioned
costs *
Unsupported
costs
A.
For which no management decision was made by
April 1, 2019 **
7
$3,208
$3,037
B.
New reports issued during period
33
129
0
Subtotals (A + B)
40
$3,337
$3,037
C.
For which a management decision was made during
the reporting period:
32


(i) Dollar value of disallowed costs

5
0

(ii) Dollar value of costs not disallowed

0
0
D.
For which no management decision was made by
September 30, 2019
8
$3,332
$3,037
* Questioned costs include unsupported costs.
** Any difference in number of reports and amounts of questioned costs between this report and our previous
semiannual report results from corrections made to data in our audit tracking system.
Table 2: OIG-issued reports with recommendations that funds be put to better use for
semiannual period ending September 30, 2019 ($ in thousands)
Report category
No. of
reports
Dollar
value
A. For which no management decision was made by April 1, 2019 *
7
$3,208
B. New reports issued during the reporting period
33
2,041
Subtotals (A + B)
40
$5,249
C. For which a management decision was made during the reporting period:
32

(i) Dollar value of recommendations from reports that were
agreed to by management
8
$1,917
(ii) Dollar value of recommendations from reports that were
not agreed to by management
0
D. For which no management decision was made by September 30, 2019
$3,332
* 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.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Summary of Investigative Results
Summary of investigative activity during reporting period
Cases open as of April 1, 2019*
141
Cases opened during period
50
Cases closed during period
49
Cases open as of September 30, 2019
142
Complaints open as of April 1, 2019
25
Complaints opened during period
55
Complaints closed during period
59
Complaints open as of September 30, 2019
21
* Adjusted from prior period.
Results of prosecutive actions

EPA OIG only
Joint *
Total
Criminal indictments/informations/complaints **
2
0
2
Convictions
3
1
4
Civil judgments/settlements/filings
1
0
1
Criminal fines and recoveries
$17,093
$54,445
$71,538
Civil recoveries
$750,000
$0
$750,000
Prison time
0 months
24 months
24 months
Prison time suspended
100 months
0 months
100 months
Home detention
30 months
0 months
30 months
Probation
120 months
24 months
144 months
Community service
340 hours
0 hours
340 hours
* With one or more federal agencies.
** Sealed indictments are not included in this category.
Administrative actions

EPA OIG only
Joint *
Total
Suspensions
2
8
10
Debarments
4
6
10
Other administrative actions
7
4
11
Total
13
18
31
Administrative recoveries
$0
$275,000
$275,000
Cost savings
$2,856
$111,937
$114,793
* With one or more federal agencies.
43

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Semiannual Report to Congress	April 1,2019—September 30, 2019
Summary of investigative reports issued and referrals for prosecution *
Number of Reports of Investigation issued **
7
Number of persons referred to U.S. Department of Justice for criminal prosecution
32
Number of persons referred to state and local authorities for criminal prosecution
2
Number of criminal indictments and informations resulting from any prior referrals to
prosecutive authorities
2
* Investigative reports are comprised of final, interim and supplemental Reports of Investigation.
** Reports of Investigation issued may differ from the numbers reported in the Reports of Investigation section.
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 as of April 1, 2019
4
7
9
24
9
53
Opened*
2
2
3
10
0
17
Closed*
0
6
9
10
4
29
Pending September 30, 2019 **
6
5
7
26
5
49
* Employee integrity investigations 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 numbers as of September 30, 2019, 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 and below
44

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Appendices
Appendix 1—Reports Issued
Section 5(a)(6) of 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.
Questioned costs
Report no.
Report title
Potential
Date
Ineligible
Unsupported
Unreasonable
monetary
benefits
6/27/19
$0
$0
$0
$0
6/27/19
0
0
0
0

$0
$0
$0
$0
4/8/19
$0
$0
$0
$0
5/15/19
0
0
0
0
5/20/19
0
0
0
0
6/4/19
0
0
0
0
6/27/19
0
0
0
0
7/15/19





$0
$0
$0
$0
4/18/19
$0
$0
$0
$0
5/7/19
0
0
0
0
5/9/19
0
0
0
0
5/16/19
0
0
123,942
0
5/20/19
5/21/19
5,158
0
0
0
0
0
0
0
5/31/19
0
0
0
1,912,275
6/3/19
0
0
0
0
6/21/19
0
0
0
0
6/24/19
0
0
0
0
FINANCIAL AUDITS IN ACCORDANCE WITH
GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS
19-F-0214 Fiscal Years 2017 and 2016 (Restated) Financial Statements for the
Pesticides Reregistration and Expedited Processing Fund
19-F-0215 Fiscal Years 2017 and 2016 (Restated) Financial Statements for the
Pesticide Registration Fund
SUBTOTAL = 2
PROJECTS NOT IN ACCORDANCE WITH
GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS
19-N-0115 Management Alert: Certain Toxic Release Inventory Data Disclosed to the Public
May Be Inaccurate
19-N-0154 EPA Region 5 Needs to Act on Transfer Request and Petition Regarding Ohio's
Concentrated Animal Feeding Operation Permit Program
19-N-0156 Fiscal Year 2019 U.S. Chemical Safety and Hazard Investigation Board
Management Challenges
19-N-0167 Quality Assurance Review of EPA OIG Audit Assignments Completed in Fiscal
Year 2018
19-N-0217 Certain Risk Communication Information for Community Not Up to Date for
Amphenol/Franklin Power Products Site in Franklin, Indiana
19-N-0235 FY 2019 EPA Management Challenges
SUBTOTAL = 6
PERFORMANCE AUDITS IN ACCORDANCE WITH
GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS
19-P-0123 Regional Research Programs Address Agency Needs but Could Benefit from
Enhanced Project Tracking
19-P-0146 Corrective Actions and Additional Guidance Have Improved EPA's
Fiscal Responsibility over Superfund Interagency Agreements
19-P-0147 CSB Still Needs to Improve Its Incident Response" and Identity and Access
Management" Information Security Functions
19-P-0155 Actions Needed to Strengthen Controls over the EPA Administrator's and
Associated Staff's Travel
19-P-0157 EPA Overpaid Invoices Due to Insufficient Contract Management Controls
19-P-0158 Insufficient Practices for Managing Known Security Weaknesses and
System Settings Weaken EPA's Ability to Combat Cyber Threats
19-P-0163 EPA Complied with Improper Payments Legislation but Stronger
Internal Controls Are Needed
19-P-0168 EPA Demonstrates Effective Controls for Its On-Road Heavy-Duty Vehicle
Compliance Program; Further Improvements Could Be Made
19-P-0195 Pesticide Registration Fee, Vulnerability Mitigation and Database Security
Controls for EPA's FIFRA and PRIA Systems Need Improvement
19-P-0198 EPA Needs to Improve Oversight of the Senior Environmental Employment
Program
45

