^60srx
| U.S. ENVIRONMENTAL PROTECTION AGENCY
pro^s° OFFICE OF INSPECTOR GENERAL
Cleaning up and revitalizing land
EPA Does Not Consistently Monitor
Hazardous Waste Units Closed with
Waste in Place or Track and Report
on Facilities That Fall Under the Two
Responsible Programs
Report No. 21-P-0114 March 29, 2021
Sretf Plains
Monterrey
MEXICO
-------
Report Contributors:
Steve Hanna
Kate Robinson
Jonathan Morrand
Brenda Vazquez-Fuentes
Tina Lovingood
Abbreviations
CEI
Compliance Evaluation Inspection
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
EPA
U.S. Environmental Protection Agency
Fed. Reg.
Federal Register
GME
Groundwater Monitoring Evaluation
NPL
National Priorities List
OAM
Operation-and-Maintenance Inspection
OECA
Office of Enforcement and Compliance Assurance
OIG
Office of Inspector General
RCRA
Resource Conservation and Recovery Act
SEMS
Superfund Enterprise Management System
TSDF
Treatment, Storage, or Disposal Facility
U.S.C.
United States Code
Cover Photo: Map of hazardous waste facilities with units closed with waste in place. Green
represents operating facilities, and red represents nonoperating facilities.
(OIG data from RCRAInfo mapped by EPA technical staff) (EPA OIG image)
Are you aware of fraud, waste, or abuse in an
EPA program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
Washington, D.C. 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.gov
Learn more about our OIG Hotline.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, D.C. 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions
-------
^tDsrx
I®!
U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
21-P-0114
March 29, 2021
Why We Did This Audit
We audited the
U.S. Environmental Protection
Agency's oversight of
hazardous waste units closed
with waste in place to verify the
continued protection of human
health and the environment.
The Resource Conservation and
Recovery Act and corresponding
RCRA regulations establish
requirements pertaining to
hazardous waste treatment,
storage, or disposal facilities, or
TSDFs. TSDFs treat, store, or
dispose of hazardous waste in
management units, such as
landfills. When a RCRA unit
stops accepting waste, the
TSDF must clean close or close
and maintain the unit with waste
in place in accordance with
RCRA regulations. RCRA and
EPA policies call for each
permitted TSDF, including
RCRA units, to be inspected at
least once every two to three
years, depending on its
operational status.
This report addresses the
following:
• Cleaning up and revitalizing land.
• Partnering with states and
other stakeholders.
This report addresses a top EPA
management challenge:
• Overseeing states
implementing EPA programs.
• Communicating risks.
• Integrating and leading
environmental justice.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
EPA Does Not Consistently Monitor Hazardous
Waste Units Closed with Waste in Place or Track
and Report on Facilities That Fall Under the Two
Responsible Programs
What We Found
The EPA did not consistently verify the continued
protection of human health and the environment
at TSDFs with RCRA units that were closed with
hazardous waste in place. Specifically, almost
half (339 of 687, or 49.3 percent) of TSDFs with
RCRA units closed with waste in place were not
inspected at the frequency set by EPA policy.
EPA regional oversight of TSDF inspections by authorized states is also
inconsistent. Five of the ten EPA regions incorporate inspection commitments in
their annual state RCRA grant negotiations to verify that their authorized states
are complying with the inspection policy. Two regions have similar processes in
place, but their processes do not include all their states, and three regions do not
have any process in place to verify compliance. Because of the lack of
inspections, a hazardous waste leak from a compromised unit could go
undetected for years, with dire human health and environmental consequences.
For example, a leak that is not expeditiously detected could contaminate
groundwater, resulting in a loss of drinking water supply, high cleanup costs, and
human exposure to contaminants.
During our evaluation of units closed with waste in place, we observed some
issues with interactions between the RCRA and Superfund programs. EPA
oversight of RCRA units referred to the Superfund program and those deferred
back to the RCRA program is incomplete. The lack of procedures and the use of
differing facility identification numbers in the two programs have hindered the
EPA's tracking of facilities transferred between the two programs. As a result, it
is uncertain whether either program is appropriately managing RCRA units and
protecting human and environmental health.
Fifty-six RCRA Corrective Action facilities that were closed with waste in place
are also managed by the Superfund program. Ineffective EPA oversight of these
sites resulted in 42 possible conflicting and 126 double-counted accomplishment
milestones. Because these milestones are used to communicate site status to
the public, communities could be confused or misled as to the cleanup status of
the sites.
Recommendations and Planned Corrective Actions
We recommend that the assistant administrator for Land and Emergency
Management develop controls to improve oversight of RCRA units with waste in
place. Three of the six recommendations are resolved with corrective actions
pending, and resolution efforts are in progress for the other three.
The EPA's inspection
frequency of TSDFs with
RCRA units closed with
waste in place does not
meet the EPA's statutory
requirement or policy.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
March 29, 2021
MEMORANDUM
SUBJECT: EPA Does Not Consistently Monitor Hazardous Waste Units Closed with Waste in Place
or Track and Report on Facilities That Fall Under the Two Responsible Programs
Report No. 21-P-0114
This is our report on the subject audit conducted by the Office of Inspector General of the
U.S. Environmental Protection Agency. The project number for this audit was OA&E-FY19-0323. This
report contains findings that describe the problems the OIG has identified and corrective actions the OIG
recommends. Final determinations on matters in this report will be made by EPA managers in accordance
with established audit resolution procedures.
