/ £% "t,
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
EPA Can Improve Incident
Readiness with Better
Management of Homeland
Security and Emergency
Response Equipment
Report No. 20-P-0066
January 3, 2020
-------
Report Contributors:
Michael D. Davis
Kevin Haas
Gabriel Porras-Sanchez
Gloria Taylor-Upshaw
Abbreviations
AAMS
Agency Asset Management System
CMAD
Consequence Management Advisory Division
EPA
U.S. Environmental Protection Agency
ERT
Environmental Response Team
ERTG
Emergency Response Technical Group
HS/ER
Homeland Security and Emergency Response
NCERT
National Criminal Enforcement Response Team
NEL
National Equipment List
OEM
Office of Emergency Management
OHS
Office of Homeland Security
OIG
Office of Inspector General
OLEM
Office of Land and Emergency Management
OSC
On-Scene Coordinator
RERT
Radiological Emergency Response Team
Cover Photo: A Region 10 emergency response vehicle in Seattle, Washington.
(EPA OIG photo)
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tfED STAf.
U.S. Environmental Protection Agency 20-P-0066
I' \ Office of Inspector General January 3,2020
I® I
At a Glance
Why We Did This Project
The U.S. Environmental
Protection Agency's (EPA's)
Office of Inspector General (OIG)
conducted this audit to determine
whether the EPA has the needed
and required homeland security
and emergency response
(HS/ER) equipment, whether the
EPA efficiently manages and
tracks that equipment, and
whether the equipment is readily
available for potential homeland
security or emergency response
incidents.
The EPA's Office of Emergency
Management, within the agency's
Office of Land and Emergency
Management, works with federal
partners to maintain capabilities
to respond to emergencies. The
EPA's Office of Homeland
Security, within the Office of the
Administrator, provides
agencywide leadership and
coordination for planning,
prevention, preparedness and
response to homeland security
incidents. Also, within the EPA,
four special teams and all
10 regions respond to homeland
security or emergency response
incidents.
This report addresses the
following:
• Operating efficiently and
effectively.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
EPA Can Improve Incident Readiness with Better
Management of Homeland Security and
Emergency Response Equipment
What We Found
The EPA needs to improve its management of
HS/ER equipment. Specifically:
The EPA did not identify the HS/ER
equipment needed to respond to a
nationally significant incident.
The EPA did not fully use its agencywide
equipment system to track the availability
of EPA-owned HS/ER equipment.
The EPA's special teams need to address the status of HS/ER
equipment that is unused or broken.
The EPA needs to improve
its management of its
HS/ER equipment, worth
over $40 million, so that it
can adequately track the
equipment it needs to fulfill
its responsibilities during
an incident in a cost-
effective manner.
While the EPA has successfully responded to past incidents, there is a risk
that—until it identifies a list of HS/ER equipment it needs to meet its
responsibilities during an incident—the agency may not have the correct
equipment to respond to future incidents. Also, while the EPA spends
$554,310 annually on the Agency Asset Management System (AAMS), which
has the ability to manage and track the EPA's equipment, the agency is not
using this functionality. Instead, the EPA spent an additional $2,365,938 to
track the equipment outside of AAMS, making it difficult for the EPA to have an
accurate inventory of HS/ER equipment. Compounding this problem is the
mismanagement of unused or broken equipment.
Recommendations and Planned Agency Corrective Actions
We recommend that the agency create and maintain an official agencywide list
of the equipment needed for incidents, maintain one official agencywide
management and tracking system for HS/ER equipment, update AAMS to
include missing equipment, implement controls to verify and record the status
of unused or broken equipment, and verify the implementation of internal
controls to justify the agency keeping unused or broken equipment.
The EPA agreed with two recommendations but did not provide corrective
actions, and it disagreed with the remaining three recommendations. Thus, all
recommendations in this report are unresolved with resolution efforts in
progress.
List of OIG reports.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
January 3, 2020
MEMORANDUM
SUBJECT: EPA Can Improve Incident Readiness with Better Management of Homeland Security
and Emergency Response Equipment
Report No. 20-P-0066
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this audit was OA&E-FY18-0109.
This report contains findings that describe the problems the OIG has identified and corrective actions the
OIG recommends. This report represents the opinion of the OIG and does not necessarily represent the
final EPA position. Final determinations on matters in this report will be made by EPA managers in
accordance with established audit resolution procedures.
The Office of Emergency Management, within the Office of Land and Emergency Management, and the
Office of Homeland Security, within the Office of the Administrator, share responsibilities for the
subjects covered in this audit.
Action Required
All recommendations in this report are unresolved. In accordance with EPA Manual 2750, the resolution
process begins immediately with the issuance of this report. We are requesting a meeting within 30 days
with the Associate Deputy Administrator, the Assistant Administrator for Land and Emergency
Management, and the OIG's Assistant Inspector General for Audit and Evaluation. If resolution is still
not reached, the Office of the Administrator and the Office of Land and Emergency Management must
submit a dispute resolution request to the Chief Financial Officer.
FROM:
TO:
Doug Benevento, Associate Deputy Administr£„_.
Charles J. Sheehan, Acting Inspector General
Peter Wright, Assistant Administrator
Office of Land and Emergency Management
We will post this report to our website at www.epa.gov/oig.
