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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Compendium of
Unimplemented Recommendations
as of March 31, 2010
Report No. 10-N-0114
April 28, 2010

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Abbreviations
BOSC	Board of Scientific Counselors
CCSP	Climate Change Science Program
CERCLIS	Comprehensive Environmental Response, Compensation, and Liability
Information System
CMM	Contracts Management Manual
COR	Contracting Officer Representative
CSO	Combined Sewer Overflows
CWS	Community Water Systems
EAS	Enterprise Architecture Strategic
EPA	U.S. Environmental Protection Agency
EPAAR	Environmental Protection Agency Acquisition Regulation
FCID	Food Commodity Intake Database
FMFIA	Federal Managers' Financial Integrity Act
GAO	Government Accountability Office
GCRP	Global Change Research Program
ICR	Information Collection Rule
MATS	Management Audit Tracking System
NHANES	National Health and Nutrition Examination Survey
OA	Office of the Administrator
OAM	Office of Acquisition Management
OAR	Office of Air and Radiation
OARM	Office of Administration and Resources Management
OCFO	Office of the Chief Financial Officer
OECA	Office of Enforcement and Compliance Assurance
OIG	Office of Inspector General
OMB	Office of Management and Budget
OPP	Office of Pesticide Programs
OPPTS	Office of Prevention, Pesticides, and Toxic Substances
ORD	Office of Research and Development
OSWER	Office of Solid Waste and Emergency Response
OW	Office of Water
QAP	Quality Assessment Plans
POTW	Publicly Owned Treatment Works
RCT	Research Coordination Team
RSL	Regional Science Liaison
SAB	Science Advisory Board
SNC	Significant Non-Compliance
TMDL	Total Maximum Daily Load
USD A	United States Department of Agriculture
WA	Work Assignments

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
April 28, 2010
MEMORANDUM
SUBJECT: Compendium of Unimplemented Recommendations as of March 31,2010
Report No. 10-N-0114
Assistant Administrators
Regional Administrators
General Counsel
Chief Financial Officer
Associate Administrators
Attached is the semiannual Compendium of Unimplemented Recommendations as of March 31,
2010, prepared by the Office of Inspector General (OIG) of the U.S. Environmental Protection
Agency (EPA). This Compendium fulfills the requirement of the Inspector General Act,
as amended, to identify reports containing significant recommendations described in previous
Semiannual Reports to Congress on which corrective actions have not been completed.
This Compendium, issued in conjunction with the Semiannual Report to Congress and as a
separate document to EPA leadership, is part of the OIG's follow-up strategy to promote robust
internal controls. Follow-up is done in collaboration with the EPA Office of the Chief Financial
Officer and EPA Audit Follow-up Coordinators. The goal is to improve overall audit
management by helping EPA managers gain a greater awareness of outstanding agreed-to
commitments for action on OIG report recommendations. Implementing these recommendations
will correct weaknesses, reduce vulnerabilities to risk, and leverage opportunities for improved
performance.
The significance of audit follow-up, as described by the Office of Management and Budget
(OMB) Circular A-50, is enhanced by the public's expectation for greater transparency and a
heightened interest by Congress in realizing potential opportunities for improvement in the
Federal Government. The OIG's previous Compendium reports appear to be having the intended
effect of increasing Agency awareness and action on unimplemented OIG recommendations.
We selected the unimplemented recommendations listed in this Compendium based on their
significance and their status in EPA's Management Audit Tracking System. In addition, some
unimplemented recommendations were identified through review by the OIG. Exclusion from
the Compendium does not indicate the OIG determined the corrective action to be complete for a
recommendation. However, it is a goal of the OIG to verify as many significant
recommendations reported as being complete as possible, through other reviews.
TO
Deputy Administrator

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According to OMB Circular A-50, audit follow-up is a shared responsibility between the Agency
and the OIG. We will continue to identify unimplemented recommendations for attention and
action, as well as remove the listing of recommendations as unimplemented when appropriate
information of completion is provided. We hope that you find this tool useful in identifying
ways to further improve Agency operations.
Bill A. Roderick
Acting Inspector General

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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Table of Contents
Introduction		1
Unimplemented Recommendations		4
OIG Report Number
09-P-0242 		4
09-P-0232 		6
09-P-0229 		7
09-P-0223 		8
09-P-0203 		9
09-P-0197 		10
09-P-0089 		12
08-P-0266 		15
08-P-0141 		16
08-1-0032 		17
2007-P-00036 		18
2007-P-00027 		20
2006-P-00013 		21
2006-P-00009 		22
2006-P-00007 		23
2005-P-00010 		24
2004-P-00030 		26
2002-P-00012 		27
Appendix A: OIG Reports with Unimplemented
Recommendations by Program Office		28
Appendix B: Unimplemented Recommendations:
10/28/09 Compendium Compared to Current Compendium 		30

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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Introduction
Purpose
The purpose of this Compendium of Unimplemented Recommendations is to highlight for
U.S. Environmental Protection Agency (EPA) management significant recommendations that
remain unimplemented past the due date agreed to by EPA and the Office of Inspector General
(OIG). The Compendium satisfies part of Section 5(a) of the Inspector General Act of 1978, as
amended, which requires each Inspector General to issue semiannual reports to Congress and
include "an identification of each significant recommendation described in previous semiannual
reports on which corrective action has not been completed." This Compendium is being issued
in conjunction with the OIG Semiannual Report to Congress for the reporting period October 1,
2009, through March 31, 2010. The OIG intends to issue this Compendium each semiannual
reporting period. The Compendium will keep Agency management informed about EPA's
outstanding commitments and its progress in taking agreed-upon corrective actions on OIG
recommendations to improve programs and operations.
Background
EPA's OIG issues recommendations to improve the economy, efficiency, effectiveness, or
integrity of EPA programs and operations. Office of Management and Budget (OMB) Circular
A-50, Audit Follow up, affirms that corrective action taken by management on resolved findings
and recommendations is essential to improve the effectiveness and efficiency of government
operations, and that audit follow-up is a shared responsibility of agency management officials
and auditors.
OMB Circular A-50 requires each agency to establish systems to ensure the prompt and proper
resolution and implementation of audit recommendations. EPA Order 2750, based on OMB
Circular A-50, details EPA's policy and procedures on audit follow-up. The Chief Financial
Officer is the Agency Audit Follow-up Official and has responsibility for Agency-wide audit
resolution, ensuring Action Officials implement corrective actions. EPA uses the Management
Audit Tracking System (MATS) to track information on Agency implementation of OIG
recommendations. The Office of the Chief Financial Officer maintains and operates MATS.
MATS receives report data, such as the report title and issue date, from the Inspector General
Enterprise Management System.
The Audit Management Official in the Office of the Administrator, the Office of General
Counsel, and each Assistant Administrator or Regional Administrator office designates an Audit
Follow-up Coordinator for that office. Audit Follow-up Coordinators are responsible for quality
assurance and analysis of tracking system data. When corrective actions in response to
recommendations in an audit report are completed and certified, the Agency should inactivate
that report's MATS file. The Audit Follow-up Coordinator then no longer has to track the
report. The Agency self-certifies that corrective actions are completed. The Agency is also
responsible under the Inspector General Act for reporting on audit reports for which final
1

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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
corrective action has not been taken 1 year or more after the Agency's management decision on
corrective actions to be taken in response to findings and recommendations.