The Office of Land and Emergency Management and the Office of Enforcement and Compliance
Assurance are responsible for the issues discussed in this report.
We make six recommendations in this report. In accordance with EPA Manual 2750, your offices provided
acceptable planned corrective actions and estimated milestone dates in response to Recommendations 1,
3, and 4. These recommendations are resolved.
Action Required
Recommendations 2, 5, and 6 are unresolved. The resolution process, as described in the EPA's Audit
Management Procedures, begins immediately with the issuance of this report. Furthermore, we request a
written response to the final report within 60 days of this memorandum. Your response will be posted on
the OIG's website, along with our memorandum commenting on your response. Your response should be
provided as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the
Rehabilitation Act of 1973, as amended. The final response should not contain data that you do not want
to be released to the public; if your response contains such data, you should identify the data for redaction
or removal along with corresponding justification.
FROM: Sean W. O'Donnell
TO:
Barry Breen, Acting Assistant Administrator
Office of Land and Emergency Management
Lawrence E. Starfield, Acting Assistant Administrator
Office of Enforcement and Compliance Assurance
We will post this report to our website at www.epa.gov/oig.
-------
EPA Does Not Consistently Monitor Hazardous 21-P-0114
Waste Units Closed with Waste in Place or
Track and Report on Facilities That Fall Under the
Two Responsible Programs
Table of Contents
Chapters
1 Introduction 1
Purpose 1
Background 1
Scope and Methodology 8
Responsible Offices 10
Prior Reports 10
2 RCRA Units Closed with Waste in Place Are Not Inspected Consistent
with the RCRA Statute or EPA Policy 11
About Half of TSDFs with RCRA Units Closed with Waste in Place
Not Inspected Within the Policy Time Frame 11
EJSCREEN Demographic Index of Communities Around TSDFs with
Units Closed with Waste in Place Is Close to National Average 13
EPA Regional Oversight of Inspections Varies 13
Conclusions 14
Recommendations 15
Agency Response and OIG Assessment 15
3 Tracking Facilities Between RCRA and Superfund Programs Is
Problematic 16
Referrals of RCRA Units to Superfund and Deferrals Back to RCRA
Are Not Tracked or Monitored 16
Environmental Indicator and Ready-for-Reuse Accomplishments Differ
or May Be Double-Counted Between Programs and Result in
Confusing Risk Communication Messages to the Public 18
Conclusions 20
Recommendations 21
Agency Response and OIG Assessment 21
Status of Recommendations and Potential Monetary Benefits 23
—continued-
-------
EPA Does Not Consistently Monitor Hazardous 21-P-0114
Waste Units Closed with Waste in Place or
Track and Report on Facilities That Fall Under the
Two Responsible Programs
Appendices
A Internal Control Assessment 24
B Sites on the Corrective Action Program and the National Priorities List 25
C Agency Response to Draft Report 28
D Distribution 34
-------
Chapter 1
Introduction
Purpose
We audited the U.S. Environmental
Protection Agency's oversight of
hazardous waste units closed with
waste in place to verify the continued
protection of human health and the
environment.
Background
The EPA regulates the management
and disposal of hazardous waste using
the authority granted by the Resource
Conservation and Recovery Act,
Subtitle C. In general terms, hazardous
waste is waste with properties that make it dangerous or potentially harmful to
human health or the environment. RCRA authorizes the EPA to develop
regulations to effect the safe management of hazardous waste in or on land.
RCRA defines land disposal as the placement of hazardous waste in a variety of
units, such as landfills, waste piles, and land treatment facilities. We refer to these
land disposal units as RCRA units in this report. A hazardous waste-management
facility receives hazardous waste for treatment, storage, or disposal. These
facilities are referred to as treatment, storage, or disposal facilities, or TSDFs.
Before they can accept hazardous waste, TSDFs must apply for and receive a
RCRA permit from the EPA or a state or territory authorized by the EPA to issue
RCRA permits. Permitted TSDFs must meet stringent requirements for RCRA
units, including the use of double liners, collection of leachate, and detection of
leaks for landfill units (Figure 1). A TSDF may have multiple RCRA units.
Hazardous waste may include a broad range of constituents, including chemicals
known to be human carcinogens. For example, one chemical disposed at TSDFs is
trichloroethylene, a widely used industrial chemical and a known human
carcinogen. If RCRA units are not properly maintained or if their covers or liners
fail over time, the hazardous waste stored within the units can leak into the
environment, contaminating groundwater and drinking water sources. Preventing
contaminants like trichloroethylene from leaking into the groundwater reduces the
health risks associated with poor drinking water quality.
Top Management Challenge
This audit addresses the following top
management challenges for the Agency, as
identified in OIG Report No. 21-N-0231. EPA's FYs
2020-2021 Top Management Challenges, issued
July 21, 2020:
• Overseeing states, territories, and tribes
implementing EPA programs.
• Communicating risks to allow the public to
make informed decisions about its health and
the environment.
• Integrating and leading environmental justice
across the Agency and government.
21-P-0114
1
-------
Figure 1: Cross-section of a RCRA hazardous waste landfill
Top Liner
Iff'
Matfirial
Leak Detection System
Secondary Leachate
Collection and Removal
System
Native Soil Foundation
Primary Leachate
and Collection
Removal System
Bottom Composite Liner
Source: EPA Training Module Introduction to Land Disposal Units, September 2005.