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EPA Can Improve Incident Readiness with
Better Management of Homeland Security
and Emergency Response Equipment
20-P-0066
Table of C
Chapters
1 Introduction 1
Purpose 1
Background 1
Responsible Offices 3
Scope and Methodology 3
Prior Reports 5
2 EPA Needs Official List of HS/ER Equipment to Adequately
Respond to Significant Incidents 6
EPA Has Not Identified Equipment It Needs to Meet Its
Responsibilities to Respond to Incidents 6
Agency Policy Implements Management of Emergency
Response Equipment 6
EPA Has Outdated and Incomplete Equipment List 7
Without an Official Agencywide List, EPA May Not Know Whether
It Has the Correct Equipment to Respond 9
Recommendation 9
Agency Response and OIG Evaluation 9
3 EPA Needs to Track Availability of HS/ER Equipment Agencywide 11
Existing Tracking System Not Used to Track Equipment 11
EPA Did Not Have Equipment Items in Its Asset System, and
Estimated Acquisition Costs May Be Inaccurate 13
Agency Compliance with Financial Management
Requirements Needed 14
EPA at Risk of Not Having Needed Equipment Available
for Future Incident 14
Recommendations 14
Agency Response and OIG Evaluation 14
4 EPA Special Teams Are Not Addressing Unused or
Broken Equipment 16
EPA Special Teams Need to Address Unused or Broken Equipment 16
EPA Policy Requires Identification of Unused or Broken Equipment 17
Special Teams Were Not Declaring Unused Equipment as Excess 17
Recommendations 17
Agency Response and OIG Evaluation 18
Status of Recommendations and Potential Monetary Benefits 19
- continued -
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EPA Can Improve Incident Readiness with 20-P-0066
Better Management of Homeland Security
and Emergency Response Equipment
Appendices
A Agency Response to Draft Report 20
B Distribution 24
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Chapter 1
Introduction
Purpose
The Office of Inspector General (OIG) of the U.S. Environmental Protection
Agency (EPA) conducted an audit of the EPA's management of homeland
security and emergency response (HS/ER) equipment. Our objective was to
determine whether the EPA has the needed HS/ER equipment, the EPA efficiently
manages and tracks that equipment, and the equipment is readily available for
potential HS/ER incidents.
Background
The EPA uses HS/ER equipment to respond to chemical, biological or
radiological incidents; oil spills; and hazardous waste releases. The EPA's HS/ER
equipment can be used in local or regional emergencies, as well as in nationally
significant incidents. The EPA senior leadership manages internal activities and
coordinates with federal, state and local entities regardless of the incident type.
EPA Roles and Responsibilities in Response Efforts
The EPA's Office of Homeland Security (OHS), Office of Land and Emergency
Management (OLEM), Regional Administrators, On-Scene Coordinators (OSCs)
and special teams can all have a role in responding to an emergency or nationally
significant incident. The OSC responding to the incident will perform an
assessment to determine the equipment that is needed for the response. Senior
leadership responsible for the oversight include:
• Associate Administrator for Homeland Security, who is responsible for the
agency's preparedness, response and recovery for nationally significant
incidents.
• Assistant Administrator for Land and Emergency Management, who
oversees the agency's incident response.
• Assistant Administrators from other program offices, who provide
information on their EPA programs.
• Regional Administrators, who serve as the designated contact on policy or
political issues, act as the regional spokesperson, and coordinate at the
political and strategic level with other agencies.
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Generally, at the program or regional level depending on the incident, the
following are involved in responding to an emergency or incident:
• The OSC from the impacted region responds to an incident; initially
determines whether federal assistance is required; and coordinates with
responding state and local agencies, if needed.
• A special team, under the direction of an EPA program office (Table 1),
focuses its response activity on the type of homeland security or
emergency incident that has occurred. Each team has its own assigned
HS/ER equipment. The four special teams are:
1. Environmental Response Team (ERT).
2. Consequence Management Advisory Division (CMAD).
3. Radiological Emergency Response Team (RERT).
4. National Criminal Enforcement Response Team (NCERT).
Table 1: Special teams' response activity focus
Team
Program office
Response activities focus
ERT
OLEM - Office of Superfund Remediation
and Technology Innovation
Environmental emergencies.
CMAD
OLEM - Office of Emergency Management
All phases of a chemical, biological,
radiological and nuclear response.
RERT
Office of Air and Radiation - Office of
Radiation and Indoor Air
Radiation monitoring and
evaluation.
NCERT
Office of Enforcement and Compliance
Assurance - Office of Criminal
Enforcement, Forensics and Training
Forensic evidence collection and
protective escorts.
Source: OIG analysis of EPA information. See Figure 1 for each team location.
The EPA also has an Emergency Response Technical Group (ERTG) that has
representatives from regions and special teams. The technical group developed
the national emergency response equipment list to assure equipment
standardization and consistency across the nation. The ERTG's mission is "to
enhance emergency response planning, preparedness and technical capabilities of
[OSCs] to respond to oil and hazardous material incidents." The technical group
is coordinated through the Office of Emergency Management's (OEM's),
Preparedness and Response Operations Division.
EPA's HS/ER Equipment and Asset Management System
As of April 2018, the EPA had 7,908 HS/ER equipment items—ranging from
rubber boots and paper towels to meters, tractors, trucks and forklifts— with an
estimated total value of $40,456,809.
The EPA uses the Agency Asset Management System (AAMS) to track and
inventory EPA equipment. The EPA Property Manual states that AAMS is used
to track assets that meet one or more of the following criteria:
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(1) for which expected useful life is two years or longer and an
acquisition value of $5,000 or more; (2) that is classified as
sensitive; (3) for which controls and official asset records are
maintained; (4) for which physical inventories are conducted;
and/or (5) that is otherwise assigned and accounted for. It includes
capitalized property, sensitive property, controlled property,
firearms and weapons, motor vehicles and trailers, vessels, aircraft,
and classified property.
The manual also states that program and regional offices shall develop and
maintain internal controls that provide reasonable assurance that all assets are
managed in accordance with federal laws, regulations and EPA policy.
Responsible Offices
The OHS, within the Office of the Administrator, provides agencywide leadership
and coordination for planning, prevention, preparedness and response to
homeland security incidents. The OLEM, through its OEM, works with federal
partners to prevent accidents and maintain capabilities to respond to emergencies.
Scope and Methodology
We conducted our audit from March 2018 to May 2019 in accordance with
generally accepted government auditing standards issued by the Comptroller
General of the United States. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a reasonable basis
for our findings and conclusions based
on our audit objective. We believe that
the evidence obtained provides a
reasonable basis for the findings and
conclusions presented in this report.