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Questioned costs	 Potential
monetary
Report no.
Report title
Date
Ineligible
Unsupported
Unreasonable
benefits
19-P-0201
EPA Complied with Applicable Laws and Rules for the July 2017 Superfund Task
6/24/19
0
0
0
0

Force Report but Could Improve Transparency





19-P-0207
EPA Effectively Screens Air Emissions Data from Continuous Monitoring Systems
6/27/19
0
0
0
0

but Could Enhance Verification of System Performance





19-P-0236
EPA Region 6 Quickly Assessed Water Infrastructure after Hurricane Harvey but
7/16/19
0
0
0
0

Can Improve Emergency Outreach to Disadvantaged Communities





19-P-0245
CSB Purchase Card Program at Low Risk for Unauthorized Purchases During
7/26/19
0
0
0
0

Fiscal Year 2018





19-P-0251
More Effective EPA Oversight Is Needed for Particulate Matter Emissions
7/30/19
0
0
0
0

Compliance Testing





19-P-0252
EPA's 2017 Glider Vehicle Testing Complied with Standard Practices
7/31/19
0
0
0
0
19-P-0267
EPA Exceeded the Deregulatory Goals of Executive Order 13771
8/9/19
0
0
0
0
19-P-0275
EPA Needs to Determine Strategies and Level of Support for Overseeing
8/15/19
0
0
0
0

State Managed Pollinator Protection Plans





19-P-0277
EPA Office of Research and Development Needs to Address Barrier to Gathering
8/19/19
0
0
0
0

External Customer Feedback





19-P-0278
EPA Oversight over Enterprise Customer Service Solution Needs Improvement
8/19/19
0
0
0
0
19-P-0279
EPA's Use of Administratively Determined Positions Is Consistent with Its Authority
8/21/19
0
0
0
0

Under the Safe Drinking Water Act





19-P-0283
Follow-Up Audit: EPA Took Steps to Improve Records Management
8/27/19
0
0
0
0
19-P-0302
EPA Not Effectively Implementing the Lead-Based Paint Renovation, Repair and
9/9/19
0
0
0
0

Painting Rule





19-P-0307
Risk Assessment Determines that Travel Card Program Merits an Audit Next Year
9/19/19
0
0
0
0

Because Internal Controls Not Adequate





19-P-0318
EPA Must Improve Oversight of Notice to the Public on Drinking Water Risks to
9/25/19
0
0
0
0

Better Protect Human Health






SUBTOTAL = 25

$5,158
$0
$123,942
$1,912,275
I
TOTAL REPORTS ISSUED = 33

$5,158
$0
$123,942
$1,912,275
46

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Appendix 2—Reports Issued Without Management Decisions
For Reporting Period Ended September 30, 2019
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. There were no reports for which we did not receive a
response within 60 days during 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 provide the resolution status of management decisions
not made as of September 30, 2019, which the OIG desires to resolve as soon as possible.
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
has not been widely used in the approximately 9 months after it was publicly released. Without metrics to measure
performance, it is unclear whether C-FERST 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. On October 11,
2018, the Office of Research and Development advised the OIG that, based on an internal review of C-FERST, future
development and use of C-FERST was ended, and unique aspects of C-FERST were incorporated into other EPA
tools. One recommendation—for the Deputy Administrator to examine all EPA web-based screening and mapping
tools to ensure the need for each tool and to avoid potential overlap, duplication and waste—remains unresolved.
Resolution Status: The agency and the OIG continue to have discussions regarding the unresolved
recommendation.
Office of the Chief of Financial Officer; Office of Enforcement and Compliance Assurance
Report No. 18-P-0239. EPA Asserts Statutory Law Enforcement Authority to Protect Its Administrator
but Lacks Procedures to Assess Threats and Identify the Proper Level of Protection, September 4, 2018
Summary: This report made recommendations to two offices that remain unresolved:
•	Office of the Chief Financial Officer. We notified the agency of an internal control weakness that resulted in
an authorized payment for pay above the annual pay limit for an agent. We issued four recommendations to
improve internal controls, determine whether similar overpayments have been made, and recover any
overpayments. The Office of the Chief Financial Officer submitted corrective actions; however, we found
some actions to be incomplete. Two of these recommendations therefore remain unresolved.
Resolution Status: The agency provided a response on October 4, 2019, which the OIG is reviewing.
•	Office of Enforcement and Compliance Assurance. We found that the Protective Service Detail for the
EPA Administrator had no approved standard operating procedures to address the level of protection
required for the Administrator or how those services were to be provided. As a result, the detail incurred over
$3.5 million in costs from February 1, 2017, through December 31, 2017, for Administrator Scott Pruitt—
an increase of over 110 percent compared to the prior period's costs of $1.6 million for the previous
47

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Administrator—without documented justification. We also found that agents worked overtime without proper
justification, resulting in improper payments. We recommended that the EPA implement new policies,
procedures and/or guidance for Protective Service Detail operations and agents; regularly complete a threat
analysis to identify the proper protection required for the Administrator; and identify and report any improper
payments to the Office of the Chief Financial Officer. Of the seven recommendations issued, five remain
unresolved.
Resolution Status: The agency provided a response on August 29, 2019, which is currently under
review.
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.
Resolution Status: 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 September 30, 2019 = 3
48