(EPA image)
EPA's Strategic Plan and RCRA Program
In its FY 2018-2022 U.S. EPA Strategic Plan, the EPA addresses its plans to
regulate hazardous waste under Objective 1.3:
EPA will update and improve the efficiency of the RCRA
hazardous waste regulations to meet the needs of today's business
and industry to ensure protective standards for managing
hazardous waste. To prevent future environmental contamination
and to protect the health of the estimated 20 million people living
within a mile of a hazardous waste management facility, EPA will
support states to issue, update, or maintain RCRA permits for the
approximately 20,000 hazardous waste units (such as incinerators
and landfills) at these facilities.
TheFY2018-2022 U.S. EPA Strategic Plan also states, under Objective 3.3, that
over the next five years, the EPA will "[ajssess the impact of pollution (e.g.,
health impact assessments) on such vulnerable groups as children, tribes,
environmental justice communities, and other susceptible populations."
The EPA defines environmental justice as "the fair treatment and meaningful
involvement of all people regardless of race, color, national origin, or income
with respect to the development, implementation and enforcement of
environmental laws, regulations and policies." The EPA recognizes that RCRA
standards are critical in protecting environmental justice communities and that
communities near RCRA facilities have greater proportions of minority and
economically disadvantaged residents relative to the U.S. average. In the EPA's
FYs 2020-2021 Top Management Challenges, the OIG identified "Integrating and
Leading Environmental Justice Across the Agency and Government" as one of
the EPA's eight categories of challenges.
21-P-0114
2
-------
According to the EPA's RCRA Overview webpage, the EPA developed its
hazardous waste program to ensure "that hazardous waste is managed safely from
the moment it is generated to its final disposal (cradle-to-grave)." The EPA has
authorized 48 states to implement RCRA and to serve as permitting authorities,
meaning that these states can approve and issue the required permits for TSDFs
under their purview. The EPA implements RCRA in Iowa and Alaska. The EPA
retains oversight responsibility and enforcement authority for state-implemented
programs. It provides financial assistance, through annual RCRA grants, to
authorized state programs to implement RCRA. States and regions negotiate
commitments to be included in the grants.
Closure of RCRA Units
When a RCRA unit stops receiving waste, it must be cleaned, closed, monitored,
and maintained in accordance with the closure and postclosure care requirements
outlined in RCRA and corresponding regulations. All TSDFs, regardless of their
operational status, and the RCRA units within these TSDFs are subject to
RCRA's closure and postclosure care requirements. The EPA defines an
operating TSDF as a facility that currently has an operating treatment, storage, or
disposal unit. In other words, operating TSDFs are still accepting waste and are,
thus, according to the EPA, "subject to the full RCRA Subtitle C requirements
and are one of the highest priorities to the RCRA Enforcement program."
Nonoperating TSDFs may have units in closure or postclosure care, but they have
no units receiving waste.
TSDFs that contain RCRA units that have stopped receiving waste can use one of
two options to close the units: clean closure or postclosure care. Clean closure
requires the TSDF owners to remove all wastes from the unit and to remove or
decontaminate all equipment, structures, and surrounding soils. If the TSDF
cannot achieve the clean closure of a RCRA unit, it must undertake postclosure
care, which involves:
• Stabilizing the waste and leaving it in place.
• Removing free liquids.
• Placing caps or covers on top of waste.
Postclosure care is typically undertaken for units that cannot achieve clean closure
standards, such as landfills, land treatment units, or surface impoundments. A
RCRA unit that is undergoing postclosure care is commonly referred to as a unit
closed with waste in place.
TSDFs obtain permits for postclosure care and comply with postclosure care
standards established by the EPA. For example, postclosure care requires TSDFs
to take certain precautions for a set period—typically 30 years—after a RCRA
unit is closed with waste in place. These precautions include monitoring
groundwater to verify that no hazardous waste is being released to the
21-P-0114
3
-------
environment. In addition, TSDFs must provide financial assurance for the
estimated costs of postclosure care. At the end of the postclosure care period,
which can be either shortened or extended by the appropriate permitting authority
as needed, the financial assurance requirement also ends.
The EPA developed guidance to assist regulators in evaluating conditions at
RCRA TSDFs approaching the end of postclosure care. The 2016 memorandum,
Guidelines for Evaluating the Post-Closure Care Periodfor Hazardous Waste
Disposal Facilities under Subtitle C of RCRA, emphasizes the importance of EPA
oversight of RCRA units closed with waste in place:
Because many hazardous wastes degrade slowly or do not degrade
under containment in these units, the continued presence of
hazardous waste in the unit (i.e., any case other than clean closure)
indicates the potential for unacceptable impacts on human health
and the environment in the future if post-closure care is not
maintained.
RCRA Information
EPA and state permitting authorities document and track RCRA units in the
EPA's RCRAInfo information system. According to RCRAInfo system
documentation:
RCRAInfo is EPA's comprehensive information system, providing
access to data supporting the Resource Conservation and Recovery
Act (RCRA) of 1976 and the Hazardous and Solid Waste
Amendments (HSWA) of 1984. The system enables cradle-to-
grave waste tracking of many types of information regarding the
regulated universe of RCRA hazardous waste handlers. RCRAInfo
characterizes facility status, regulated activities, and compliance
histories[,] in addition to capturing detailed data on the generation
of hazardous waste from large quantity generators and on waste
management practices from treatment, storage, and disposal
facilities.