To answer our objective, we reviewed
the following federal law, guidance, and
agency policies and procedures related to
the HS/ER equipment process:
• Federal Financial Management Improvement Act of1996,
Pub. L. No. 104-208, Div. A, Title I, §101(f), HO Stat. 3009-389 (1996).
• The Joint Financial Management Improvement Program's
JFMIP-SR-00-4, Federal Financial Management System Requirements:
Property Management System Requirements, October 2000.
• The Government Accountability Office's GAO-02-171G, Property
Management Systems Requirements: Checklist for Reviewing Systems
Region 8 storage of HS/ER equipment.
(EPA OIG photo)
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Under the Federal Financial Management Improvement Act, December 1,
2001.
• EPA Order 2071, National Approach to Response, October 27, 2016.
• EPA 4832, EPA Personal Property Manual, June 2017.
• OLEM memorandum, Decommissioning of the Equipment Tracking
Module (ETM) and Move to the Agency Asset Management System
(AAMS) to Track Equipment, May 22, 2018.
We selected site visit locations based on the type of equipment (EPA- or
contractor-managed) and the total value of the equipment. We selected
287 equipment items for review with an estimated acquisition cost of
$15.7 million based on the highest estimated acquisition costs at each site.
Figure 1 shows the organizations and locations selected.
Figure 1: Audit sites visited, number of equipment items and estimated
costs of equipment
Total equipment items sampled: 287
Total estimated acquisition costs: $15.7 million
Org: Region 10
Seattle, WA
37 items
$1.67 million
Org: Region
Arvada, CO
33 items
$925,441
Org: CMAD
Lakewood. CO
5 items
$322,861
Org: NCERT
Lakewood, CO
14 items
$113,831
Org: CMAD
Erlanger. KY
18 items
$1.95 million
Org: ERT
Erlanger. KY
3 items
$88,768
Org: RERT
Las Vegas, NV
19 items
$1.79 million
Org: ERT
Las Vegas, NV
19 items
$1.58 million
Org: CMAD
Castle Rock, CO
41 items
$4.05 million
Org: Region 4
Norcross, GA
61 items
$1.78 million
Org: RERT
Montgomery, AL
38 items
$1.45 million
Source: OIG analysis of site visits.
For each item sampled, we reviewed equipment tags, purchase costs,
maintenance/usage records and the condition of the equipment. At each site, we
reviewed the systems that were used to track equipment and the process for
handling unused or broken equipment; we also looked at whether the equipment
was agency- or contractor-owned and/or managed. We reviewed AAMS to
determine whether the equipment was accurately recorded and compared data in
the system to data provided to us from regional or contractor databases and
spreadsheets.
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We interviewed regional OSCs, property management staff, a criminal
investigator, scientists, program office staff and contractors. We also interviewed
property management specialists about AAMS updates and use, as well as
controls and changes for HS/ER equipment.
Prior Reports
The EPA OIG issued several prior reports that relate to HS/ER equipment:
• Report No. 1 l-P-0616. EPA Has Not Fully Implemented a National
Emergency Response Equipment Tracking System, issued September 13,
2011. This report involved a review of a hotline complaint that alleged the
EPA was not using the Emergency Management Portal equipment module
and that the module was ineffective and costly. The OIG recommended that
the EPA determine whether the Emergency Management Portal was the
most cost-efficient equipment-tracking alternative. The OIG also
recommended that the EPA mandate that regions and response teams use
the national tracking system. The agency indicated that the corrective
actions were completed.
• Report No. 09-P-0087. EPA Plans for Managing Counter Terrorism/
Emergency Response Equipment and Protecting Critical Assets Not Fully
Implemented, issued January 27, 2009. The OIG found that the EPA
needed to improve management of counter terrorism/emergency response
equipment. The OIG recommended that the agency establish milestones
and accountability for implementing the Emergency Management Portal
equipment module and ensure resources are available for training and
implementation of the module. The agency indicated that all corrective
actions were completed.
• Report No. 2006-P-00022. EPA Needs to Better Implement Plan for
Protecting Critical Infrastructure and Key Resources Used to Respond to
Terrorist Attacks and Disasters, issued April 26, 2006. The OIG found
that the EPA had not implemented a national system for tracking
emergency response equipment. The OIG recommended that the EPA
determine the categories of equipment to be tracked, as well as update
warehouse data at specific intervals until a national equipment system is
operational. The agency indicated that it completed corrective actions.
• Report No. 2004-P-00011. EPA Needs to Better Manage Counter Terrorism/
Emergency Response Equipment, issued March 29, 2004. The OIG found that
the EPA did not have a national counter terrorism/emergency response
equipment tracking system. The OIG recommended that the agency establish
a timetable to (1) determine what emergency response equipment and
characteristics to track and (2) develop and implement a plan, with points of
accountability, for a national tracking system. The agency indicated that it
completed corrective actions.
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Chapter 2
EPA Needs Official List of HS/ER Equipment to
Adequately Respond to Significant Incidents
The EPA has not identified the HS/ER equipment needed to respond to a
nationally significant incident. EPA Order 2071, National Approach to Response,
says the agency must "continue to focus preparation and response planning on the
possibility for multiple, simultaneous significant incidents that could occur across
several regions." The EPA's response planning includes an outdated and
incomplete national equipment list (NEL) and separate equipment lists maintained
by regions and special teams. Without one official agencywide list of items, there
is a risk that the agency may not have the correct equipment to respond to future
incidents. Also, a list will help the agency spend taxpayer funds in a responsible
manner to support its equipment needs.