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
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 2008 to
September 30, 2018, in 52 OIG audit reports.
There are a total of 77 current and unimplemented recommendations for the EPA with total potential monetary
benefits of approximately $68 million, none of which 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 was one CSB recommendation with $0,349 million of sustained monetary benefits.
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:
DA	Deputy Administrator (within the Office of the Administrator)
OAR	Office of Air and Radiation
OCFO	Office of the Chief Financial Officer
OCSPP	Office of Chemical Safety and Pollution Prevention
OECA	Office of Enforcement and Compliance Assurance
OLEM	Office of Land and Emergency Management
OMS1	Office of Mission Support
OP	Office of Policy (within the Office of the Administrator)
ORD	Office of Research and Development
OW	Office of Water
Region 6
Region 9
1 Effective November 26, 2018, the former Office of Environmental Information and Office of Administration and
Resources Management were merged into the new Office of Mission Support. In this appendix, any
recommendations originally issued to the former offices will be listed as under the purview of the new office.
49

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Semiannual Report to Congress	April 1,2019—September 30, 2019
EPA Reports with Unimplemented Recommendations
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)
Management
and
Operations
EPA's Water Infrastructure
Finance and Innovation
Act Program Needs
Additional Internal
Controls
19-P-0045
12/14/18
OMS
4. Test and assess the implemented Water
Infrastructure Finance and Innovation Act
SharePoint system access controls to
determine whether the controls are
functioning as intended and comply with
federal requirements and the EPA's
information technology security program.
3/30/19


Management
and
Operations
EPA's Fiscal Years 2018
and 2017 Consolidated
Financial Statements
19-F-0003
11/14/18
OMS
14: Implement controls to enforce the
required verification of individuals' identity
every time individuals enter the computer
rooms.
15. Perform a review of system
requirements and evaluate the suitability of
existing technology to replace or implement
updates to the computer room's surveillance
system and generators. Update or replace, if
warranted, the equipment based
3/31/20
1/15/22


Environmental
Contamination
and Cleanup
EPA Unable to Assess the
Impact of Hundreds of
Unregulated Pollutants in
Land-Applied Biosolids on
Human Health and the
Environment
19-P-0002
11/15/18
OW
OW
OW
OW
OW
3.	Complete development of the probabilistic
risk assessment tool and screening tool for
biosolids land application scenarios.
4.	Develop and implement a plan to obtain
the additional data needed to complete risk
assessments and finalize safety
determinations on the 352 identified
pollutants in biosolids and promulgate
regulations as needed.
6. Publish guidance on the methods for the
biosolids pathogen alternatives 3 and 4.
8. Issue updated and consistent guidance on
biosolids fecal coliform sampling practices.
12. Conduct regular biosolids training and
conference calls or meetings for regional
and state staff and wastewater treatment
operators to improve consistency in rule
interpretation and aid in knowledge transfer.
3/31/19
12/31/22
12/31/20
12/31/20
12/31/19


Management
and
Operations
EPA Law Enforcement
Availability Pay Properly
Certified but Controls over
Process Could Be
Improved
19-P-0001
11/6/18
OECA
1.	Enforce compliance by the investigators
to submit, and the supervisors to approve,
the monthly activity reports supporting Law
Enforcement Availability Pay within the
required timeframes in the Monthly Activity
Reporting System Purpose, Requirements
and Procedures Manual.
2.	Implement controls to improve timeliness
of the annual certification process for Law
Enforcement Availability Pay.
10/1/19
10/1/19
4/1/20
4/1/20

50

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)
Management
and
Operations
Management Alert - EPA's
Incident Tracking System
Lacks Required Controls
to Protect Personal
Information
18-P-0298
9/28/18
OMS
1. Develop and implement a strategy that
protects the confidentiality of personally
identifiable information and sensitive
personally identifiable information, as
required by federal and EPA privacy and
password guidance, for incident tickets in
the current incident tracking system.
9/30/18
12/31/19

Air Quality
Collecting Additional
Performance Data from
States Would Help EPA
Better Assess the
Effectiveness of Vehicle
Inspection and
Maintenance Programs
18-P-0283
9/25/18
OAR
3. Revise the vehicle inspection and
maintenance rule to remove the cross
reference to Title 40 § 51.353(b)(1) of the
Code of Federal Regulations and provide
defined evaluation methodology guidance to
enable states to quantify emission
reductions.
5. Develop and implement guidance on the
calculation of individual test statistics in state
reports to provide consistency in state
reports across regions.
7. Issue guidance to address any trends or
common problems identified by the outreach
conducted to states with deficiencies in
program implementation.
6/30/19
6/30/19
3/31/20
12/31/19
12/31/19

Toxics,
Chemical
Safety and
Pesticides
Measures and
Management Controls
Needed to Improve EPA's
Pesticide Emergency
Exemption Process
18-P-0281
9/25/18
OCSPP
1. Develop and implement applicable
outcome-based performance measures to
demonstrate the human health and
environmental effects of the EPA's
emergency exemption decisions.
5.	Develop concise emergency exemption
application guidance that specifies the
minimum requirements of an application
submission and is available on the Office of
Pesticide Programs Section 18 website.
6.	Provide clear guidance to state lead
agencies on how and when they can use
efficacy data from other state lead agencies
to satisfy the emergency exemption
application criteria.
7.	Expand the data presented in the Office of
Pesticide Programs Section 18 database by
considering additional data points, such as
application acreage requested, actual
acreage applied and registration status of
each exempted pesticide.
6/30/20
9/30/20
9/30/20
6/30/20