This is the fourth edition of the Compendium of Unimplemented Recommendations. It identifies
34 unimplemented recommendations from 18 reports compared to 44 unimplemented
recommendations from 26 reports identified in the third edition for the period ending
September 30, 2009. Of the 34 unimplemented recommendations currently reported, 10 from
7 reports are continuing, and 24 from 11 reports are newly identified. Also, we removed
34 unimplemented recommendations from 20 reports that were included in the previous
Compendium. Please note that removal of an unimplemented recommendation does not imply
that it was verified as implemented, but rather, it was reported as being completed or that the
target completion date has been revised with OIG approval.
Scope and Methodology
Due to our limited scope and purpose, we did not conduct our work in accordance with all
generally accepted government auditing standards issued by the Comptroller General of the
United States. Specifically, we did not evaluate management controls, determine compliance
with laws and regulations, or develop findings and recommendations. Further, we did not
thoroughly assess the validity and reliability of data obtained from the Agency's MATS.
Although MATS was our primary source for identifying unimplemented recommendations, we
did perform additional steps to search for unimplemented recommendations that may not have
been identified in MATS.
We reviewed selected audit and evaluation reports issued by the EPA OIG from October 1, 1997,
through September 30, 2009, to identify significant unimplemented recommendations for
inclusion in the Compendium. However, we did not identify any significant unimplemented
recommendations from Fiscal Years 1998 through 2001. We did not review recommendations
from reports without an OIG agreement on the Agency's corrective action plan (Management
Decision). A list of these reports can be found in Appendix 2 of the OIG Semiannual Report to
Congress.
We excluded recommendations with future milestone dates for action. Some unimplemented
recommendations that were excluded from this Compendium may, upon further review, be
included in the next Compendium. A recommendation's exclusion from the Compendium does
not indicate our determination that the recommendation has been implemented. We limited the
unimplemented recommendations to those we believe are significant because they could have a
material impact on the economy, efficiency, effectiveness, or integrity of EPA programs and
operations. For this purpose, we define significant recommendations in the following terms:
•	Economy: Opportunity to save, prevent loss, or recover at least $500,000 in monetary
costs or value.
•	Efficiency: Improvement in the process, capacity, accessibility, or delivery of program
objectives and the elimination of unnecessary or unproductive actions or expenses.
•	Effectiveness: Improvement in the quality of, or reduction in the risk to, public health
and the environment.
•	Integrity: Improvement in operational accountability, enforcement of and compliance
with laws and regulations, and security of resources for public confidence.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
The following EPA offices have unimplemented recommendations listed in this Compendium:
Office of Administration and Resources Management (OARM)
Office of Air and Radiation (OAR)
Office of Enforcement and Compliance Assurance (OECA)
Office of Prevention, Pesticides and Toxic Substances (OPPTS)
Office of Research and Development (ORD)
Office of the Administrator (OA)
Office of the Chief Financial Officer (OCFO)
Office of Solid Waste and Emergency Response (OSWER)
Office of Water (OW)
We anticipate that the Agency will provide updates in MATS on the status of each
unimplemented recommendation, including a description of progress and an explanation of the
delay in completing an agreed-to action, in response to this Compendium.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Unimplemented Recommendations
Action Office:
OARM
Report Title:
Contractor Invoice Internal Controls Need Improvement
Report No.:
09-P-0242
Date Issued:
09/23/2009
Report Summary
In 2008, EPA paid contractors $1.3 billion. To safeguard EPA funds, invoices must be reviewed
to determine whether the submitted costs are allowable, allocable, and reasonable. The OIG
conducted this review to determine whether EPA controls ensure that invoiced contractor costs
are properly supported and allowable in accordance with the Federal Acquisition Regulation.
During our review, we found (1) invoice reviews were not always documented as required by the
Contracts Management Manual (CMM), (2) Project Officer reviews were based on incomplete
information, (3) monthly progress reports did not always contain the information needed to
evaluate invoices, and (4) Agency staff did not perform required rate verifications and math
checks. Some responsible for invoice reviews were unaware of the guidance and checklists in
the CMM, did not understand the level of documentation needed to review invoices, or did not
adhere to the guidance.
Unimplemented Recommendations
Recommendation 2-1: We recommend that the Assistant Administrator for OARM modify
the CMM to require use of the checklist for invoice reviews the contracting officer
representatives (CORs) perform, and to ensure CORs receive invoices and supporting
documentation to assist their reviews.
Status: OARM agreed that the CMM needs to be modified to better define documentation
needs at two levels: first, the supporting documentation that needs to be supplied by the
contractor to assist the COR in invoice reviews; and second, the documentation that the
COR needs to prepare to prove that a sufficient invoice review has been performed.
OARM planned to encourage CORs to use the checklist if it is applicable to their specific
contract. For cases where it does not apply, OARM planned to define the specific
documentation that the COR needs to prepare to properly document that an invoice review
has been performed. OARM planned to promulgate the new documentation definitions via
an Interim Policy Notice. The agreed-to completion date was December 31, 2009.
Recommendation 2-2: We recommend that the Assistant Administrator for OARM, where the
progress report and invoice did not cover the same period, require the contractors identified
during this review to revise their progress reports to match the time period of the invoice.
Status: OARM agreed that EPA's contracting officers (COs) would notify their
contractors of this requirement via a written letter. OARM planned that in cases where
the contracts do not contain the requirement that progress report and invoice periods
match, the contracts would be modified. The agreed-to completion date was December
31, 2009.
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Compendium of Unimplemented Recommendations as of March 31, 2010
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Recommendation 2-4: We recommend that the Assistant Administrator for OARM require that
the COs, as part of the annual invoice review, perform periodic reviews to make certain that
project officers and CORs are: (a) implementing changes to the CMM made in response to the
audit report; and (b) requiring contractors to submit invoices and progress reports with matching
periods of performance.
Status: OARM agreed that the reviews would be carried out in each CO's annual review
of invoices as required by their Division's or Region's Quality Assessment Plan (QAP).
OARM planned that the QAP policy would be modified accordingly in EPA's
Acquisition Handbook. The agreed-to completion date was December 31, 2009.
Recommendation 3-1: We recommend that the Assistant Administrator for OARM analyze
financial monitoring reviews to identify findings that are recurring on multiple contracts.
Status: OARM agreed to complete the analysis by November 30, 2009.
Recommendation 3-2: We recommend that the Assistant Administrator for OARM develop a
corrective action for addressing the common findings identified in financial monitoring reviews.
Status: OARM agreed to develop the corrective action plan by December 31, 2009.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office: ORD
Report Title: EPA's Office of Research and Development Could Better Use the Federal
Managers' Financial Integrity Act to Improve Operations
Report No.:	09-P-0232
Date Issued: 09/15/2009
Report Summary
ORD's management integrity program is inconsistent with Agency Federal Managers' Financial
Integrity Act (FMFIA) guidance. ORD approaches FMFIA as an administrative reporting
activity rather than an opportunity to evaluate and report on research program performance. As a
result, ORD has not:
•	Conducted a comprehensive risk assessment.
•	Included National Program Directors in the FMFIA process.
•	Developed and implemented a strategy to establish and evaluate the effectiveness of
internal controls over research programs.
•	Provided FMFIA training to managers and staff.
•	Included relevant risk and program performance information in assurance letters.
Applying FMFIA as intended would help EPA achieve its mission and program results through
improved accountability. ORD has initiated actions that we believe will address our findings,
such as developing a draft multiyear review strategy. In developing its new strategy, ORD
should include programmatic elements, a training plan, pertinent results from peer reviews, and
best practices to ensure more effective FMFIA implementation.