EPA Has Not Identified Equipment It Needs to Meet Its Responsibilities
to Respond to Incidents
The EPA has not identified the HS/ER equipment
needed to support its role in the federal response to
incidents. Without this information against which to
compare the EPA's actual equipment, the agency may
not know whether it has the assets to respond quickly
and effectively to a nationally significant incident. The
EPA's OHS has performed evaluations related to the
EPA's responsibilities under presidential directives that
address the agency's requirements to respond to
incidents such as chemical, biological or radiological
incidents; oil spills; hazardous waste releases; and
water emergencies. However, these evaluations
contained only observations and did not identify the
equipment needed or provide a roadmap for developing
one for emergencies or homeland security incidents.
A CMAD HS/ER response
vehicle in Castle Rock,
Colorado. (EPA OIG photo)
Agency Policy Implements Management of Emergency Response
Equipment
In 2003, the EPA issued a National Approach to Response policy to manage its
emergency response, including its management of assets during a nationally
significant incident or disaster. The National Approach to Response stated that the
agency would deploy people and equipment to emergency responses in a timely
manner and take a national approach to coordinating efforts, regardless of whether
the EPA had the lead or provided support. The National Approach to Response
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noted that a nationally significant incident might be the result of a chemical,
biological or radiological emergency or a natural disaster.
Effective October 27, 2016, the National Approach to Response was updated and
became part of EPA Order 2071, National Approach to Response. This order
documents agency policy for implementing "the government-wide national
incident management system." EPA Order 2071 states that the EPA "must
continue to focus preparedness and response planning on the possibility for
multiple, simultaneous significant incidents that could occur across several
regions."
EPA Has Outdated and Incomplete Equipment List
The EPA has not been able to identify what equipment is needed to respond to
emergencies or significant incidents because it has an outdated and incomplete
National Emergency Response Equipment List, which is also referred to as the
NEL. In addition, regions and special teams have separate equipment lists.
EPA Does Not Maintain Complete Equipment List
The ERTG developed the NEL for equipment consistency and standardization
across the country for all regions and special teams. We only became aware of the
NEL when the agency provided its working draft of the Five-Year Equipment
Replacement Plan 2017-2022, dated March 7, 2018. The plan identified
replacement priorities and aids the agency in identify funding needed to support
equipment replacement and maintenance. The NEL, which was last updated in
2015, is in the appendix of the plan. The OIG requested an updated list, but the
agency did not provide one.
The NEL does not list all equipment maintained by regions and special teams.
The plan assumes that the emergency response program will support one large
and one small concurrent national incident or event. We found that the NEL did
not include large emergency response equipment, such as response vehicles,
generators, trailers and communications equipment. The plan has not been
finalized or implemented because of the agency's limited budget.
The budget is also a factor for OLEM and its management of HS/ER equipment.
Specifically, an OLEM Director said that "existing budgets allow us to operate
and maintain our capabilities and assets. The budgets are not at levels that allow
us to evolve, upgrade or modernize to keep up with technological advancements
and emerging threats."
If the EPA updates and maintains an official agencywide equipment list, like the
NEL, it may help the agency know whether it has the HS/ER equipment needed to
support its role in the federal response to incidents.
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Regions and Special Teams Maintain Separate Equipment Lists
Each region and special team that we reviewed maintained its own list of HS/ER
equipment and knew its ability to respond to an incident. The regions and special
teams that we visited told us about various methods they use to identify needs for
their HS/ER equipment:
• Special teams in Las Vegas, Nevada, and staff in Regions 4 and 8 said that
information about the need for equipment comes from the agency's ERTG
review process.
• CMAD said that it follows Homeland Security Presidential Directives and
Presidential Policy Directives to determine the need for its equipment.
• NCERT said that it developed a 5-day model to determine the amount and
type of equipment needed.
• A special team in Montgomery, Alabama, said that the air program office
develops a yearly acquisition plan for purchases over $150,000, which
would include large equipment items.
• Region 4 said that it is using its own 3-year purchase plan to help identify
equipment needs.
• Region 10 said that it has a 5-year plan for equipment acquisition derived
from ERTG's NEL.
OLEM noted that it was not aware of any EPA requirement to maintain a single
agencywide list of HS/ER equipment. However, the agency stated that the ERTG
had defined the current makes
and models of the specific
instalments needed for standard
hazardous material
releases/spills. The ERTG's NEL
specifies the items that a
region/team needs to respond
appropriately, along with the
ability to rapidly pool equipment
from across all regions and teams
to respond to major incidents.
Regions and special teams determine whether they require additional equipment
based on local assessments.
An official agencywide list would allow the EPA to understand agencywide
capabilities and assess needs it should address as an agency, so it is prepared to
respond to a nationally significant incident.
EPA Region 4 emergency response warehouse.
(EPA OIG photo)
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Without an Official Agencywide List, EPA May Not Know Whether It
Has the Correct Equipment to Respond
The EPA has HS/ER equipment with an
estimated value of $40,456,809.
Without an agencywide list of
equipment, the EPA will not know
whether it is using its limited budget on
the equipment it needs for an
emergency or incident. A list of the
equipment needed will also help the
agency responsibly spend taxpayer
funds. While the EPA has successfully
responded to past incidents, there is a
risk that the agency may not have the
correct equipment to meet its
responsibilities when responding to
future incidents.
Recommendation
We recommend that the Deputy Administrator and the Assistant Administrator for
Land and Emergency Management:
1. Create and maintain an official agencywide list of needed homeland
security and emergency response equipment, so that the agency can
maintain readiness for significant incidents in accordance with EPA
Order 2071, National Approach to Response.
Agency Response and OIG Evaluation
The EPA did not agree with Recommendation 1 and proposed deleting it. The
EPA stated that:
The creation of a single list of 'needed and required equipment' for
emergency responses is only possible with appropriate bounds
given the Agency's authorities and resource constraints. The
current requirements for equipment are provided in the National
Equipment List and are estimated based on realistic and probable
scenarios for which EPA is authorized and delegated to provide
equipment.