51

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)
Air Quality
EPA Can Strengthen Its
Process for Revising Air
Quality Dispersion Models
that Predict Impact of
Pollutant Emissions
18-P-0241
9/5/18
OAR
2.	Develop a quality assurance project plan
or equivalent documents describing the
results of systematic planning before
developing a new air quality dispersion
model or undertaking any significant
revisions in the future to existing preferred
air quality dispersion models, which are
codified in Appendix A to Appendix W of 40
CFR Part 51.
3.	Revise the Office of Air Quality Planning
and Standards' Quality Management Plan to
state whether the agency is developing
quality assurance project plans or equivalent
documents to meet EPA Quality System
requirements for developing or revising
preferred air quality dispersion models.
3/31/20
3/31/20
Research and
Laboratories
EPA Needs a
Comprehensive Vision
and Strategy for Citizen
Science that Aligns with Its
Strategic Objectives on
Public Participation
18-P-0240
9/5/18
DA
ORD
1.	Establish a strategic vision and objectives
for managing the use of citizen science that
identifies:
a.	Linkage to the agency's strategic goals,
b.	Roles and responsibilities for
implementation, and
c.	Resources to maintain and build upon
existing agency expertise.
2.	Through appropriate EPA offices, direct
completion of an assessment to identify the
data management requirements for using
citizen science data and an action plan for
addressing those requirements, including
those on sharing and using data, data
format/standards, and data
testing/validation.
3.	Finalize, in coordination with the Office of
Environmental Information and Region 1, the
Draft Quality Assurance Handbook for
Citizen Science, and communicate to
agency staff and citizen science groups the
availability and content of this handbook.
4.	Build capacity for managing the use of
citizen science, and expand awareness of
citizen science resources, by:
a.	Finalizing the checklist on administrative
and legal factors for agency staff to consider
when developing citizen science projects, as
well as identifying and developing any
procedures needed to ensure compliance
with steps in the checklist;
b.	Conducting training and/or marketing on
the EPA's citizen science intranet site for
program and regional staff in developing
projects; and
c.	Finalizing and distributing materials
highlighting project successes and how the
EPA has used results of its investment in
citizen science
12/31/20
12/31/20
12/31/20
12/31/20
52

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)
Management
and
Operations
EPA Asserts Statutory
Law Enforcement
Authority to Protect Its
Administrator but Lacks
Procedures to Assess
Threats and Identify the
Proper Level of Protection
18-P-0239
9/4/2018
OECA
2. Implement the Office of General Counsel
opinion through new policies, procedures
and/or guidance that defines the amount of
time agents must spend on investigating
environmental crimes and how the time will
be monitored and documented by
supervisors.
9/30/18


Environmental
Contamination
and Cleanup
EPA Needs to Finish
Prioritization and
Resource Allocation
Methodologies for
Abandoned Uranium Mine
Sites on or Near Navajo
Lands
18-P-0233
8/22/2018
Regions
6 and 9
1.	Complete the necessary removal site
evaluations and engineering
evaluations/cost analyses.
2.	Fully develop and implement prioritization
and resource allocation methodologies for
the Tronox abandoned uranium mine sites
on or near Navajo Nation lands.
12/31/20
12/31/21


Management
and
Operations
EPA's Purchase Card and
Convenience Check
Program Controls Are Not
Effective for Preventing
Improper Purchases
18-P-0232
8/20/2018
DA
11. Issue an agencywide memorandum to
emphasize compliance with federal and EPA
requirements for purchase card and
convenience check transactions.
9/30/18
10/31/19
$152
Toxics,
Chemical
Safety and
Pesticides
EPA Completed OIG
Recommendations for the
Presidential Green
Chemistry Challenge
Awards Program but
Lacks Controls over Use
of Unverified Results
18-P-0222
7/20/2018
OCSPP
1. Establish and document internal controls
to prevent the use of Presidential Green
Chemistry Challenge Awards results in
Pollution Prevention Program performance
metrics.
12/31/18
4/15/19

Water Issues
Management Weaknesses
Delayed Response to Flint
Water Crisis
18-P-0221
7/21/2018
OECA
and OW
1. Establish controls to annually verify that
states are monitoring compliance with all
Lead and Copper Rule requirements,
including accurately identifying tier 1
sampling sites and maintaining continuous
corrosion control treatment.
9/30//19
1/31/20



OW
2. Revise the Lead and Copper Rule to
improve the effectiveness of monitoring and
corrosion control treatment protocols.
2/28/19
1/31/20

53

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)
Management
and
Operations
Operational Efficiencies of
EPA's Human Resources
Shared Service Centers
Not Measured
18-P-0207
5/31/18
OMS
1.	Develop a plan that establishes a baseline
to measure the future program operational
efficiency of human resources operations.
2.	Establish a workgroup comprising
regional and program representatives to
develop a baseline level of human resources
support necessary for each program and
regional office.
3.	Review human resources policies,
prioritize the policies requiring updates, and
update the policies with stakeholder input.
2/28/19
6/30/19
12/31/19
7/31//19
8/30/19

Air Quality
EPA Did Not Identify
Volkswagen Emissions
Cheating; Enhanced
Controls Now Provide
Reasonable Assurance of
Fraud Detection
18-P-0181
5/29/18
OAR
1.	Define performance measures to assess
the performance of the EPA's light-duty
vehicle compliance program.
2.	Conduct and document a formal risk
assessment for the EPA's light-duty vehicle
compliance program that prioritizes risks and
links specific control activities to specific
risks. Update the risk assessment on a
scheduled and periodic basis.
3/31/21
12/31/19


Toxics,
Chemical
Safety and
Pesticides
EPA Can Better Manage
State Pesticide
Cooperative Agreements
to More Effectively Use
Funds and Reduce Risk of
Pesticide Misuse
18-P-0079
2/13/18
OECA
1. Develop and implement additional Federal
Insecticide, Fungicide, and Rodenticide Act
guidance to assist Project Officers in
evaluating whether funding is reasonable
given projected work plan tasks.
11/30/19


Management
and
Operations
Self-Insurance for
Companies with Multiple
Cleanup Liabilities
Presents Financial and
Environmental Risks for
EPA and the Public
18-P-0059
12/22/17
OLEM
2. Once the study in Recommendation 1 is
complete, use the information to develop
appropriate risk management actions to
mitigate any identified problems in line with
Agency practices for enterprise risk
management under Office of Management
and Budget Circular A-123, and determine
whether additional controls, such as the
requirement for full disclosure of all self-
insured environmental liabilities over
corporate self-insurance, should be
implemented and if corporate self-insurance
should continue as an option.
9/30/20





3. Update standard operating procedures
and data systems to accommodate the
implemented risk management actions.
9/30/21




OLEM
& OECA
4. Train staff on the implemented risk
management actions.
12/31/22
12/31/21