A combination of legal and operating status codes identifies the status of RCRA
units in the EPA's RCRAInfo database. The legal codes refer to the permit status
of a unit, such as permitted, permit terminated, or postclosure permitted. The
operating status codes include designations, such as operating, clean closed, or
closed with waste in place. In addition, operating status codes indicate whether a
unit is being addressed in the RCRA Corrective Action Program or has been
referred for cleanup to the EPA's Comprehensive Environmental Response,
Compensation, and Liability Act hazardous waste cleanup program, known as
Superfund. When the legal or operating status of a unit changes, the new status
and date of change are entered into RCRAInfo. Staff in authorized states update
21-P-0114
4
-------
all RCRA data for their states, including legal and operating status, permitting,
enforcement, and inspection information.
Why Monitoring RCRA Units Closed with Waste in Place Is Critical
CASE STUDY: Former FMC Corporation Elemental Phosphorous Plant in Pocatello, Idaho
The FMC facility has eight RCRA units closed with waste in place, all of which are surface impoundments, also
referred to as ponds, used to manage a slurry of waste containing elemental phosphorous. According to the EPA:
The RCRA ponds were closed in 2004 and 2005 under the RCRA Consent Decree, in accordance
with EPA approved RCRA closure plans. While most of the facility has been demolished, the eight
RCRA ponds are closed RCRA regulated units with waste remaining in place, which requires
ongoing monitoring under a RCRA post-closure plan. The RCRA Ponds were capped by one of two
types of cover systems following the removal of water in accordance with the EPA-approved
closure plans, the RCRA engineered cap or the RCRA double cap, depending on the type of pond
construction.
In 2006, excess phosphine gas was detected emanating from one of the ponds and, later, at hazardous levels at
some of the other ponds. The EPA concluded that the postclosure plans did not provide adequate protection. As a
result:
[The] EPA is reviewing and developing amendments to the existing post-closure plans to make
sure that the new FMC post-closure plan contains all applicable ongoing RCRA requirements to
ensure the long term protection of human health and the environment, including ongoing gas
management at all of the RCRA Ponds for as long as that is needed.
The RCRA ponds were closed under EPA-approved RCRA closure plans in accordance with the 1998 consent decree.
Since 2006, it has been necessary to extract and treat phosphine gas being generated at levels posing unacceptable
risk to human health and the environment by the waste left in place in the RCRA ponds. At the time of this report,
the management of phosphine at the RCRA ponds was governed by an enforcement document that will remain in
place until adequate gas management requirements are in effect under an amended RCRA postclosure plan for all
remaining RCRA regulated units, including the eight RCRA ponds.
The EPA has concluded that 'There can be no reuse of the RCRA pond area because there is waste left in place in
the ponds."
— EPA's "Hazardous Waste Cleanup: FMC RCRA Ponds, Pocatello, Idaho" webpage
Two Thousand RCRA Units Have Been Closed with Waste in Place
The RCRAInfo information system identifies RCRA units closed with waste in
place by the operating status code "CP." As of July 30, 2019, RCRAInfo had
classified a total of 2,000 RCRA units with this operating status code since 1978
(Figure 2). Of these 2,000 RCRA units, 1,361 (68 percent) remain in CP status
while 639 (32 percent) have been changed to another operating status, such as:
• AE—Under an alternate enforceable document for
postclosure care, such as a consent order or other enforceable document.
• CA—Referred to the RCRA Corrective Action Program.
• SF—Referred to the Superfund.
21-P-0114
5
-------
Addressed
by another
process
639.32%
Closed with
waste in
place,
1361,68%
Of the 1,361 units still with waste in place, 345 (25 percent) are at operating
TSDFs, and 1,016 (75 percent) are at nonoperating TSDFs. RCRA units that
remain classified as CP have been closed with waste in place for an average of
25.25 years.
Figure 2: Status of RCRA units classified as closed with waste in place
Superfund Program
"The Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA), commonly known Superfund,
was enacted by Congress on December 11,
1980. This law created a tax on the
chemical and petroleum industries and
provided broad Federal authority to
respond directly to releases or threatened
releases of hazardous substances that may
endanger public health or the
environment."
National Priorities List
"The National Priorities List (NPL) is the list
of sites of national priority among the
known releases or threatened releases of
hazardous substances, pollutants, or
contaminants throughout the United
States and its territories. The NPL is
intended primarily to guide the EPA in
determining which sites warrant further
investigation."
RCRA Corrective Action Program
"Corrective action is a requirement under
the Resource Conservation and Recovery
Act (RCRA). Facilities that treat, store, or
dispose of hazardous wastes are to
investigate and clean up hazardous
releases into soil, groundwater, surface
water, and air. In 1984, Congress passed
the Hazardous and Solid Waste
Amendments, which granted EPA
expanded authority to require corrective
action at permitted and nonpermitted
treatment, storage, and disposal facilities
(TSDFs)."
Sources:
EPA Superfund program overview
EPA National Priorities List
RCRA Corrective Action Program
Source: OIG analysis of RCRAInfo data.
(EPA OIG image)
Inspection Requirements
RCRA mandates that each TSDF for
which a permit is required under
Section 3005 of RCRA, 42 U.S.C.