Unimplemented Recommendation
Recommendation 2-3: We recommend the Assistant Administrator for ORD revise the
Management Integrity Policy to include programmatic operations. The policy should include a
role for National Program Directors, integrate performance measures, reference current FMFIA
guidance, and include a training plan. The program should incorporate public sector best
practices and a two-track approach to address administrative and programmatic elements.
Status: ORD planned to revise the ORD Management Integrity Policy to include
programmatic operations, a definition of the National Program Directors' role in the
process, and integration of performance measures and outcomes. The agreed-to
completion date was January 31, 2010.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office:
Report Title:
Report No.:
Date Issued:
OARM
EPA Should Stop Providing Estimates of Total Labor Hours to Contractors
09-P-0229
09/09/2009
Report Summary
For 6 of the 22 contracts we reviewed, EPA provided the contractor with the government's
estimate for total labor hours prior to receiving the contractor's proposal. The Federal
Acquisition Regulation provides that the government may use various cost analysis techniques to
ensure a fair and reasonable price, including comparing proposed prices with IGCEs. Since EPA
is providing total labor hours to the contractor prior to receiving the proposal, EPA may be
diminishing its ability to obtain a fair and reasonable price.
Office of Acquisition Management managers pointed out that EPA's Acquisition Regulation
(EPAAR) requires that estimated labor hours be provided to contractors for contracts in which
work is ordered through work assignments. Yet, an Office of Acquisition Management guide
states that information from the IGCE should not be provided to the contractor. When EPA
provides its estimate of total labor hours before receiving the proposal, the contractor does not
have an incentive to seek a more efficient or innovative approach to meet the government's
requirement.
Unimplemented Recommendations
Recommendation 1: We recommend the Assistant Administrator for OARM revise the EPAAR
(48 CFR, Section 1552.21 l-74(b)) to eliminate the requirement that EPA include total estimated
labor hours in work assignments or identify specific circumstances in which the requirement
should apply.
Status: EPA agreed that the EPAAR clause on work assignments (WAs) should be
modified to provide better guidance to contracting officers (COs) on issuing WAs. The
new guidance will clarify the discretion COs have in revealing estimated labor hours to
the contractor, depending on the circumstances of the individual contracting situation.
EPA planned to issue interim guidance while the revised EPAAR clause is promulgated.
The agreed-to completion date was November 1, 2009.
Recommendation 2: We recommend the Assistant Administrator for OARM communicate to
contract management and program staff who prepare and use IGCEs that estimates of total labor
hours, or any other cost-related estimates, should not be provided to contractors prior to
receiving the contractor's proposal.
Status: EPA agreed with the recommendation and planned to communicate the new
interim WA guidance, as described above, to all affected parties that prepare and use
IGCEs. The agreed-to completion date was November 1, 2009.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office: OW
Report Title: EPA Needs to Accelerate Adoption of Numeric Nutrient Water Quality
Standards
Report No.:	09-P-0223
Date Issued: 08/26/2009
Report Summary
EPA's 1998 National Strategy and Plan to promote State adoption of nutrient water quality
standards (which better protect aquatic life and human health) has been ineffective. In 1998,
EPA stated that a critical need existed for improved water quality standards, given the number of
water bodies impaired from nutrients. In the 11 years since EPA issued its strategy, half the
States still had no numeric nutrient standards. States have not been motivated to create these
standards because implementing them is costly and often unpopular with various constituencies.
EPA has not held the States accountable to committed milestones. The current approach does
not assure that States will develop standards that provide adequate protection for downstream
waters. Until recently, EPA has not used its Clean Water Act authority to promulgate water
quality standards for States.
EPA cannot rely on the States alone to ensure that numeric nutrient standards are established.
EPA should prioritize States/waters significantly impacted by excess nutrients and determine
whether it should set the standards. EPA also needs to establish effective monitoring and
measures so that accurate program progress is reported. These progress reports will assist EPA
management in program decision making.
Unimplemented Recommendations
Recommendation 2-3: We recommend that the Assistant Administrator for OW establish EPA
and State accountability for meeting milestones for adopting numeric nutrient water quality
standards for those waters in the rest of the Nation that require them. EPA should do this by:
(a)	Requiring States to develop milestones based on resources available.
(b)	Reviewing those milestones and approving them as appropriate
Recommendation 2-4: We recommend that the Assistant Administrator for OW establish
metrics to gauge the actual progress made by States in adopting numeric nutrient water quality
standards.
Recommendation 2-5: We recommend that the Assistant Administrator for OW ensure that the
regions annually validate Water Quality Standards Actions Tracking Applications data.
Status: OW agreed to utilize the next available opportunity to revise internal program
activity reports to better gauge cumulative State progress. This corrective action is
associated with the three recommendations above. The agreed-to completion date was
February 28, 2010.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office:
Report Title:
Report No.:
Date Issued:
OCFO
EPA Should Use FMFIA to Improve Programmatic Operations
09-P-0203
08/06/2009
Report Summary
EPA has not implemented and used FMFIA to improve program operations, as intended by
federal and Agency guidance. Although EPA offices rely on annual guidance that OCFO
issues:
•	EPA offices have not developed internal control review strategies that include elements
such as the Government Performance and Results Act.
•	OCFO's guidance and training have not provided staff and managers with adequate
awareness of the U.S. Government Accountability Office's (GAO's) internal control
standards.
•	OCFO's guidance, until recently, has not required offices to report on compliance with
all GAO standards.
•	OCFO did not devote needed resources to validate assurance letters.
Per Agency guidance, OCFO is responsible for ensuring and implementing a strategy for
validating EPA's compliance with FMFIA. However, OCFO relies on Assistant and Regional
Administrators to verify letters' program elements before certifying them. EPA offices view
FMFIA reporting as an administrative task, rather than an opportunity to achieve goals by
assessing program results and identifying risks. As a result, when signing EPA letters, the
Administrator has little assurance that offices reviewed program operations. Additional
emphasis on FMFIA's importance could result in more certain, documented assurance in the
Agency's Performance and Accountability Report that EPA programs annually evaluate internal
controls to comply with GAO's standards and deter fraud, waste, and mismanagement.
Unimplemented Recommendation
Recommendation 3: We recommend that the Chief Financial Officer revise the internal
checklist that OCFO uses as part of its strategy for validating Agency-wide FMFIA compliance
to confirm that EPA offices addressed each of the five GAO standards in evaluating their internal
controls and identifying weaknesses. Describe, in its annual Agency guidance, OCFO's strategy
for assessing offices' assurance letters for compliance.
Status: OCFO agreed to include a description of how OCFO will review and assess
offices' assurance letters in FY 2010 management integrity guidance. OCFO anticipated
issuing its FY 2010 management integrity guidance on December 31, 2009. However,
for FY 2010, OCFO revised its approach and issued separate financial and programmatic
guidance on February 18, 2010, and March 10, 2010, respectively. OCFO will issue
guidance for preparing and submitting assurance letters including a description of how
OCFO will assess Assistant Administrators and Regional Administrators' (AA/RAs)
assurance letters, in April or May 2010. The original agreed-to completion date was
December 31, 2009.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office: OARM
Report Title: EPA Should Delay Deploying Its New Acquisition System until Testing Is
Completed
Report No.:	09-P-0197
Date Issued: 07/20/09
Report Summary
Office of Acquisition Management (OAM) did not comply with EPA's System Life Cycle
Management policy and procedure while developing the new EPA Acquisition System (EAS).