54

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)


OLEM
OLEM
OLEM
OECA
OECA
5. Develop or update existing standard
operating procedures to outline the Office of
Land and Emergency Management and
Office of Enforcement and Compliance
Assurance roles and responsibilities for
overseeing the validity of Resource
Conservation and Recovery Act and
Superfund financial assurance instruments,
where needed.
6/30/20


6. Develop and include procedures for
checking with other regions for facilities/sites
with multiple self-insured liabilities in the
standard operating procedures created for
Recommendation 5.
6/30/20


7. Develop and include instructions on the
steps to take when an invalid financial
assurance instrument (expired, insufficient in
dollar amount, or not provided) is identified
in the standard operating procedures
created for Recommendation 5 collect
information on the causes of invalid financial
assurance.
6/30/20


8. Train staff on the procedures and
instructions developed for
Recommendations 5 through 7.
9/30/20


9b. Work with EPA regions and states to
identify and implement appropriate metrics,
including metrics to help identify, track, and
correct, on a facility level, where there are
monetary gaps in the amount of Resource
Conservation and Recovery Act financial
assurance required and provided. Develop
and distribute to EPA regions and states
annual reports on these metrics.
12/31/20
12/31/19

10. Develop and distribute to EPA regions
and states annual reports that include
progress on the reduction of financial
assurance that is expired, insufficient and/or
not provided.
9/30/19
12/31/19

Toxics,
Chemical
Safety and
Pesticides
EPA Can Better Reduce
Risks From Illegal
Pesticides by Effectively
Identifying Imports for
Inspection and Sampling
17-P-0412
9/28/17
OECA
1. Establish national compliance monitoring
goals based on assessment and
consideration of available regional
resources.
9/30/19
3/27/20

2. Implement internal controls to monitor and
communicate progress on regional goals.
9/30/19
3/27/20

Toxics,
Chemical
Safety and
Pesticides
EPA Needs to Manage
Pesticide Funds More
Efficiently
17-P-0395
9/18/17
OCSPP
2. Develop and implement a plan to reduce
excess Pesticides Reregistration and
Expedited Processing Fund and Pesticide
Registration Fund balances within the
established target range.
12/31/21


55

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)
Research and
Laboratories
Management Alert: EPA
Should Promptly
Reassess Community Risk
Screening Tool
17-P-0378
9/7/17
ORD
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.
9/30/19


Management
and
Operations
EPA Needs to
Institutionalize Its
"Lean" Program to Reap
Cost and Time Benefits
17-P-0346
7/31/17
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.
6/30/18


2. Develop policies that specify how to plan,
design, oversee and implement Lean
practices within the agency.
6/30/18


3. Develop a process for monitoring, tracking
and measuring quantifiable results, including
cost savings, for Lean projects.
1/31/18


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.
6/30/18


5. Develop and implement a consistent and
standardized Lean training effort for the
EPA's staff.
6/30/18


Air Quality
24. Improved Data and
EPA Oversight Are
Needed to Assure
Compliance With the
Standards for Benzene
Content in Gasoline
17-P-0249
6/8/17
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.
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.
U
6/30/20

56

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)



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.
U
6/30/20

6. Ensure the integrity of benzene credit
trading by developing and implementing a
process to verify that annual average
benzene concentration and total volume
values that facilities input into the trading
database are supported by batch reports.
6/30/20


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.
9/30/20


Water Issues
EPA Needs to Provide
Leadership and Better
Guidance to Improve Fish
Advisory Risk
Communications
17-P-0174
4/12/17
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.
3/31/20


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.
3/30/20


Management
and
Operations
EPA's Fiscal Years 2016
and 2015 Consolidated
Financial Statements
17-F-0046
11/15/16
OCFO
9.	Work with the Compass Financials
service provider to establish controls for
creating and locking administrative
accounts.
10.	Work with the Compass Financials
service provider to develop and implement a
methodology to monitor accounts with
administrative capabilities.
9/30/21
9/30/21


Air Quality
EPA Has Not Met Certain
Statutory Requirements to
Identify Environmental
Impacts of Renewable
Fuel Standard
16-P-0275
8/18/16
OAR
2.	Complete the anti-backsliding study on
the air quality impacts of the Renewable
Fuel Standard as required by the Energy
Independence and Security Act.
3.	Determine whether additional action is
needed to mitigate any adverse air quality
impacts of the Renewable Fuel Standard as
required by the Energy Independence and
Security Act.
9/30/24
9/30/24


57

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)
Management
and
Operations
Audit of EPA's Fiscal
Years 2015 and 2014
Consolidated Financial
Statements
16-F-0040
11/16/15
OCFO
26.	Implement an internal control process for
transferring the management of an
applications user access to the Application
Management Staff.
27.	Conduct an inventory of Office of the
Chief Financial Officer systems managed by
the Application Management Staff and
create or update supporting access
management documentation for each
application.
36. Complete the corrective actions
previously identified in Table 4.
38. Follow the terms in the legal source
documents when recording interest by
ensuring interest is recorded in the system
when a receivable becomes past due, either
through Compass automatic calculations or
manual interest calculations prepared by the
Cincinnati Finance Center.
12/31/17
12/31/17
9/30/16
9/30/16
12/31/18
12/31/18
5/31/18
5/31/18

Management
and
Operations
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
4/17/15
Region 2
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.
9/30/18
9/30/19
3/31/20
$37,000
Management
and
Operations
Internal Controls Needed
to Control Costs of
Emergency and Rapid
Response Services
Contracts, as Exemplified
in Region 6
14-P-0109
2/4/14
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.
9/30/24


Air Quality
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
6/20/13
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.
9/30/20

$2,905
58

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)
Environmental
Contamination
and Cleanup
Improvements Needed in
EPA Training and
Oversight for Risk
Management Program
Inspections
13-P-0178
3/21/13
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.
7/31/14
2/28/19
6/30/22




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.
9/30/14
2/28/20
2/30/23

Environmental
Contamination
and Cleanup
EPA Needs to Further
Improve How It Manages
Its Oil Pollution Prevention
Program
12-P-0253
2/6/12
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.