§ 6925, be inspected at least once every
two years and that federally owned or
operated TSDFs be inspected annually.
Furthermore, the Office of Enforcement
and Compliance Assurance, known as
OECA, published its Compliance
Monitoring Strategy for the Resource
Conservation and Recovery Act (RCRA)
Subtitle CProgram in September 2015.
OECA's Compliance Monitoring
Strategy addresses the types and
frequencies of inspections for TSDFs.
The Compliance Monitoring Strategy
acknowledges that RCRA requires
"thorough" inspections of TSDFs and
that thorough inspections are typically
compliance evaluation inspections, or
CEIs. A CEI is "primarily an on-site
evaluation of the compliance status of
the site with regard to all applicable
21-P-0114
6
-------
RCRA Regulations and Permits (with the exception of groundwater monitoring
and financial assurance requirements)."
The Compliance Monitoring Strategy distinguishes between inspections of
operating TSDFs and nonoperating TSDFs:
At TSDFs that are no longer receiving waste but have land-based
units that preclude clean closure of the site, many of the normal
CEI [compliance evaluation inspection] inspection items for
TSDFs are not applicable (e.g., manifests, contingency plans,
personnel training, and waste storage requirements).
For nonoperating TSDFs, the Compliance Monitoring Strategy says that a
groundwater monitoring evaluation, or GME, or operation-and-maintenance
inspection, or OAM, may be more appropriate than a CEI. OECA considers a
GME appropriate for new or newly regulated land-disposal facilities, while an
OAM is appropriate after the permitting authority determines that the
groundwater-monitoring system is adequately designed and installed.
In addition, although Section 3007(e) requires inspection every two years of each
TSDF for which a permit is required under Section 3005, the Compliance
Monitoring Strategy institutes a policy of inspection at nonoperating facilities
every three years. Specifically, the Compliance Monitoring Strategy states,
"Regions and states are expected to inspect at least every three (3) years TSDFs
that are no longer in the operating universe but still have compliance
requirements." Compliance requirements at nonoperating TSDFs are commonly
established via permits issued pursuant to regulations implementing Section 3005.
We asked OECA what its basis was for the three-year inspection frequency for
nonoperating TSDFs, which appears to be inconsistent with the statutory
requirement to inspect every two years. OECA's response stated:
EPA decided as early as 1989 to separate TSDFs into two
universes—operating and nonoperating. The 3-year inspection
frequency for TSDFs in the Post-Closure phase—and therefore no
longer operating—provides a common-sense policy for balancing
limited inspection resources and risk. The policy allows for the
reduced inspection frequency at TSDFs only if a post-closure care
plan has been submitted to and approved by an authorized state or
EPA region and if a Post-Closure permit has been issued.
Given that OECA's response did not directly address the apparent deviation from
the statutory two-year inspection frequency requirement, we sought further
clarification. In response, after consulting with the EPA's Office of General
Counsel and the RCRA program office, OECA stated:
21-P-0114
7
-------
OECA's 3-year inspection policy for closed TSDFs with a post-
closure permit is consistent with RCRA § 3007(e), 42 U.S.C. §
6927(e), because, although EPA has the authority to issue a post-
closure permit, it is not required by statute. Therefore, closed
TSDFs are not TSDFs that require a permit under 3005 and are not
subject to the 2-year deadline.
In addition, the EPA directed us to a past rule in which the Agency had asserted a
similar interpretation. The Agency noted that the preamble to a proposed rule
stated that:
EPA has always interpreted sections 3004(a) and 3005 of RCRA to
authorize—but not compel—the issuance of permits to implement
post-closure care requirements at facilities that have ceased
operating.1
The EPA maintained this interpretation in the final rule issued subsequently.2 The
OIG accepts this long-held interpretation for the purpose of this audit.
Scope and Methodology
We conducted our work from August 2019 to February 2021. We conducted this
performance audit in accordance with generally accepted government auditing
standards. 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 upon our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based upon
our audit objectives.
As detailed in Appendix A, we assessed the internal controls necessary to satisfy
our audit objectives.3 In particular, we assessed the internal control components
and underlying principles—as outlined in the U.S. Government Accountability
Office's GAO-14-704G, Standards for Internal Control in the Federal
Government, also called the Green Book—significant to our audit objectives. Any
internal control deficiencies we found are discussed in this report. Because it was
limited to the internal control components and underlying principles deemed
significant to our audit objectives, our audit may not have disclosed all internal
control deficiencies that may have existed at the time of the audit.
1 "Standards Applicable to Owners and Operators of Closed and Closing Hazardous Waste Management Facilities;
Post-Closure Permit Requirement; Closure Process; State Corrective Action Enforcement Authority," 59 Fed.
Reg. 55778, 55782 (November 8, 1994).
2 "Standards Applicable to Owners and Operators of Closed and Closing Hazardous Waste Management Facilities;
Post-Closure Permit Requirement; Closure Process," 63 Fed. Reg. 56710, 56717-18 (October 22, 1998).
3 An entity designs, implements, and operates internal controls to achieve its objectives related to operations,
reporting, and compliance. The U.S. Government Accountability Office sets internal control standards for federal
entities in GAO-14-704G, Standards for Internal Control in the Federal Government, also known as the Green
Book, issued September 10, 2014.
21-P-0114
8
-------
We evaluated internal controls to determine the:
• Manner in which the EPA monitors the inspection frequency of TSDFs
with RCRA units closed with waste in place to determine adherence to the
inspection policy.