OAM did not fully develop the system's requirements documents during the requirements phase
and requirements were incomplete. Test scripts were not developed to prove that the system
fulfilled all requirements and ensure that the system would function as required. Although the
EAS Project Manager developed a Draft Master Test Plan that contained testing procedures,
OAM management never approved, implemented, and enforced this plan.
OAM management did not provide the oversight, authority, and support necessary to ensure the
EAS development project complied with EPA's System Life Cycle Management policy and
procedure. Because OAM had not completed the steps needed to reasonably ensure that EAS
would meet EPA's business needs if implemented by June 29, 2009, as planned, OAM does not
have a sound basis for deploying EAS as scheduled. More management emphasis is needed to
ensure the system development control environment achieves the desired results and the end
product meets EPA's needs.
Unimplemented Recommendations
Recommendation 1: We recommend that the Assistant Administrator for OARM identify and
document all system requirements, including functional, technical, security, and EPA-specific
requirements, in the EAS Requirements Document(s).
Status: EPA planned to:
a.	Identify new and detailed requirements using minutes of meetings
between EAS Developer and EPA Stakeholders. The agreed-to
completion date was October 16, 2009.
b.	Update Requirements Baseline with approved new and detailed
requirements. The agreed-to completion date was October 21, 2009.
c.	Update the Requirements Traceability Matrix with new detailed
requirements from updated Requirements Baseline. The agreed-to
completion date was October 21, 2009.
Recommendation 2: We recommend that the Assistant Administrator for OARM update,
review, and implement formal testing policies and procedures that would enforce:
a.	the review and approval of all system requirements prior to testing,
b.	the completion of Requirement Traceability Matrices mapping each system requirement
to a test script,
c.	the independent validation of vendor-supplied test scripts prior to testing, and
d.	the review and approval of testing results at the end of each round of testing.
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Compendium of Unimplemented Recommendations as of March 31, 2010
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Status: EPA planned to conduct 12 different actions in response to this recommendation,
e.g., verifying the accuracy and completeness of new and detailed requirements,
reviewing and approving all system requirements prior to testing, conducting an
Integrated Baseline Review of the Performance Measurement Baseline, etc. The latest
agreed-to completion date for all of the actions was March 26, 2010.
Recommendation 3: We recommend that the Assistant Administrator for OARM delay EAS
implementation until OAM has successfully tested all of the system requirements.
Status: EPA planned to conduct system tests. The agreed-to completion date was
August 9, 2009.
Recommendation 4: We recommend that the Assistant Administrator for OARM update the
EAS Project Schedule to communicate the current status of and future plans for EAS project
activities.
Status: EPA planned to update the EAS Project Schedule with approved schedule
changes following the Interim Baseline Requirements and distribute project schedule to
EAS Integrated Project Team. The agreed-to completion date was November 13, 2009.
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Compendium of Unimplemented Recommendations as of March 31, 2010
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Action Office: OA, ORD
Report Title: EPA Needs a Comprehensive Research Plan and Policies to Fulfill its Emerging
Climate Change Role
Report No.:	09-P-0089
Date Issued: 02/02/2009
Report Summary
EPA does not have an overall plan to ensure developing consistent, compatible climate change
strategies across the Agency. We surveyed EPA regions and offices and found they need more
information on a variety of climate change topics. They need technical climate change research
and tools as well as other climate change policy guidance and direction. We learned that EPA's
OW and several regional offices have developed or are developing their own individual climate
change strategies and plans. The lack of an overall climate change policy can result in
duplication, inconsistent approaches, and wasted resources among EPA's regions and offices.
EPA has not issued interim guidance to give its major components consistent direction to ensure
that a compatible national policy - when it emerges - will not result in wasted efforts.
EPA's latest plan for future climate change research does not address the full range of emerging
information needs. Specifically, the projected time of completion or the scope of some research
projects do not match the timing or the scope of regions' needs. ORD does not have a central
repository of its climate change research for its internal users, nor does it effectively
communicate the results of its climate change research to EPA's internal users. While ORD
collects research requirements from regions and program offices, the selection criteria for
research topics are not transparent to the regions. Finally, ORD does not have a system to track
research requests through completion, or a formal mechanism to obtain feedback from its users.
Unimplemented Recommendations
Recommendation 3-1: We recommend that the Deputy Administrator establish guidance to
programs and regional offices for regularly entering their climate change scientific information
in the Science Inventory.
Status: ORD planned to continue to provide the Science Inventory (and the
Environmental Science Connector) as depositories for EPA's scientific information. On
an annual basis, the Administrator or Deputy Administrator planned to continue to issue
guidance to program and regional offices for entering their scientific information into the
Science Inventory, including climate science information. The agreed-to completion date
was October 2009.
Each program and regional office will have the responsibility of entering and maintaining
its own scientific information in the Science Inventory on an ongoing basis. ORD
planned to provide the Administrator with annual reports on the number of entries related
to climate change by each program and regional office in the Science Inventory. The
agreed-to completion date was January 2010.
Recommendation 3-3: We recommend that the Assistant Administrator for ORD establish a
formal, transparent research requirements determination process that includes well-defined
procedures for identifying a unified set of priority climate change research needs.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Status: ORD stated that its Global Change Research Program (GCRP) already has an
effective process in place to determine the highest-priority research requirements of
EPA's Programs and Regions and of the U.S. Climate Change Science Program (CCSP).
GCRP's prioritization process includes the Research Coordination Team (RCT),
Regional Science Liaisons (RSLs), Regional Office Climate Coordinators, input from the
Board of Scientific Counselors (BOSC), input from the Science Advisory Board (SAB),
priorities set by the CCSP, and other formal and informal mechanisms. Several of these
processes (e.g., the RCT) include representatives from ORD, program offices, and
regional offices.
To make ORD's and the GCRP's research prioritization processes more transparent to the
program and regional offices, the National Program Director for the GCRP planned to
issue a memorandum describing how GCRP priorities are set on an annual basis. This
memorandum will include a discussion of how the GCRP must consider the individual
requests of programs and regions, as well its interagency responsibilities under the CCSP,
when determining priorities. The agreed-to completion date was January 31, 2010.
Recommendation 3-4: We recommend that the Assistant Administrator for ORD establish a
formal mechanism to track regional research needs from research project selection to
completion, and to requestor.
Status: ORD stated that GCRP already has an effective process in place to determine the
highest-priority research requirements of EPA's programs and regions, and of the CCSP.
GCRP's prioritization process includes RCT, RSLs, Regional Office Climate
Coordinators, input from BOSC, input from SAB, priorities set by the CCSP, and other
formal and informal mechanisms. Several of these processes (e.g., the RCT) include
representatives from ORD, program offices, and regional offices.
To make ORD's and the GCRP's research prioritization processes more transparent to the
program and regional offices, the National Program Director for the GCRP planned to
issue a memorandum describing how GCRP priorities are set on an annual basis. This
memorandum will include a discussion of how the GCRP must consider the individual
requests of programs and regions, as well its interagency responsibilities under the CCSP,
when determining priorities. The agreed-to completion date was January 31, 2010.
Recommendation 3-5: We recommend that the Assistant Administrator for ORD establish a
formal method for coordinating GCRP's research work with regions and program offices,
communicating research results, and collecting feedback on research products. The feedback
requested should include the accessibility, usability, value, and awareness of updates to the
Science Inventory and the Environmental Science Connector.