Responses vary, and the necessary equipment required to
adequately respond to [sicjvaries. It is impossible to preselect
equipment types and number due to the uncertainty of the different
types of incidents, equipment technology advances and evolving
Canberra 300G iSolo Gasless Gross Alpha
Beta Machines (HS/ER equipment) in RERT
Montgomery, Alabama. (EPA OIG photo)
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intelligence. EPA has an Emergency Response and Removal
Program National Equipment List (aka National Equipment List or
NEL). The National Equipment List provided through the ERTG
contacts is maintained by the regions and special teams and
supports a planning scenario for 1 large and 1 medium incident.
The EPA has not created an official agencywide list of equipment needed to
respond to significant incidents. The agency's draft Five-Year Equipment
Replacement Plan 2017-2022 is not final and has not been implemented. The
NEL is outdated, is incomplete and does not identify all needed emergency
response equipment. While the EPA has successfully responded to past incidents,
there is a risk that the agency may not have the correct equipment to respond to
future incidents until it creates a list of needed HS/ER equipment.
Recommendation 1 is unresolved with resolution efforts in progress. The full
agency response is in Appendix A.
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Chapter 3
EPA Needs to Track Availability of
HS/ER Equipment Agencywide
The EPA did not use AAMS to track the availability of EPA-owned HS/ER
equipment. Without a cost-effective and efficient agencywide tracking system for
all HS/ER equipment, the EPA is at risk of not knowing whether it has the
necessary equipment to timely respond to a nationally significant incident.
AAMS, which costs the agency $554,310 annually, does not have information on
HS/ER equipment availability, nor does it always include EPA-owned HS/ER
equipment, and it may have inaccurate equipment costs. Moreover—at an
acquisition cost of $2,365,938—the agency uses contractors to track equipment,
even though AAMS could do this for the agency.
Existing Tracking System Not Used to Track Equipment
The EPA did not use its agencywide equipment system to indicate whether HS/ER
equipment is available to respond to a nationally significant incident. The EPA said
that in the event of a homeland security or emergency incident, the regions and
special teams call each other to determine who has HS/ER equipment available to be
deployed (see Figure 2). This interaction is not an efficient, systematic way to
identify the availability of HS/ER equipment
that is used to respond to nationally significant
incidents.
EPA Has Not Fully Used Agency's
Tracking System Abilities
In May 22, 2018, the EPA issued the
memorandum, Decommissioning of the
Equipment Tracking Module (ETM) and
Move to the Agency Asset Management
System (AAMS) to Track Equipment, which
mandated the use of AAMS to track all
HS/ER equipment. The agency explained that
in December 2015, AAMS became the
"authoritative information technology system
for all enterprise asset management for the
Agency." Additionally, the memorandum
stated, "This designation requires all regional program offices and labs to
transition from using external and existing internal equipment tracking tools and
begin using AAMS."
Figure 2: HS/ER equipment managers/trackers
and services used
Regional offices
Special teams
Source: EPAOIG image.
Official asset
management
system:
$554,310
Additional
contracted
services used:
$2.4 million
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The EPA's special teams and regions use tools and contractors to track the
availability of HS/ER equipment outside of AAMS. The agency has not fully used
AAMS to track the availability of equipment, despite the EPA stating that AAMS
can track availability. The agency noted:
AAMS is an all-inclusive asset management system designed to
track and account for various types of assets. In addition to
tracking, key features and requirements include: acquisition,
utilization, and disposition data. Also included are 1) a
maintenance module that is capable of tracking events like asset
calibration, 2) a materials module which is a solution for supply
chain management of expensed and consumed items, and 3) a
reporting capability covering the varying aspects of lifecycle
management.
Although the EPA directed the use of AAMS, other tools to track equipment
availability continue to be used throughout the agency to manage HS/ER
equipment needs. From our site visits, we found that three regions had contracted
$2,365,938 to manage and track equipment. Table 2 provides a breakdown of the
contracts.
Table 2: EPA contractors who manage and track HS/ER equipment
Special team
or region
Contractor
name/contract
number
Summary of some contractor services
provided to the EPA
Estimated annual
contract value
Period of
performance
Region 4
Basha Services
EP-S4-16-05
• Manage inventory of equipment and
supplies and maintain and calibrate
government-owned equipment.
$858,123*
6/23/18 to
6/22/19
Region 8
CBT Logistics
EP-S8-16-01
• Provide 24/7 on-call access to the
warehouse for the EPA Region 8
Emergency Planning and Response staff
and other authorized third parties such as
the START3 contractor.
• Operate and maintain the warehouse
facility, to include all services and
functions, in conformance with
established commercial/government
practices.
• Maintain a detailed warehouse inventory
for all government property. Ensure that
the inventory control system provides
accurate location and selection of stock.
$713,171
8/11/17 to
8/11/18
Region 10
(3 locations)**
Vanquish Worldwide
EP-S7-13-01
• Manage warehouse facilities operations.
• Provide emergency response equipment
management on a 24/7 basis.
• Provide inventory control and a tracking
system.
• Maintain equipment.
$794,644
Amount is for
three warehouses in
Region 10; Seattle,
Washington, is the
largest.
5/6/17 to
11/5/18
Total
$2,365,938
Source: OIG analysis of EPA data.
* Total contract amount was $2,574,368 over 3 years. Amount in Table 2 is equivalent to 1 year.
** Locations—Seattle, Washington; Portland, Oregon; Anchorage, Alaska.
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EPA Did Not Have Equipment Items in Its Asset System, and
Estimated Acquisition Costs May Be Inaccurate
Figure 3: HS/ER equipment items not in
AAMS
NCERT
2 items
$13,902
9 items not
reported
$284,906
Region 8
7 items
$271,004
Source: OIG analysis of EPA data.
Figure 4: HS/ER special teams and regions
with AAMS equipment acquisition cost
discrepancies*
Region 10
9 items
($24,717)
4 items
$73,202
ERT-Las Vegas
4 items
$19,354
Total:
26 items
with cost
discrepancies
$121,319
Region 8
9 items
$53,480
Source: OIG analysis of EPA data.