• Logical consistency of RCRAInfo data entries.
• Manner in which mechanisms in place to verify RCRA referrals to
Superfund and Superfund deferrals to RCRA are addressed.
• Existence or nonexistence of an EPA mechanism to crosswalk
nonidentical RCRA and Superfund site identifications. A crosswalk
identifies facilities that exist in both the RCRA and Superfund program
information systems, but with different identification numbers.
• Steps the EPA has taken to verify the milestones between sites on the
RCRA Corrective Action Program and the Superfund National Priorities
List do not double-count accomplishments or present conflicting results to
the public.
To address our objectives, we reviewed relevant materials pertaining to the
process and procedures used to track and monitor RCRA units closed with waste
in place. We interviewed key staff within the EPA's Office of Land and
Emergency Management's Office of Resource Conservation and Recovery. We
conducted interviews with or distributed questions to managers of all regional
offices. We requested copies of CEI reports performed by EPA regional staff
since January 1, 2018, to examine groundwater monitoring results. We reviewed
the inspection requirements in OECA's Compliance Monitoring Strategy. We
surveyed each region regarding its policies and practices for RCRA units closed
with waste in place.
We reviewed nationwide RCRA data for RCRA units closed with waste in place,
and we used RCRAInfo to identify and analyze the operational status of RCRA
units.
We distributed site-specific questions about TSDFs with RCRA units closed with
waste in place that had not been inspected to EPA Regions 3, 4, 8, 9, and 10. We
distributed general questions about the process for inspecting TSDFs with RCRA
units closed with waste in place to the remaining EPA regions.
To assess the three-year inspection frequency of nonoperating RCRA units closed
with waste in place, we used RCRAInfo to identify the TSDFs of those RCRA
units, excluding those that have been addressed by another process, that had not
been inspected since January 1, 2015. We considered a facility uninspected if
RCRAInfo did not document a CEI, GME, or OAM.
21-P-0114
9
-------
To analyze the environmental justice impact, we used the demographic results
provided by EPA staff from the EPA's environmental justice mapping and
screening tool, known as EJSCREEN. This tool:
• Looks at the proximity of a community to EPA-regulated sites. For
RCRA TSDFs, EJSCREEN looks at TSDFs within five kilometers of the
community. Therefore, we obtained data on demographics within
five kilometers of the TSDFs with units closed with waste in place.
Demographic data were available for 97 percent of those TSDFs.
• Produces a demographic index that is an average of the percentage of
people who are low income and the percentage of people who are
minorities.
Responsible Offices
The Office of Land and Emergency Management provides policy, guidance, and
direction for the Agency's emergency response and waste programs. Within the
Office of Land and Emergency Management, the Office of Resource Conservation
and Recovery implements RCRA. OECA's Office of Site Remediation
Enforcement manages the enforcement of the EPA's national hazardous waste
cleanup programs. OECA's Office of Compliance provides policy, guidance, and
direction for the Agency's compliance monitoring programs.
Prior Reports
OIG report, Superfund Sites Deferred to RCRA, Report No. El SFF8-11-0006-
9100116. issued on March 31, 1999, relates to the findings of our audit. The
report identified the lack of a crosswalk between RCRA and Superfund
information systems.
OIG Report No. 15-P-0169. Some Safeguards in Place for Long-Term Care of
Disposed Hazardous Waste, But Challenges Remain, issued on June 17, 2015, relates
to the objective and findings of our audit. The report made three
recommendations to finalize and issue guidance on adjusting the postclosure care
period and to provide information on the benefits of implementing controls
afforded through environmental covenant statutes. The EPA agreed with the
recommendations and reported that it took agreed-to corrective actions.
OIG Report No. 16-P-0104. EPA Has Not Met Statutory Requirements for
Hazardous Waste Treatment, Storage and Disposal Facility Inspections, but
Inspection Rates Are High, issued March 11, 2016, also relates to the objective
and findings of our audit. The report made one recommendation: that OECA
implement management controls to ensure that operating TSDFs are inspected as
required. The EPA agreed with the recommendation and reported that it took
agreed-to corrective actions.
21-P-0114
10
-------
Chapter 2
RCRA Units Closed with Waste in Place
Are Not Inspected Consistent
with the RCRA Statute or EPA Policy
The EPA does not consistently verify the continued protection of human health
and the environment at TSDFs with RCRA units closed with waste in place.
Specifically, the EPA does not inspect TSDFs at the frequency required by the
RCRA statute for operating TSDFs or the frequency set by OECA's Compliance
Monitoring Strategy for nonoperating postclosure TSDFs. The RCRA statute
requires inspections every two years at operating TSDFs, but in contrast, the
EPA's Compliance Monitoring Strategy sets the policy of inspections at least
once every three years at nonoperating postclosure TSDFs. However, almost half
(339 of 687, or 49.3 percent) of the TSDFs that have RCRA units closed with
waste in place were not inspected by the permitting authority at the applicable
frequency. The TSDFs not timely inspected include five operating TSDFs not
inspected every two years, as required by the RCRA statute, and 334
nonoperating TSDFs not inspected every three years.