Status: ORD/GCRP stated that it already uses several mechanisms to coordinate,
communicate, and collect feedback. The Environmental Science Connector's "Global
Change Resource Center" and GCRP's new public Website are two tools used by ORD to
coordinate and communicate its global change research. In addition, GCRP's National
Program Director uses biweekly Global Conference Calls to obtain feedback from all
program and regional offices.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
To further formalize its ongoing efforts, the National Program Director for the GCRP
planned to issue a memorandum summarizing the mechanisms that ORD has already put
in place to communicate and coordinate GCRP's work with the program and regional
offices. This memorandum will be sent to partners across the Agency to improve their
awareness of GCRP's resources. This memorandum will be updated whenever new
mechanisms are developed. The agreed-to completion date was January 31, 2010.
ORD stated that it has begun to survey EPA stakeholders about the timeliness and
usefulness of products from its various programs to enhance research planning. The
GCRP planned to issue such a survey that will include a request for feedback on the
accessibility, usability, value, and awareness of updates to the Science Inventory and
Environmental Science Connector. The agreed-to completion date was
October 30, 2009.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
AOction Office:
Report Title:
Report No.:
Date Issued:
OW
EPA Assisting Tribal Water Systems but Needs to Improve Oversight
08-P-0266
09/16/2008
Report Summary
EPA, rather than the States, has the responsibility for protecting human health and the
environment on tribal lands. Approximately 600 tribal community water systems (CWSs) serve
an estimated 622,000 people. EPA staff members provide these systems with technical and other
assistance so that tribal CWSs maintain compliance with Safe Drinking Water Act requirements.
We conducted this evaluation to assess EPA's oversight and assistance of tribal CWSs, and to
independently evaluate water quality at selected drinking water systems.
Tribal drinking water sample results in EPA files indicate that drinking water supplies
consistently met regulatory requirements. Regional EPA staff also made correct compliance
decisions with sample results that tribal CWSs provided. However, the OIG found internal
control deficiencies in administering EPA's oversight of tribal CWSs in two of the five regions
we reviewed. To varying degrees, tribal drinking water records in four of the five regions were
incomplete due to a failure to maintain oversight of system operations and/or poor records
management.
Unimplemented Recommendation
Recommendation 2-3: We recommend that the Assistant Administrator for OW direct regions
to issue monitoring and reporting violations, take appropriate enforcement actions against tribal
CWSs with health-based violations or who fail to monitor or submit monitoring reports, and
enter violations into Safe Drinking Water Information System.
Status: OW planned to issue guidance regarding expectations of regions implementing the
tribal drinking water program. The original agreed-to completion date was April 30, 2009.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office:
Report Title:
Report No.:
Date Issued:
OECA
EPA Needs to Track Compliance with Superfund Cleanup Requirements
08-P-0141
04/28/2008
Report Summary
According to EPA's Superfund information system, there were 3,397 active Superfund
enforcement instruments to ensure clean-ups at National Priorities List sites as of September 30,
2007. Yet, EPA does not nationally compile or track data on substantial noncompliance (SNC)
with the terms or requirements of these instruments. Therefore, we were not able to fully
determine whether the regions have resolved Superfund instrument violations consistent with
criteria and authorities. In 2000, though, EPA recognized it needed to improve in this area. It
issued an internal report recommending that the regions improve their data on the compliance
status of Superfund enforcement instruments and responses to noncompliance. However, EPA
has not implemented this recommendation. Consequently, the Agency lacks the internal controls
necessary to monitor compliance with Superfund instruments nationally.
In a limited review of EPA regions' enforcement records, we found that two regions were
consistent with EPA guidance and authorities when they took enforcement actions in 12
instances of SNC. While the regions took appropriate actions to address these 12 violations,
Region 5 had not established necessary and enforceable requirements to address contamination
from the Muskego Landfill Site, in Waukesha County, Wisconsin. The report was issued to
OECA and Region 5. However, Region 5 has no past-due corrective actions recorded in MATS.
Unimplemented Recommendations
Recommendation 3: We recommend that the Assistant Administrator for OECA annually
review the Comprehensive Environmental Response, Compensation, and Liability Information
System (CERCLIS) compliance data to monitor Agency status and progress in managing SNC
by way of Superfund instruments.
Status: OECA stated that CERCLIS data will be pulled to establish a baseline for the
status of compliance with Superfund enforcement instruments. This is based upon
compliance monitoring data for FY 2008. This process will be repeated annually after
November 2009. The agreed-to completion date was November 30, 2009.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office: OCFO
Report Title: Audit of EPA's Fiscal 2007 and 2006 (Restated) Consolidated Financial
Statements
Report No.:	08-1-0032
Date Issued: 11/15/2007
Report Summary
We rendered an unqualified, or clean, opinion on EPA's Consolidated Financial Statements for
Fiscal Years 2007 and 2006 (restated), meaning that they were fairly presented and free of
material misstatement. We noted one material weakness with EPA's Implementation of the
"Currently Not Collectible" policy for accounts receivable that caused a Material
Understatement of Asset Value and led to the restatement of the Fiscal Year 2006 financial
statements. Further, we noted the following six significant deficiencies:
•	EPA did not properly compute an allowance for doubtful accounts.
•	EPA needs to improve internal controls in recording and accounting for accounts
receivable.
•	Key applications do not meet federal and EPA information security requirements.
•	Access and security practices over critical information technology assets need
improvement.
•	EPA needs to improve controls over the Integrated Financial Management System
Suspense Table.
•	EPA did not maintain adequate documentation for obligating accounting adjustments.
Unimplemented Recommendations
Recommendation 18: We recommend that the Chief Financial Officer conduct and document
an annual verification and validation of implemented procedures to ensure controls are
implemented as intended and are effective.
Status: According to MATS, OARM incorporated the verification and validation process
into their contract by November 11, 2007. However, during a follow-up review, OIG
found that EPA had not completed the corrective actions associated with this
recommendation. The OIG also found that EPA was not performing monthly server
vulnerability scanning as stated in the OARM Server Scanning standard operating
procedures.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office: OW
Report Title: Total Maximum Daily Load Program Needs Better Data and Measures to
Demonstrate Environmental Results
Report No.:	2007-P-00036
Date Issued: 09/19/2007
Report Summary
EPA does not have comprehensive information on the outcomes of the Total Maximum Daily
Load (TMDL) program nationwide, nor national data on TMDL implementation activities. EPA
and States are responsible for implementing point source TMDLs; however, EPA cannot identify
all of the permitted dischargers that should receive or have received wasteload allocations.
Measuring nonpoint source TMDL implementation is difficult because EPA does not have
statutory authority to regulate nonpoint sources and it is highly dependent on State and local
stakeholders. EPA's lack of information prevents the Agency from determining the extent to
which TMDLs are restoring impaired waters and whether TMDL implementation activities are
occurring in a timely manner.
EPA has begun to take steps to measure program results and improve program data, sponsored
several studies of TMDL implementation, and is studying additional TMDL results measures.
Developing meaningful measures is challenging; however, EPA needs to provide more
management direction to improve its ability to assess how well this critical program is
functioning. The TMDL and performance measures we reviewed do not provide clear and
complete metrics of the program's accomplishments.
Unimplemented Recommendation
Recommendation 1-2: We recommend that the Assistant Administrator for OW demonstrate
that TMDLs are being implemented by annually reporting on the progress of TMDL
implementation activities completed nationwide including the number of TMDLs:
•	that have all wasteload allocations incorporated into NPDES permits,
•	that have implemented load allocations through at least one best management practice
funded through the Section 319 Program, and
•	for which implementation data are not available to EPA.
Status: According to MATS, OW has:
•	Reported on TMDL implementation rates, including point source permits and
nonpoint source best management practices, through a statistical study covering
EPA Region 5.