* Discrepancies are defined as AAMS costs, less
the amounts reported on regional and special
team spreadsheets. The amount in parentheses is
a negative amount representing an understated
amount in AAMS.
Due to the EPA using both AAMS and
contractors to manage and track equipment,
AAMS was missing some HS/ER equipment
items and had some inaccurate acquisition cost
information. Out of the 287 items we sampled
during the audit, the EPA had nine HS/ER
equipment items that were not in AAMS and
26 equipment items in AAMS with inaccurate
acquisition costs.
In addition, Figure 4 shows that there were
26 items in Region 4, Region 8, Region 10 and
the Las Vegas ERT special team that had
discrepancies totaling $121,819 between what
was reported in Excel spreadsheets for acquisition
costs and amounts in AAMS. We also found that
the 26 items resulted in a high percentage of items
that were misstated in our samples from the Las
Vegas ERT special team, Region 8, Region 10
and Region 4, which were 22 percent, 27 percent,
24 percent, and 7 percent respectively, therefore
raising concerns about AAMS data integrity.
When we compared the acquisition costs of HS/ER
equipment recorded in AAMS with Excel
spreadsheets provided to us from contractors and
regional or special team staff, we found
discrepancies in the equipment items and
acquisition costs. As noted in Figure 3, NCERT—
a special team located in Colorado and Region 8—
had nine items totaling $284,906 that were tracked
outside of AAMS. We sampled 14 items from the
NCERT special team with a total value of
$113,831. Two items (14 percent) in our sample
were missing from AAMS, with a value of
$13,902, or 12 percent of the entire value of the
sample. We found a higher rate of missing items
from AAMS in the Region 8 sample. Seven
(21 percent) of the 33 items in our Region 8
sample were missing from AAMS. The value of
the seven items missing from AAMS was
$271,004, or 29 percent of the total value of the
Region 8 sample.
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Agency Compliance with Financial Management Requirements Needed
The EPA needs to fully use AAMS to track HS/ER equipment to comply with the
Property Management System Requirements, which state that property
accountability includes tracking the movement of assets, recording changes in
physical condition, and verifying the number of equipment. A property
management system must also capture the quantity of property, when it was
received, or the date that it is available for use.
EPA at Risk of Not Having Needed Equipment Available for
Future Incident
While the EPA stated that AAMS could track the
availability of HS/ER equipment, the agency does not use
it for that purpose because of functional issues and
therefore used other tracking tools. By not using an
agencywide equipment system to track the availability of
HS/ER equipment, the EPA is at risk of not knowing
whether the agency has specific equipment available for a
future incident. In addition, Regions 4, 8 and 10 each have
their own contractors, with a total value of $2,365,938, to
manage and track EPA-owned HS/ER equipment, while
AAMS costs $554,310 total. The EPA needs a more
accurate agencywide system that tracks the availability of
HS/ER equipment to help the agency to respond timely to
nationally significant incidents.
Recommendations
We recommend that the Deputy Administrator and the Assistant Administrator for
Land and Emergency Management:
2. Maintain one official agencywide management and tracking system for
homeland security and emergency response equipment that provides for
the status, availability and acquisition costs of all equipment.
3. Update the Agency Asset Management System with any missing
homeland security and emergency response equipment.
Agency Response and OIG Evaluation
The EPA did not agree with Recommendation 2; proposed deleting the
recommendation; and stated that it was completed in December 2015, when the
EPA made AAMS the system of record for all asset management in the agency.
However, the EPA spent funds on contractors to manage and track HS/ER
equipment throughout the agency. The EPA has not used the capability to track
Thermofisher FH40G
Multipurpose Digital
Survey Meter at NCERT
warehouse in Lakewood,
Colorado. Item was not
included in AAMS.
(EPA OIG photo)
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the availability of equipment in AAMS and should maintain one official system
for managing and tracking HS/ER equipment. The use of multiple contracts
throughout the agency is an inefficient use of taxpayer funds. If the agency had
completed the proposed recommendation in December 2015, the agency would
have an official agencywide list of HS/ER equipment.
The EPA agreed with Recommendation 3 but did not provide planned corrective
actions. In accordance with EPA Manual 2750, Audit Management Procedures,
the agency is to provide intended corrective actions and estimated completion
dates for recommendations with which it agrees.
Both Recommendations 2 and 3 are considered unresolved with resolution efforts
in progress. The full agency response is in Appendix A.
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Chapter 4
EPA Special Teams Are Not Addressing
Unused or Broken Equipment
The EPA special teams need to address the status of HS/ER equipment that is
unused or broken. Special teams had eight unused or broken HS/ER equipment,
with a total acquisition value of $929,644, that could have been excessed or used
for other purposes. The EPA's Personal Property Manual states that property is
declared excess when it is no longer needed to fulfill the requirements for which it
was acquired and that management teams should identify excess personal
property and declare it as such. Special teams indicated that they kept unused or
broken equipment for replacement parts or future use. However, special teams did
not identify excess equipment as required. The EPA could have better used the
equipment if the agency had the accurate status of unused or broken HS/ER
equipment.
EPA Special Teams Need to Address Unused or Broken Equipment
The EPA special teams have not addressed the status of unused or broken HS/ER
equipment. Table 3 notes each special team and estimated costs of the eight
broken or unused equipment identified during site visits.
Table 3: Unused or broken HS/ER equipment
Special team
Number of
equipment items
Unused or broken HS/ER
equipment estimated
acquisition costs
CMAD - Castle Rock, Colorado
1*
$94,043
RERT - Montgomery, Alabama
0**
576,617
RERT - Las Vegas, Nevada
4
258,984
Total
8
$929,644
Source: OIG analysis.
* The EPA put the item on the excess equipment list after the OIG inquiry.
** The RERT team decided to repurpose the unused items for spare parts after the OIG
inquiry.
In one instance, we found that RERT Las Vegas categorized its unused or broken
HS/ER equipment as "standby" with an "out of service" tag because RERT was
evaluating its need for the equipment. However, from our audit, damaged
equipment could be excessed or used for other purposes.