In addition, EPA regional oversight of TSDF inspections was inconsistent. Five of
the ten EPA regions incorporate commitments in their state RCRA grant
processes to ensure that all their state permitting authorities comply with the
inspection policy. Two regions have similar processes in place, but the processes
do not apply to all states within those regions. Three regions do not have any
process in place to verify compliance. Because the inspections are not being
conducted at the frequency set by policy, leaks from RCRA units in uninspected
TSDFs may not be detected in a timely manner. Undetected contamination of
groundwater from a unit could result in loss of drinking water supply, high
cleanup costs, and human exposure to contaminants.
About Half of TSDFs with RCRA Units Closed with Waste in Place
Not Inspected Within the Policy Time Frame
We analyzed the inspection frequency at TSDFs with RCRA units closed with
waste in place. As discussed in Chapter 1:
• Operating TSDFs are subject to the RCRA statutory two-year inspection
frequency. OECA's Compliance Monitoring Strategy states that
compliance evaluation inspections are generally expected for operating
TSDFs.
• OECA policy states that nonoperating TSDFs with units closed with waste
in place are subject to the three-year inspection frequency outlined in
21-P-0114
11
-------
OECA's Compliance Monitoring Strategy. OECA's Compliance
Monitoring Strategy states that GMEs should be conducted at any new or
newly regulated land disposal facility. Once the adequacy of the
groundwater monitoring system is established, an OAM may become the
appropriate inspection for groundwater monitoring for nonoperating
TSDFs.
A total of 687 TSDFs manage the RCRA units classified by RCRAInfo as closed
with waste in place that have not been addressed by another process. Of these
687 TSDFs, 112 are operating TSDFs that, under RCRA, should be inspected at
least every two years. The other 575 TSDFs are nonoperating and, according to
OEC A policy, should be inspected at least every three years. We found that since
January 1, 2015:
• About 96 percent (107 of 112) of the operating TSDFs that manage RCRA
units closed with waste in place received a compliance evaluation
inspection every two years.
• In contrast, 58 percent (334 of 575) of nonoperating TSDFs that manage
RCRA units closed with waste in place had not received a GME or an
OAM within three years.
As a result, roughly 50 percent (339 of 687) of nonoperating TSDFs that have
RCRA units closed with waste in place were not inspected at the frequency set by
policy (Figure 3).
Figure 3: Inspection of TSDFs*
Operating
NOT
Inspected,"
0.7%
Nonoperating
NOT Inspected,
334,48.6% i
Operating^
Inspected,
107,15.6%
Nonoperating
Inspected, 241
35.1%
Source: OIG analysis of RCRAInfo data. (EPA OIG image)
Inspected refers to whether the TSDF was inspected at the applicable frequency,
which is every two years for operating TSDFs and every three years for those that are
not operating.
21-P-0114
12
-------
EJSCREEN Demographic Index of Communities Around TSDFs with Units Closed
with Waste in Place Is Close to National Average
Our analysis of EJSCREEN data for communities surrounding TSDF with units
closed with waste in place found:
• A total of 22.8 million people live within five kilometers, which is about
three miles, of a TSDF with units closed with waste in place. According to
the U. S. Census Bureau, the 2019 U.S. population was 328.2 million, so
about 7 percent of the population lives within five kilometers of a TSDF
with units closed with waste in place.
• The demographic index for populations within five kilometers of TSDFs
with units closed with waste in place is 39 percent of the population,
which is slightly higher than the national average of 36 percent. The
demographic index is an average of the percent of the population who are
minority and low income. EJSCREEN defines low income as households
with income less than or equal to twice the federal poverty level and
minority as all people other than non-Hispanic white-alone individuals.
• The demographic index for inspected TSDFs with units closed with waste
in place is 39 percent, and the index for uninspected TSDFs with units
closed with waste in place is 40 percent, which suggests TSDFs with units
closed with waste in place are being inspected without regard to the
percent of the population that is minority and low income.4
EPA Regional Oversight of Inspections Varies
EPA regions do not consistently monitor state inspections of RCRA units closed
with waste in place at nonoperating TSDFs. As a result, some TSDFs may not be
inspected as required by RCRA or as set by the OECA's Compliance Monitoring
Strategy. Lack of monitoring of the inspection frequency could result in delayed
detection or nondetection of groundwater contamination and potential human
exposure.
We asked all ten EPA regions about the mechanisms they use to try to comply
with the applicable inspection frequency. Seven of the regions had some
mechanism in place, while three regions had no mechanism in place. However,
regardless of the mechanisms in place, according to RCRAInfo, all regions had
TSDFs with units closed with waste in place that had not been inspected in the
applicable time frame. Table 1 summarizes the responses we received.
4 In its response to the draft report, the Agency expressed concerns that the environmental justice analysis suggests
that Agency guidance has established the demographic index as a driver for inspection priority. That is not the
intent; we merely wanted to include relevant information on environment justice in our analysis.
21-P-0114
13
-------
Table 1: Regional mechanisms used for three-year inspection policy at
nonoperating TSDFs
Regional status
Details
Five regions monitor inspection
frequency through state RCRA grants.
State commitments to inspect are included in
RCRA grant commitments for all states in these
regions.
Two regions monitor inspection
frequency through state RCRA grants
for some, but not all, of their states.
State commitments to inspect included in RCRA grant
work plans for some states but not for all.
Three regions have no mechanisms
in place to monitor inspection
frequency.