•	Completed development of a national statistical study design to assess TMDL
implementation rates.
•	Queried EPA data systems and issued its first annual national report on the three
metrics specified in 1-2.
OW has three corrective actions that have not been completed for this
recommendation:
•	Complete development of an information collection rule (ICR) that covers
assessments of TMDL implementation.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
•	Produce a synthesis paper covering the findings from multiple implementation-
related studies.
•	Initiate national sample-based assessment upon ICR approval.
The agreed-to completion date for these actions was December 31, 2009. The OW
indicated that they have not proposed rescheduled completion dates for — developing the
ICR and completing a national sample-based assessment — because they plan to request
modifications to these corrective actions with the OIG. OW feels that the relevance of
the ICR to the TMDL implementation survey is questionable. If the ICR is no longer
essential to the implementation survey as originally conceived, OW could potentially
request that the ICR's development be withdrawn as a corrective action. OW also stated
that the value-added worth of a national TMDL implementation survey, estimated to cost
$400,000 or more in 2007, is also questionable given improved knowledge about
implementation and budgetary constraints. OW's position is that the survey would not be
cost effective and should be withdrawn as a corrective action.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office: OECA
Report Title: Overcoming Obstacles to Measuring Compliance: Practices in Selected
Federal Agencies
Report No.:	2007-P-00027
Date Issued: 06/20/07
Report Summary
Federal regulatory agencies with missions and obstacles similar to EPA use statistical methods to
generate compliance information. They use this information to monitor their enforcement and
compliance programs and to demonstrate program results. These federal programs extensively
use statistical methods to identify and analyze risk, set goals, develop strategies to manage the
most significant risks, and report their accomplishments. We performed this review to collect
successful practices from federal agencies similar to OECA that extensively use statistical
methods, including random sampling, to measure and ensure compliance and to monitor
regulatory programs. While the programs the OIG reviewed face similar obstacles as OECA,
they use practical approaches to overcome these obstacles that OECA could potentially apply to
its programs.
Unimplemented Recommendation
Recommendation 2-1: We recommend that the Assistant Administrator for OECA establish a
plan of action with milestones to incorporate using statistical methods to demonstrate the results
of EPA's enforcement and compliance strategies.
Status: OECA agreed to develop an action plan to expand the use of statistically valid
compliance rates for specific noncompliance patterns focused on national priorities or
other important problem areas. The agreed-to completion date for this corrective action
was December 31, 2008.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office:	OSWER
Report Title:	EPA Can Better Manage Superfund Resources
Report No.:	2006-P-00013
Date Issued:	02/28/2006
Report Summary
The Superfund Trust Fund has decreased over the years so that in Fiscal Years 2004 and 2005,
all Superfund appropriations came from general tax revenue rather than the Trust Fund. Recent
studies have reported shortages in funding needs for Superfund and have identified needed
improvements in how the program is managed. We performed this review in response to a
congressional request to evaluate Superfund expenditures at Headquarters and the regions.
EPA has been unable to allocate and manage Superfund resources for clean-up as efficiently and
effectively as possible because of the way the Agency accounts for program resources, manages
by functions, supplements the program with other funds, relies on an outdated workload model,
and maintains unliquidated Superfund obligations and funds in special accounts. Close
alignment of offices that support the Superfund program and production of program performance
and cost data have been limited because EPA disperses the responsibility for allocating and
managing program resources.
Unimplemented Recommendation
Recommendation 2-3 - Accounting Definitions: We recommend to the Assistant
Administrator for OSWER that EPA should agree to define costs in a manner that supports
management decision making and improve their accounting of such resources to maximize
achieving program goals.
Status: OSWER reported in MATS that Recommendation 2-3 is partially implemented.
Two planned corrective actions addressed this recommendation. To support management
decision making, EPA modified Superfund E-Facts to reflect Superfund site cost data.
The module is available for use by EPA staff. This action is considered completed.
OCFO is determining if the Agency's new centralized financial management system will
solve the accounting definition issue. If not, OCFO may consider having system
adjustments made. The new centralized system is planned to be operational by
October 1, 2010.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office: OPPTS
Report Title: Opportunities to Improve Data Quality and Children's Health through the
Food Quality Protection Act
Report No.:	2006-P-00009
Date Issued: 01/10/2006
Report Summary
We performed this review to examine the impact of the Food Quality Protection Act of 1996 on
the EPA's need for scientific data and predictive tools, particularly in relation to children's
health. This report is the second in a series of three reports on the Act's impact on EPA
regarding children's health. We specifically sought in this review to determine:
•	What data requirements were required by the Food Quality Protection Act
•	Whether testing guidelines, requirements, and evaluation procedures allow EPA's Office
of Pesticide Programs (OPP) to determine the potential adverse effects of pesticide
exposure on the developing nervous system
•	What challenges OPP overcame and what opportunities exist for OPP to acquire better
pesticide exposure data to aggregate risks
•	What challenges exist and what opportunities are available for OPP to improve
cumulative risk assessments
•	What opportunities exist to better manage pesticide health risk for children
Unimplemented Recommendation
Recommendation 4-1: We recommend that the Acting Assistant Administrator for OPPTS
update the dietary exposure databases used in probabilistic models for risk assessments as soon
as the food consumption data from the 2003-2004 National Health and Nutrition Examination
Survey (NHANES) become available in 2006. EPA should also update the Food Commodity
Intake Database (FCID) with the latest food consumption survey data, and if possible use data
such as the Gerber Products Company's Feeding Infants and Toddlers Study.
Status: OPP has continued to collaborate with our partners in the Centers for Disease
Control and Prevention's National Center for Health Statistics and the U.S. Department
of Agriculture (USD A) to transition to the new consumption data. OPP met with
USDA's Human Nutrition Survey in December 2007 regarding using this food
consumption database to develop the requisite food commodity consumption database,
FCID. In 2008, OPP began discussions on a variety of statistical issues with USDA's
survey statisticians on the appropriate methods for combining NHANES survey cycles.
At that time, OPP decided to adjust its pace in this area to allow us to obtain more years
of data from the NHANES survey such that the resulting database includes more survey
respondents and is more robust. In 2009, OPP met with personnel from USDA's Nutrient
Data Laboratory and completed the majority of the recipe work. Also in 2009, OPP
began working with ORD's National Center for Environmental Assessment and OW to
incorporate the updated FCID into our exposure and risk assessment software. The
agreed-to completion date was December 31, 2006. OPP anticipates completing the
actions for this recommendation by summer 2010.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office:
Report Title:
Report No.:
Date Issued:
OW
More Information Is Needed on Toxaphene Degradation Products
2006-P-00007
12/16/2005
Report Summary
Toxaphene in the environment changes, or degrades. The resulting degradation products are
different from the original toxaphene in chemical composition and how they appear to testing
instruments, so they could go unreported. The analytical methods EPA uses to identify and
measure toxaphene are not designed to identify toxaphene degradation products. However, a
new testing method used by others specifically tests for toxaphene degradation products. We
believe EPA should validate, approve, and use this method. Certain toxaphene degradation
products accumulate inside people. Although studies indicate that some of these degradation
products may be harmful, more research is needed to determine how much of a risk these
products pose to people. The report recommendations were reported to OA, OW, OSWER and
ORD, OA and ORD have no past-due corrective actions recorded in MATS.
Unimplemented Recommendations
Recommendation 2: We recommend that the Administrator direct the Assistant Administrators
for ORD, OW and OSWER to arrange for specific research into the dangers of tumors (i.e.,
cancer) and of harm to embryos posed principally by a mixture of toxaphene congeners and
metabolites found in fish.