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EPA Policy Requires Identification of Unused or Broken Equipment
The EPA should determine whether unused or broken HS/ER equipment should
be excessed or repurposed. According to the EPA Personal Property Manual, "all
EPA employees and contractors must adhere to the
policy guidance set forth in the manual when
executing personal property management functions
on behalf of the EPA." According to Section 7.4,
equipment should be declared excess when it is no
longer needed to fulfill the requirement for which it
was acquired. Section 6.5.1 states that management
teams should, at a minimum, identify excess
personal property and declare it as such.
Section 8.3.5 states that contractor responsibilities
include reporting lost, stolen, damaged and
destroyed property incidents, or excess government-
furnished property, to the contract property
coordinator. Section 8.5.2 states that the contractor is also required to promptly
report government property that is in excess of contract requirements.
Special Teams Were Not Declaring Unused Equipment as Excess
Special teams were not declaring unused equipment as excess. One special team
kept broken items for repair parts for other items, and another special team stated
that it was waiting for a budget to fix and upgrade broken equipment.
The EPA special team s could have better used equipment items if they had the
accurate status of the unused or broken HS/ER equipment. The equipment could
have been made available to other parts of the agency or to other federal agencies.
Also, the EPA special teams would have more warehouse space for other
equipment if they remove unused or broken equipment, such as a large unused
tractor-trailer in the RERT Montgomery warehouse.
Recommendations
We recommend that the Deputy Administrator and the Assistant Administrator for
Land and Emergency Management:
4. Require special teams to implement controls that require property officers
over homeland security and emergency response equipment to verify and
record the proper status of unused or broken equipment during the
agency's annual inventory.
5. Require special teams to verify implementation of internal controls for
their teams that justify maintaining unused or broken equipment in
accordance with requirements in the EPA Personal Property Manual.
Solid Phase Extractor in the CMAD warehouse
in Castle Rock, Colorado, that was unused
equipment. (EPAOIG photo)
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Agency Response and OIG Evaluation
The EPA agreed with Recommendation 4 but did not provide planned corrective
actions. In accordance with EPA Manual 2750, Audit Management Procedures, the
agency is to provide intended corrective actions and estimated completion dates for
recommendations with which it agrees.
The EPA did not agree with Recommendation 5 and proposed deleting the
recommendation. The EPA stated that Recommendation 5 was completed in
December 2015. If the agency completed the proposed recommendation in
December 2015, the agency should provide the implemented internal controls
established by special teams to verify that unused or broken equipment was
excessed, repaired and maintained in accordance with the EPA Personal Property
Manual.
Both Recommendations 4 and 5 are unresolved with resolution efforts in progress.
The full agency response is in Appendix A.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
No.
Subject
Status1
Action Official
Planned
Completion
Date
Potential
Monetary
Benefits
(in $000s)
9 Create and maintain an official agencywide list of needed U
homeland security and emergency response equipment, so that
the agency can maintain readiness for significant incidents in
accordance with EPA Order 2071, National Approach to
Response.
14 Maintain one official agencywide management and tracking U
system for homeland security and emergency response
equipment that provides for the status, availability and
acquisition costs of all equipment.
14 Update the Agency Asset Management System with any missing U
homeland security and emergency response equipment.
17 Require special teams to implement controls that require
property officers over homeland security and emergency
response equipment to verify and record the proper status of
unused or broken equipment during the agency's annual
inventory.
17 Require special teams to verify implementation of internal
controls for their teams that justify maintaining unused or broken
equipment in accordance with requirements in the EPA Personal
Property Manual.
Deputy Administrator and
Assistant Administrator for
Land and Emergency
Management
Deputy Administrator and
Assistant Administrator for
Land and Emergency
Management
Deputy Administrator and
Assistant Administrator for
Land and Emergency
Management
Deputy Administrator and
Assistant Administrator for
Land and Emergency
Management
Deputy Administrator and
Assistant Administrator for
Land and Emergency
Management
$40,456
$835
C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUL 1 5 2019
OFFICE OF
SOUD WASTE AND
EMERGENCY RESPONSE
memorandum
NOW THE
OFFICE OF LAND AND
EMERGENCY MANAGEMENT
SUBJECT: Response to the Office of Inspector General's Audit: EPA Needs to Improve
Management of Homeland Security and Emergency Response Equipment, Project No.
OA&E-FY 18-0109. draft *
We appreciate the opportunity to review the subject Office of the Inspector General (OIG) report. The
consolidated list of specific concerns was sent to you via email on June 17, 2019, and the OIG discussed
its responses with the stakeholder workgroup on June 24, 2019.
Although we agree there are some areas for improvement, we do not concur that there is evidence for
the draft conclusion "EPA may not be able to respond in a timely manner to future incidents" and "EPA
does not have an agency-wide system capable of tracking EPA-owned [homeland security/emergency
response] HS/ER equipment." We continue to believe that the draft report does not provide the evidence
to support many of the findings and conclusions and mischaracterizes EPA's role in responding to
emergencies, as well as our delegated responsibilities related to the National Response Framework.
Throughout the OIG audit and summarized within this response and attached, we have provided data to
support our concerns. We recommend the OIG remove or revise these and related unsupported
statements throughout the report, or supplement the record and allow us to review that record.
EPA concurs with the OIG's recommendations to "Update the Agency Asset Management System
("Sunflower") with any missing homeland security and emergency response equipment" and to
"implement controls to verify and record proper status of unused or broken equipment and establish
internal controls to act as needed on unused or broken equipment."
EPA's Office of Emergency Management (OEM) works with other EPA offices, federal agencies, state,
local and tribal governments to respond quickly to chemical, radiological and hazardous substance
releases and oil spills, and continually strives to protect the public from immediate dangers and future
accidents. EPA is:
• Designated as the nation's lead federal agency for emergency response to hazardous substance
and inland oil spills.