6/30/20

Water Issues
EPA Should Revise
Outdated or Inconsistent
EPA-State Clean Water
Memoranda of Agreement
10-P-0224
9/14/10
OW
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.
9/28/18
9/30/20

Environmental
Contamination
and Cleanup
Making Better Use of
Stringfellow Superfund
Special Accounts
08-P-0196
7/9/08
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
9/21/23
$27,800

Total
$ 67,857
59

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Semiannual Report to Congress	April 1,2019—September 30, 2019
CSB Reports with Unimplemented Recommendations
Category
Report title,
number
and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
recommended
(in $000s)
Management and
Operations
CSB Needs to Continue
to Improve Agency
Governance and
Operations
16-P-0179
5/23/16
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.
10/20/22

$349

Total
$349
60

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Appendix 4—Closed Investigations Not Previously
Publicly Disclosed
For Reporting Period Ended September 30, 2019
Details on each investigation conducted by the OIG involving both senior and non-senior employees closed
during the semiannual reporting period ending September 30, 2019, 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 Previously Publicly Disclosed
None.
Investigations Involving Senior Employees Not Previously Publicly Disclosed
CASE NUMBER: QI-HQ-2017-CAC-0120
An EPA SES-level employee allegedly provided false information on the Standard Form 86, Questionnaire for
National Security Positions. The investigation found the employee did not include previous employment-related
discipline on the form. The employee resigned after receiving a notice of proposed removal. The case was
referred to and declined for prosecution by the U.S. Department of Justice on September 8, 2017.
CASE NUMBER: QI-HQ-2017-CFR-0085
An EPA GS-15 employee allegedly violated bribery and conflict of interest criminal statutes and EPA scientific
integrity policy regarding an agency classification decision. During the investigation, the OIG received additional
information that other high-level EPA employees may have benefited financially as a result of the decision. The
allegations were not supported.
CASE NUMBER: QI-HQ-2017-CFR-0088
An EPA GS-15 employee and an EPA GS-14 employee were alleged to have made unauthorized and
inaccurate changes to data in a contractor database on an information technology contract that they oversaw.
The allegations of misconduct were not supported.
CASE NUMBER: QI-HQ-2018-CFD-0064
An EPA GS-15 Special Agent supervisor allegedly steered a contract to a partner in an outside business. The
Federal Bureau of Investigation led a joint investigative effort into the potential criminal allegations, with the OIG
investigating any potential employee policy violations. On June 19, 2019, the OIG was notified by the Federal
Bureau of Investigation that the case was declined by the U.S. Department of Justice for prosecution. During the
course of the investigation the EPA employee retired; as a result, the administrative portion of the investigation
was closed.
CASE NUMBER: QI-AT-2018-ADM-0122
An EPA GS-15 employee allegedly attended personal appointments and events during work hours without using
annual or sick leave. It was further alleged that the employee used his/her EPA title to solicit funds for
scholarships and had inappropriately received a reasonable accommodation to fly first-class for official
business. The allegations were not supported.
CASE NUMBER: QI-HQ-2018-ADM-0126
An EPA GS-15 employee allegedly sexually assaulted another employee while at work, just prior to retiring. It
was also alleged that after the assault was reported, the resulting inquiry was not handled by management and
human resources officials in accordance with the EPA's workplace harassment order. Both allegations were
supported. The victim did not press assault charges, the subject retired, and management and human resource
officials underwent additional anti-harassment training. Because this was an administrative case, as the victim
did not press charges, the case was not referred to the U.S. Department of Justice.
61

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
CASE NUMBER: QI-CH-2018-ADM-0132
An EPA GS-15 employee allegedly took part in an "off-the-books" timekeeping scheme for 6 years where the
employee would keep track through email of the number of hours worked in excess of the standard 8-hour day
and then would take time off based on these extra hours. The employee did not record this time off in the
employee's timecards. The employee admitted to the scheme; however, the statute of limitations for the
potential criminal violations had expired and the case therefore was not referred to the U.S. Department of
Justice. The employee retired from federal service during the investigation.
Investigations Involving Non-Senior Employees Not Previously Publicly Disclosed
CASE NUMBER: QI-CH-2019-ADM-0108
An EPA GS-14 allegedly committed fraud by editing an official EPA document containing a manager's signature.
The investigation found that the document in question had not been officially signed by all parties, thus was still
in draft form when the edits were made. It was found that the complainant misunderstood the process of how
this type of document is handled. The allegation was not supported.
CASE NUMBER: QI-CI-2015-CFR-0055
An EPA GS-13 employee allegedly used his/her official position to receive gifts, meals and personal favors from,
as well as socialize with, EPA contractors. The allegations were supported. The employee was suspended
without pay for 30 days.
CASE NUMBER: OI-AR-2017-CAC-00Q6
An EPA GS-13 employee allegedly falsified information on an Electronic Questionnaires for Investigations
Processing application. During the investigation the employee was transferred to a position that does not require
a security clearance. The investigation was inconclusive.
CASE NUMBER: QI-CH-2017-ADM-0068
An EPA GS-13 employee allegedly engaged in time-and-attendance fraud by teleworking full-time from a
residence outside the employee's official duty station and thus was receiving a higher locality pay than what the
employee was entitled. The allegation was not supported.
CASE NUMBER: OI-DA-2018-ADM-00Q6
An EPA GS-13 employee was arrested while off-duty for possession of a controlled substance and unlawfully
carrying a weapon. The employee admitted to the arrest and possession of these items and, upon returning to
work, was ordered to participate in counseling through the Employee Assistance Program and was subject to
unannounced drug testing. The employee failed an unannounced drug test and was subsequently terminated.
CASE NUMBER: OI-HQ-2018-ADM-010Q
An EPA GS-13 employee was arrested during non-duty hours for allegedly possessing synthetic marijuana. An
investigation to determine if the employee had been involved in the manufacture of synthetic marijuana and if
the employee had made a false statement on the Standard Form 85P, Questionnaire for Public Trust Positions,
regarding the arrest did not reveal that the employee was involved in the manufacture of synthetic marijuana or
made false statements on the form.
CASE NUMBER: OI-NE-2019-ADM-00Q1
An EPA OIG GS-13 Special Agent allegedly was charging hours in the office's project management reporting
system that were not supported by documented work. The allegation was supported. The employee was
suspended for 5 days.
CASE NUMBER: QI-HQ-2017-ADM-0146
An EPA GS-11 employee allegedly regularly failed to report for duty as scheduled, and did not contact a
supervisor to request leave. The agency determined that the employee was absent without leave. The employee
was removed from federal service.
62