Status: OW anticipated completing the third Contaminant Candidate List by August 31,
2009.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office: OAR
Report Title: Substantial Changes Needed in Implementation and Oversight of Title V
Permits If Program Goals Are to Be Fully Realized
Report No.:	2005-P-00010
Date Issued: 03/09/2005
Report Summary
Title V of the Clean Air Act, designed to reduce violations and improve enforcing air pollution
laws for the largest sources of air pollution, requires that all major stationary sources of air
pollutants obtain a permit to operate. More than 17,000 sources are subject to Title V permit
requirements. Our analysis identified concerns with five key aspects of Title V permits:
(1) permit clarity, (2) statements of basis, (3) monitoring provisions, (4) annual compliance
certifications, and (5) practical enforceability. One finding in particular relates to compliance
certifications and wording on credible evidence. When EPA amended the rule on continuous or
intermittent compliance,1 a key clause on credible evidence was inadvertently left out.
(Recommendation 2-2 addresses this issue.)
Collectively, these problems can hamper the ability of EPA, State and local regulators, and the
public to understand what requirements sources are subject to, how they will be measured, and
ultimately to hold sources accountable for meeting applicable air quality requirements. EPA's
oversight and guidance of Title V activities have resulted in some improvements in Title V
programs; however, areas needing further improvement remain.
Unimplemented Recommendations
Recommendation 2-1: We recommend that the Assistant Administrator for OAR develop and
issue guidance or rulemaking on annual compliance certification content which requires
responsible officials to certify compliance with all applicable terms and conditions of the permit,
as appropriate.
Status: EPA stated in MATS that based on recommendations from the Clean Air Act
Advisory Group Task Force on Title V Implementation, the Office of Air Quality
Planning and Standards has begun developing a guidance document that will include,
among other topics, guidance on compliance certifications. However, EPA has not
submitted a formal action plan stating how it plans to address this recommendation to the
OIG for approval.
Recommendation 2-2: We recommend that the Assistant Administrator for OAR issue the draft
rule regarding intermittent versus continuous monitoring as it relates to annual compliance
certifications and including credible evidence.
Status: EPA did not concur with this recommendation, and it remains unresolved. The
Agency met with the OIG in July 2009 and is providing additional information. The OIG
believes this recommendation is key to knowing the basis of the permittee's reported
compliance with the terms and conditions of its Title V permit that underlies its annual
compliance certification.
1 40 Code of Federal Regulations 70.6 (c)(5)(iii)(B)
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Recommendation 2-3: We recommend that the Assistant Administrator for OAR develop
nationwide guidance or rulemaking, as appropriate, on the contents of statements of basis which
includes discussions of monitoring, operational requirements, regulatory applicability
determinations, explanations of any conditions from previously issued permits that are not being
transferred to the Title V permit, discussions of streamlining requirements, and other factual
information, where advisable, including a listing of prior Title V permits issued to the same
applicant at the plant, attainment status, and construction, permitting, and compliance history of
the plant.
Status: OAR plans to work with the regions to disseminate information about the
positions EPA has taken on statements of basis in response to citizens programs and
permit petitions. OAR also intends to develop a plan for identifying and sharing with
permitting agencies those statements of basis that represent "best practices." This effort
is planned to be included in guidance documentation addressing Recommendation 2-1.
However, EPA has not submitted a formal action plan stating how it plans to address this
recommendation to the OIG for approval.
Recommendation 3-1: We recommend that the Assistant Administrator for OAR promulgate
the draft order of sanctions rule which provides notice to State and local agencies, as well as the
public, regarding the actions that will be taken when Notices of Deficiency are not timely
resolved by State and local Title V permitting authorities.
Status: EPA did not concur with this recommendation, and it remains unresolved. The
Agency met with the OIG in July 2009 and is providing additional information. The OIG
believes this issue involves basic program criteria needed for EPA to oversee the Title V
program.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office:
Report Title:
Report No:
Date Issued:
OW
EPA Needs to Reinforce Its National Pretreatment Program
2004-P-00030
09/28/2004
Report Summary
The reductions in industrial waste discharges to the nation's sewer systems that characterized the
early years of the National Pretreatment Program have not endured. Since the middle of the
1990s, there has been little change in the volume of a broad list of toxic pollutants transferred to
Publicly Owned Treatment Works (POTWs) or in the index of risk associated with these
pollutants. As a result, the performance of EPA's pretreatment program, which is responsible for
controlling these discharges, is threatened, and progress toward achieving the Clean Water Act
goal of eliminating toxic discharges that can harm water quality has stalled.
The curtailing of the early gains may be explained in part by two factors: (1) dischargers that
developed systems in response to EPA's initial program requirements have not enhanced their
pretreatment systems in recent years, and (2) the rate at which EPA has been issuing effluent
guidelines dramatically declined since 1990. Without more visible leadership from
Headquarters, improved programmatic information, and the adoption of results-based
performance measures, EPA's pretreatment program is at risk of losing the gains it made in its
early years.
Unimplemented Recommendation
Recommendation 4-1: We recommend that the Acting Assistant Administrator for OW direct
staff to develop a long-term strategy to identify the data it needs for developing pretreatment
results-based measurements; determine the resources necessary to carry out the strategy; and
gain the support of other Agency, State, and POTW staff to carry out the strategy..
Status: OW agreed to request information on databases used by the EPA regions and
States to store information regarding POTW pretreatment program performance.
Through the Permitting for Results process, OW will compile information regarding
current data systems used to store pretreatment data at the EPA regional and State level.
OW intends to use this information to identify inaccurate data and target data correction
in the Permit Compliance System. Both of these activities are crucial to facilitate
migration and retention of data as we transition to the Integrated Compliance Information
System. Once these efforts are complete, OW will be able to determine a long-term
strategy based on data availability and resources, which should ultimately assist it in
developing pretreatment results-based measurements. The agreed-to completion date for
this corrective action was September 30, 2007.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Action Office:
Report Title:
Report No:
Date Issued:
OW
Wastewater Management: Controlling and Abating Combined Sewer Overflows
2002-P-00012
08/26/2002
Report Summary
Combined sewer overflows (CSOs) are the total discharges into waterbodies of untreated
domestic, commercial, industrial waste, wastewater, and storm water runoff, which can adversely
affect the health of humans, animals, and aquatic organisms, as well as cause beach closings and
fishing and recreational restrictions. We found that many communities do not as yet have the
data to determine the effect of CSO controls on water quality. Most communities were only
monitoring the number, volume, and duration of CSO discharges, and did not have data on the
effect CSO controls were having on the quality of receiving waters. This was because EPA does
not require monitoring until completion of CSO projects. Consequently, it could not be
determined until it was too late whether each CSO project being undertaken was a wise
investment of taxpayers' dollars.
Unimplemented Recommendation
Recommendation 5-1: We recommend that the Assistant Administrator for OW work with CSO
permitting authorities and communities to assure they negotiate and establish the proper level of
interim monitoring of CSO efforts to determine the impact of the project on water quality.
Status: OW agreed to initiate an effort at EPA Headquarters to develop a compilation of
the monitoring approaches that are or may be used in different situations. This
compilation, which will be available in Fiscal Year 2009, will help permit writers
develop appropriate monitoring expectations for those permitees that have completed
construction of their planned CSO controls. In August 2008, EPA reached a settlement
filed in U.S. District Court for the Central District of California that requires EPA to
complete studies and develop new recreational water quality criteria by October 2012.