FROM: Peter C. Wright
Assistant Administrator
TO:
Charles J. Sheehan, Acting Inspector General
Office of Inspector General
Internet Address (URL) • http://www epa gov
Recycled/Recyclable • Pnnied with Vegetable Ol Based Inks on 100% Poslconsumer. Process Chlorine Free Recycled Paper
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• Staffed with about 230 emergency responders who are ready to deploy to anywhere in the
country,
• Equipped with cutting edge monitoring technology such as the Airborne Spectral
Photometric Environmental Collection Technology airplane, the Portable High-
throughput Integrated Laboratory Information System mobile units, and the Trace
Atmosphere Gas Analyzer that provide real-time monitoring information for decision
makers,
• Strongly connected with other federal agencies, states, local governments and tribes, to
ensure coordinated and efficient responses to emergencies.
Overview of EPA positions:
• The significant errors on the part of the OIG regarding the role and authority of EPA in
an emergency response and impact of EPA's response programs render the associated
findings unsound.
• The creation of a single list of "needed and required equipment" for emergency responses
is only possible with appropriate bounds given the Agency's authorities and resource
constraints. The current requirements for equipment are provided in the National
Equipment List and are estimated based on realistic and probable scenarios for which
EPA is authorized and delegated to provide equipment.
• National level emergencies are managed by the Federal Emergency Management
Agency, which draws necessary resources from across the federal government to
supplement that of states, tribes and local governments, where needed. The extremely
remote possibility that the federal government would not be able to respond to an
extraordinary emergency is evaluated by FEMA and its leadership partners.
• EPA has mandated the use of the Agency Asset Management System (" AAMS") as the
single system for managing personal property. The responsibility for populating AAMS
lies with each national program office and Region.
• Not all "equipment" used in an emergency response is considered personal property.
Following the June 24 meeting, the OIG provided revised language with respect to conclusions
on timely responses and incidents and AAMS capabilities for the final report, along the
following lines:
• While EPA has successfully responded to past incidents, there is a low Agency risk
remaining that it may not have the correct equipment when responding to future incidents
until a list of the needed and required HS/ER equipment is identified.
• While the EPA Sunflower system has other HS/ER equipment tracking capabilities,
EPA's regions and special teams have contracted to obtain those needed tracking
capabilities outside of Sunflower.
While improved, we are still concerned that these statements go beyond the record, because the
OIG did not audit EPA's response capabilities and only audited the status of the equipment list.
In addition, tracking capability incidental to AAMS is necessary for managing required and
needed HS/ER equipment that is not EPA personal property and, subsequently, would not be
tracked in AAMS. We continue to recommend that changes be made in the following statements:
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FROM: "As a result, the EPA may not be able to respond in a timely manner to future
incidents" and "The EPA's response to a nationally significant incident may be impaired because
it did not identify specific HS/ER equipment needed and required for such a response" and "EPA
at Risk of Not Responding Timely to a Future Incident"
TO: "EPA can make improvements/reduce risks to ensure continued timely responses to future
incidents."
Also,
FROM: "The EPA does not have an agencywide equipment system capable of tracking the
availability of EPA-owned HS/ER equipment."
TO: "The EPA is not consistently implementing the agencywide equipment tracking system
(i.e., AAMS) available to all Regions and Programs to track EPA owned HS/ER equipment."
Agency's Response to Report Recommendations:
Agreements
No.
Reconinieiuhlion
1 lijih-l.oM'l Intended
Correcti\e Action(s)
Ksliniitted Completion by
Qiiiirter itiul I'Y
3
Update the Agency Asset Management
System ("Sunflower") with any missing
homeland security and emergency
response equipment.
4
Require special teams to implement
controls that require property officers
over homeland security and emergency
response equipment to verify and record
the proper status of unused or broken
equipment during the agency's annual
inventory
Disagreements
No.
Reconinieiuhlion
Agency K\phm;it ion/Response
Proposed
Allern;iti\e
1
Creale and muinluin an agenc) wide list
of all needed and required homeland
security and emergency response
equipment
Responses \ ar\, and die necessai) equipment
required to adequately respond to varies. It is
impossible to preselect equipment types and
number due to the uncertainty of the different
types of incidents, equipment technology
advances and evolving intelligence. EPA has an
Emergency Response and Removal Program
National Equipment List (aka National
Delete
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No.
Reconiineiuhlion
Agency K\phm;it ion/Response
Proposed
Alteriuithe
Equipment List or NEL). The National
Equipment List provided through the ERTG
contacts is maintained by the regions and
special teams and supports a planning scenario
for 1 large and 1 medium incident.
2
Maintain one official, required
agencywide management and tracking
system for homeland security and
emergency response equipment that
provides for the status, availability and
acquisition costs of all equipment
Duplicate of # 1 above and completed
December 22, 2015.
Delete
5
Require special teams to establish
internal controls for, and verify
implementation to, excess, repair or
justify maintaining unused or broken
equipment in accordance with
requirements in the EPA Personal
Property Manual.
Duplicate of #2 above
Delete
If you have questions, please feel free to contact me at (202) 566-0200 or have your staff contact
Reggie Cheatham, Director, Office of Emergency Management, at (202) 564-8003.
Attachment
cc: Henry Darwin, AO
Barry Breen, OLEM
Kevin Christensen, OIG
Susan Bodine, OECA
Bill Wehrum, OAR
Anne Idsal, OAR
Donna Vizian, OMS
Mary Walker, Region 4
Greg Sopkin, Region 8
Chris Hladick, Region 10
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Distribution
Appendix B
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Chief of Staff
Deputy Chief of Staff
Assistant Administrator for Land and Emergency Management
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Associate Administrator for Homeland Security
Director, Office of Continuous Improvement, Office of the Administrator
Principal Deputy Assistant Administrator for Land and Emergency Management
Deputy Assistant Administrator for Land and Emergency Management
Director, Office of Emergency Management, Office of Land and Emergency Management
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Land and Emergency Management
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