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
CASE NUMBER: QI-DA-2017-ADM-0041
An EPA GS-7 employee allegedly provided false information on application materials for federal employment,
specifically his/her employment history on a resume and criminal history on the Standard Form 85P,
Questionnaire for Public Trust Positions. The investigation revealed that the employee did not provide false
information on a resume and previously had disclosed information to the EPA about the criminal history. The
allegations were not supported.
CASE NUMBER: OI-PH-2019-ADM-00Q8
An office within the EPA allegedly provided false information on financial statements. Interviews and reviews of
EPA documents were conducted. The allegations were not supported.
Investigations Involving Non-Employees Not Previously Publicly Disclosed
CASE NUMBER: QI-AR-2013-CAC-0072
An EPA server was allegedly compromised. A review of the computer system logs determined a file had been
uploaded into the root website directory within the server, causing the server to be compromised. The allegation
was supported. The investigation also determined that a foreign actor caused the compromise. The subject was
indicted on conspiracy to defraud the United States and fraud charges. The subject was arrested and charged in
the subject's home country. The subject will not face extradition to the United States.
CASE NUMBER: QI-RTP-2017-CAC-0047
An EPA contractor allegedly installed a keylogger device on an EPA employee's keyboard, enabling the
contractor to log the EPA employee's key strokes. The allegation was supported. The former contractor pleaded
guilty to unlawfully accessing a computer and was sentenced to 2 years of probation and fined $5,000. The
former contractor was debarred from participation in federal procurement and non-procurement programs for
3 years.
CASE NUMBER: OI-HQ-2018-CCR-009Q
There was an alleged phishing attack against the EPA network. An email was sent to multiple EPA network
users from what appeared to be a legitimate business source. However, the organization from which the email
appeared to originate had been compromised and it sent infected emails to legitimate users from its database.
The EPA network was not an entry point and a vulnerability was identified in Microsoft's Office 365 Suite.
Investigators received updates from Microsoft that explained the vulnerability and remediation instructions for
the problem.
CASE NUMBER: QI-HQ-2019-CCR-0014
An EPA contractor allegedly gained unauthorized access to confidential business information stored on an EPA
employee's laptop. The investigation revealed that the contractor was properly given authorization to access the
confidential business information. The allegation was not supported.
CASE NUMBER: QI-AR-2013-CAC-0120
A construction company allegedly falsified documents in order to be awarded a contract involving EPA Drinking
Water State Revolving Funds. The company provided the name of a certified disadvantaged business enterprise
in its bid documents without the disadvantaged business enterprise's knowledge or consent. The allegation was
supported; however, the U.S. Attorney's office declined the case for prosecution and the matter was declined for
administrative remedies.
CASE NUMBER: QI-DA-2017-CFR-0121
An EPA Drinking Water State Revolving Fund recipient alleged that a contractor provided an inferior above-
ground water storage tank. Interviews and review of the contract documents disclosed no federal violations. The
allegation was not supported.
CASE NUMBER: QI-CH-2018-CFD-0113
An EPA contractor self-reported to the EPA that it had received an overpayment of $64,133 under a contract it
was previously awarded. The OIG worked with the EPA and the contractor to facilitate the recovery of the
overpayment. The EPA funds were recovered in full.
63