The agreed-to completion date was September 30, 2009.
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Appendix A
OIG Reports with
Unimplemented Recommendations
by Program Office
as of March 31, 2010
OA	
09-P-0089, EPA Needs a Comprehensive Research Plan and Policies to Fulfill Its Emerging Climate Change Role
OAR	
2005-P-00010,	Substantial Changes Needed in Implementation and Oversight of Title V Permits If Program Goals
Are to Be Fully Realized
OARM	
09-P-0242, Contractor Invoice Internal Controls Need Improvement
09-P-0229, EPA Should Stop Providing Estimates of Total Labor Hours to Contractors
09-P-0197, EPA Should Delay Deploying Its New Acquisition System until Testing Is Completed
OCFO	
09-P-0203, EPA Should Use FMFIA to Improve Programmatic Operations
08-1-0032, Audit of EPA's Fiscal 2007 and 2006 (Restated) Consolidated Financial Statements
OECA	
08-P-0141,	EPA Needs to Track Compliance with Superfund Cleanup Requirements
2007-P-00027, Overcoming Obstacles to Measuring Compliance: Practices in Selected
Federal Agencies
OPPIS	
2006-P-00009,	Opportunities to Improve Data Quality and Children's Health through the Food Quality Protection
Act
ORD	
09-P-0232,	EPA's Office of Research and Development Could Better Use the Federal Managers' Financial Integrity
Act to Improve Operations
09-P-0089, EPA Needs a Comprehensive Research Plan and Policies to Fulfill Its Emerging Climate Change Role
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
OSWER	
2006-P-00013,	EPA Can Better Manage Superfund Resources
ow	
09-P-0223, EPA Needs to Accelerate Adoption of Numeric Nutrient Water Quality
08-P-0266, EPA Assisting Tribal Water Systems but Needs to Improve Oversight
2007-P-00036,	Total Maximum Daily Load Program Needs Better Data and Measures to Demonstrate
Environmental Results
2006-P-00007, More Information Is Needed on Toxaphene Degradation Products
2004-P-00030, EPA Needs to Reinforce Its National Pretreatment Program
2002-P-00012, Wastewater Management: Controlling and Abating Combined Sewer Overflows
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Appendix B
Unimplemented Recommendations
10/28/09 Compendium Compared to Current Compendium
Continuing Unimplemented Recommendations	
08-P-0266, EPA Assisting Tribal Water Systems but Needs to Improve Oversight (Recommendation 2-3)
08-1-0032,	Audit of EPA's Fiscal 2007 and 2006 (Restated) Consolidated Financial Statements
(Recommendation 18)
2007-P-00027, Overcoming Obstacles to Measuring Compliance: Practices in Selected
Federal Agencies (Recommendation 2-1)
2006-P-00009, Opportunities to Improve Data Quality and Children's Health through the Food Quality Protection
Act (Recommendation 4-1)
2006-P-00007,	More Information Is Needed on Toxaphene Degradation Products (Recommendation 2)
2005-P-00010,	Substantial Changes Needed in Implementation and Oversight of Title V Permits If Program Goals
Are to Be Fully Realized (Recommendations 2-1,2-2,2-3,3-1)
2004-P-00030, EPA Needs to Reinforce Its National Pretreatment Program (Recommendation 4-1)
New Unimplemented Recommendations
09-P-0242,	Contractor Invoice Internal Controls Need Improvement (Recommendations 2-1,2-2,2-4,3-1,3-2)
09-P-0232, EPA's Office of Research and Development Could Better Use the Federal Managers' Financial Integrity
Act to Improve Operations (Recommendation 2-3)
09-P-0229, EPA Should Stop Providing Estimates of Total Labor Hours to Contractors (Recommendations 1,2)
09-P-0223, EPA Needs to Accelerate Adoption of Numeric Nutrient Water Quality (Recommendations 2-3,2-4,
2-5)
09-P-0203, EPA Should Use FMFIA to Improve Programmatic Operations (Recommendation 3)
09-P-0197, EPA Should Delay Deploying Its New Acquisition System until Testing Is Completed
(Recommendations 1,2,3,4)
09-P-0089, EPA Needs a Comprehensive Research Plan and Policies to Fulfill Its Emerging Climate Change Role
(Recommendations 3-1,3-3,3-4,3-5)
08-P-0141, EPA Needs to Track Compliance with Superfund Cleanup Requirements (Recommendation 3)
2007-P-00036,	Total Maximum Daily Load Program Needs Better Data and Measures to Demonstrate
Environmental Results (Recommendation 1-2)
2006-P-00013,	EPA Can Better Manage Superfund Resources (Recommendation 2-3)
2002-P-00012, Wastewater Management: Controlling and Abating Combined Sewer Overflows
(Recommendation 5-1)
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Compendium of Unimplemented Recommendations as of March 31, 2010
(Report No. 10-N-0114)
Removed Unimplemented Recommendations
09-P-0129, EPA Can Improve Managing of Working Capital Fund Overhead Costs (Recommendations 1,3)
09-P-0119, Improved Management of Superfund Special Accounts Will Make More Funds Available for Clean-ups
(Recommendation 4)
09-P-0097, Results of Technical Network Vulnerability Assessment: EPA Headquarters (Recommendations 1,2,
3)
09-P-0055, Results of Technical Network Vulnerability Assessment: EPA's Research Triangle Park Campus
(Recommendations 1,2,3)
09-P-0029, EPA's Safety Determination for Delatte Metals Superfund Site Was Unsupported (Recommendations
2-2,2-4)
09-1-0026, Audit of EPA's Fiscal 2008 and 2007 Consolidated Financial Statements (Recommendation 27)
08-P-0265, EPA Should Continue Efforts to Reduce Unliquidated Obligations in Brownfields Pilot Grants
(Recommendation 3)
08-P-0235, EPA Decisions to Delete Superfund Sites Should Undergo Quality Assurance Review
(Recommendations 2-4,2-5,3-1)
08-P-0199, EPA Needs to Better Report Chesapeake Bay Challenges - A Summary Report (Recommendation 1)
08-P-0116, EPA Can Recover More Federal Superfund Money (Recommendation 2)
08-P-0049, Despite Progress, EPA Needs to Improve Oversight of Wastewater Upgrades in the Chesapeake Bay
Watershed (Recommendation 2-4)
08-1-0032, Audit of EPA's Fiscal 2007 and 2006 (Restated) Consolidated Financial Statements
(Recommendation 12)
2007-P-00028, ENERGY STAR Program Can Strengthen Controls Protecting the Integrity of the Label
(Recommendation 3-1)
2007-P-00008, EPA Could Improve Controls Over Mainframe System Software (Recommendations 9,17)
2007-P-00007, EPA Could Improve Processes for Managing Contractor Systems and Reporting Incidents
(Recommendation 2-1)
2006-P-00038, Existing Contracts Enabled EPA to Quickly Respond to Hurricane Katrina: Future Improvement
Opportunities Exist (Recommendation 4-l(bullet 5))
2006-P-00016, EPA Can Better Implement Its Strategy for Managing Contaminated Sediments
(Recommendations 3-1,3-2)
2006-P-00013, EPA Can Better Manage Superfund Resources (Recommendation 2-3)
2005-P-00011, Security Configuration and Monitoring of EPA's Remote Access Methods Need Improvement
(Recommendations 2-1,2-2,2-3,2-4)
2004-P-00013, EPA's Administration of Network Firewalls Needs Improvement (Recommendations 2-1,3-2)
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