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Semiannual Report to Congress
April 1, 2019—September 30, 2019
CASE NUMBER: QI-CH-2018-AFD-0115
It was alleged that a city municipality was erroneously foreclosing on homes to allow a nonprofit housing
corporation to purchase the homes using grant funds from the EPA Brownfields Program. Investigators
determined that all interviewees admitted to being delinquent for several years on state taxes, which then
allowed the city to legally foreclose on the properties. The Brownfields funds were then used by the grantee to
clean up the area. The allegations were not supported.
CASE NUMBER: QI-DA-2018-LFD-0131
It was alleged that a state department of health agency mishandled the lab analysis of drinking water samples.
The investigation revealed several quality control and documentation issues in the agency's processing of
samples. The allegations were supported. As a result of the investigation, lab officials changed standard
operating procedures and generated corrective action reports.
CASE NUMBER: QI-AT-2019-AFD-0060
An employee for a state Department for Environmental Protection (an EPA grant recipient) allegedly received a
bribe in return for not performing inspection duties at an agricultural facility. Multiple interviews and record
reviews were conducted. The allegations were not supported.
CASE NUMBER: OI-AR-2015-CFR-00Q7
Potential fraud-related issues were identified at a nonprofit organization receiving EPA grant funds during an
audit performed by another federal agency. The investigation determined that no EPA funds were misused.
CASE NUMBER: QI-SA-2015-CFR-0123
The former administrator of an environmental agency for a U.S. territory allegedly violated local and federal laws
by entering into settlement agreements and accepting supplemental environmental projects with violators of
environmental laws when determining enforcement actions. The investigation found that applicable policy and
procedures were followed regarding the administrator's discretion over the administration of enforcement
actions. The allegations were not supported.
CASE NUMBER: QI-AT-2018-CFD-0051
An investigation by the Federal Bureau of Investigation revealed that three individuals allegedly conspired to
prevent the EPA from listing a Superfund site on the National Priorities List. The three individuals were
convicted of conspiracy, bribery and wire fraud. Once the OIG was brought into the case, one individual and one
associated business entity were debarred for 5 years from participation in federal procurement and non-
procurement programs.
CASE NUMBER: QI-DE-2018-AFD-0071
A tribal member allegedly used an EPA grant-funded motor vehicle for personal use, including driving it to
Canada. Investigation disclosed that the allegation was not supported.
CASE NUMBER: QI-AT-2019-AFD-0038
A local wastewater treatment authority that was awarded a Clean Water State Revolving Fund grant allegedly
used the grant money as collateral to secure additional funds for projects. The allegation was not supported.
CASE NUMBER: QI-DA-2019-ADM-0041
A former employee of a state grant recipient allegedly falsified inspection information of facilities subject to
Title V of the Clean Air Act while employed there, which was reported to the EPA. Investigators determined that
EPA funds were not used for fraudulent purposes. The matter was referred to the state's OIG for action as
deemed appropriate.
CASE NUMBER: QI-AT-2019-CFD-0057
An EPA contractor allegedly used foreign iron products on a project funded by a Drinking Water State Revolving
Fund grant in violation of the American Iron and Steel Requirement. The investigation determined that there
were no indications foreign iron materials were used on the project and a review of certifications and compliance
documents did not reveal any anomalies. The allegation was not supported.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
CASE NUMBER: QI-AT-2019-AFD-0067
A grantee allegedly misused EPA grant funds. After multiple requests from the EPA, the entity failed to submit
required financial reports by the deadline. The investigation determined that the grantee's technical advisor had
resigned and no grant funding had been expended in over a year. The EPA finance center received and
processed the reports requested from the grantee. As a result, the grant was closed and the unobligated
balance of funds returned to the EPA. The allegation was not supported.
CASE NUMBER: OI-SA-2017-OTH-Q129
An EPA employee alleged another federal employee from an outside agency had sexually harassed the EPA
employee and made harassing comments relating to the employee's national origin. The investigation was led
by the OIG of the subject's agency, with the EPA OIG assisting. The allegations were not supported. The
conduct was found to be unprofessional and obnoxious but did not rise to the level of harassment and did not
violate any ethical standard.
CASE NUMBER: OI-SA-2019-QTH-0017
An EPA laptop was stolen at an airport while an EPA employee was on official government travel. Security
footage confirmed that the laptop was stolen while the employee was going through security. All investigative
leads were exhausted, the laptop could not be recovered, and the identity of the suspect could not be
determined.
CASE NUMBER: OI-DA-2019-QTH-0018
An EPA laptop was stolen from an EPA employee's vehicle. Investigators were unable to locate the property or
develop additional leads.
CASE NUMBER: OI-SA-2019-QTH-0032
An EPA laptop and Personnel Access and Security System identification badge were stolen from an EPA
employee's rental vehicle. Investigators were unable to locate the property or develop additional leads.
CASE NUMBER: QI-SA-2019-PFD-0033
A contractor was allegedly posing as an EPA employee for personal gain. The contractor had been previously
issued safety gear with the EPA logo while working on a state government contract involving the EPA. The
contractor proceeded to wear the gear with the EPA logo while working on a separate contract with which the
EPA was unaffiliated. The investigation determined that the contractor did not claim to be an EPA employee and
no personal gains were made by the contractor. The allegation was not supported.
CASE NUMBER: QI-DA-2019-ADM-0055
An EPA-issued iPad and iPhone were stolen from an EPA employee's vehicle. Investigators were unable to
locate the property or develop additional leads.
CASE NUMBER: QI-SA-2019-THT-0063
Two personal laptop computers were found abandoned inside an EPA-controlled room. Once all investigative
leads were exhausted and the identity of the owner(s) could not be determined, the computers were sent for
disposal.
CASE NUMBER: OI-RTP-2019-ADM-007Q
An individual allegedly represented himself to be an EPA "senior agent" and used the authority from this position
to have another individual banned from a casino. Subsequent interviews with casino management and security
refuted the allegation. The allegation was not supported.
CASE NUMBER: QI-DA-2018-THT-0058
An individual allegedly made a verbal threat over the phone to an EPA contractor. The caller was identified and
admitted to making the threat. The U.S. Attorney's office declined the case for prosecution.
CASE NUMBER: QI-HQ-2019-THT-0083
An EPA GS-13 employee allegedly made threatening statements to the employee's supervisor. The
investigation was inconclusive.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
Appendix 5—Peer Reviews Conducted
Audits
The U.S. Department of Defense OIG completed an external peer review of the EPA OIG audit
organization covering the fiscal year ended September 30, 2017, and issued its report on June 18, 2018.
The review was conducted in accordance with generally accepted government auditing standards and
the Council of the Inspectors General on Integrity and Efficiency's Guide for Conducting Peer Reviews
of the Audit Organizations of Federal Offices of Inspector General. The peer review report stated that
the system of quality control for the EPA OIG audit organization in effect for the year ended
September 30, 2017, was suitably designed and complied with to provide the EPA OIG with reasonable
assurance that audits are performed and reported in conformity with applicable professional standards in
all material respects. The EPA OIG received an external peer review rating of pass.
Investigations
The U.S. General Services Administration OIG completed the most recently 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 June 11, 2018. The U.S. General Services Administration OIG
identified no deficiencies and found internal safeguards and management procedures compliant with
quality standards.
On May 7, 2019, the EPA OIG completed its report on a quality assessment review of the investigative
operations of the Special Inspector General for the Troubled Asset Relief Program in effect for the
3-year period ending September 30, 2018. We found that the Special Inspector General's system of
internal safeguards and management procedures for the investigative function for the period reviewed
was in compliance with applicable quality standards.
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Semiannual Report to Congress
April 1, 2019—September 30, 2019
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 (Mail Code: 15-1)
Boston, MA 02109-3912
Audit/Evaluation: (617) 918-1475
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) 886-7167
Offices
Dallas
U.S. Environmental Protection Agency
Office of Inspector General - 4th Floor
1201 Elm Street
Dallas, TX 75270
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: (913) 551-7420
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) 814-2326
Investigations: (215) 814-2359
Research Triangle Park
U.S. Environmental Protection Agency
Office of Inspector General
Mail Drop N283-01
Research Triangle Park, NC 27711
Audit/Evaluation: (919) 541-1030
Investigations: (919) 541-0517
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 17-H13
1200 Sixth Avenue, Suite 155
Seattle, WA 98101-3140
Audit/Evaluation: (206) 553-6906
Investigations: (206) 553-1273
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