Two of these regions were unaware of the three-year
inspection policy. The third region stated that it did not
monitor the inspections of TSDFs with RCRA units
closed with waste in place because its inspection
priorities were prioritized based upon multiple
inspection criteria, such as national compliance
initiatives and state and local government priorities.
Source: OIG analysis of regional responses. (EPA OIG table)
We asked OECA whether it had any nationwide mechanism in place to track
regional or state adherence with the three-year inspection policy. OECA
responded:
Adherence to the 3-year inspection policy for post-closure TSDFs
is tracked at the regional level in the RCRA grant work plans.
Headquarters and regions focus inspection resources on the highest
risk TSDF and [large quantity generator] universes, while ensuring
the overall program integrity is maintained.
We, therefore, conclude that adherence to the three-year inspection policy is not
consistently implemented in EPA regions. EPA regions and authorized states
could identify and track TSDFs that have not been inspected in accordance with
the policy by identifying them in using regular reports from RCRAInfo. Because
of a lack of compliance with the inspection policy, uninspected units could be
leaking and causing groundwater contamination and potential human exposure
without EPA knowledge.
Conclusions
EPA regions do not consistently verify that TSDFs with RCRA units closed with
waste in place are inspected at the applicable frequency. Controls, such as reviews
of RCRAInfo information on units closed with waste in place, are inconsistent.
Implementation of controls would allow regions to readily verify that all TSDFs
with units closed with waste in place are inspected at the applicable frequency. In
the absence of frequent inspections, contamination from sites closed with waste in
place could migrate and go unidentified in a timely manner, which increases the
possibility of human health exposure and environmental contamination.
21-P-0114
14
-------
Recommendations
We recommend that the assistant administrator for Land and Emergency
Management, in collaboration with the Office of Enforcement and Compliance
Assurance:
1. Develop RCRAInfo reports for regular distribution to EPA regions that
identify the inspection frequency status of nonoperating treatment, storage,
or disposal facilities with respect to the time frames stated in the Office of
Enforcement and Compliance Assurance's Compliance Monitoring
Strategy.
We recommend that the assistant administrator for Enforcement and Compliance
Assurance, in collaboration with the Office of Land and Emergency Management:
2. Establish mechanisms to ensure that all inspections are completed within
the required time frame of two years for operating treatment, storage, or
disposal facilities or the policy time frame of three years for nonoperating
treatment, storage, or disposal facilities.
Agency Response and OIG Assessment
The acting assistant administrators for the Office of Land and Emergency
Management and the Office of Enforcement and Compliance Assurance
responded to our draft report. We included these responses, as well as our full
analysis of these response, in Appendix C. The Agency proposed an acceptable
modification to Recommendation 1 and provided an acceptable planned
corrective action and estimated completion date. This recommendation is resolved
with corrective action pending.
The Agency proposed an alternate to Recommendation 2 with a proposed
corrective action and estimated completion date. We disagree with both the
alternate Recommendation 2 and the proposed corrective action.
Recommendation 2, therefore, remains unresolved. The proposed corrective
action does not indicate how the Agency will track the completed inspections, nor
does it say how the Agency will comply with the two-year inspection
requirement, as outlined in the statute.
21-P-0114
15
-------
Chapter 3
Tracking Facilities Between RCRA
and Superfund Programs Is Problematic
During our review of units closed with waste in place, we observed some issues
with interactions between the RCRA and Superfund programs. EPA oversight of
TSDFs that are referred to the Superfund program and then deferred back to the
RCRA program is incomplete. The lack of procedures and the use of differing
program identification numbers in the two programs hinder the EPA's ability to
track facilities between the two programs. As a result, it is unclear whether either
program is appropriately managing these units and protecting human health and
the environment. EPA oversight of RCRA corrective action facilities also
managed by the Superfund program was ineffective. It resulted in 42 possibly
conflicting and 126 double-counted accomplishment milestones. Because these
milestones are used to communicate site status to the public, communities living
near these sites could be confused or misled as to the cleanup status of the sites
and be hindered from being able to take necessary steps to protect themselves
from dangerous environmental conditions.
Referrals of RCRA Units to Superfund and Deferrals Back to RCRA
Are Not Tracked or Monitored
The RCRAInfo operating status code for
RCRA units closed with waste in place that
have been referred to the EPA's Superfund
program is "SF." We identified 108 such units
across 47 TSDFs. The Superfund program's
Superfund Enterprise Management System, or
SEMS, tracks these referred units by a facility
identification number that may or may not be
the same number as the RCRA identification.
We readily identified most of the 108 units
coded as SF in RCRAInfo in SEMS but had
difficulty finding 26 of the units that have
different identification numbers in SEMS and
RCRAInfo. We also identified ten units that
appear to have been incorrectly identified as
SF, as they were referred to state Superfund programs, not the federal program.
The EPA appears to have no process in place to verify that SF referrals in
RCRAInfo have consistent information in SEMS and are being appropriately
managed by the Superfund program.
Additionally, we noted that some sites listed in SEMS as "deferred to RCRA"
were not found in RCRAInfo with an entry after the SEMS deferral date. To
The Superfund Enterprise
Management System
SEMS is "the official repository
for site and non-site specific
Superfund data in support of the
Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA). It contains
information on hazardous waste
site assessment and remediation
from 1983 to the present." The
public can search Superfund
data at the EPA's Search
Superfund Site Information
website.
21-P-0114
16
-------
analyze this issue further, we identified 23 Superfund deferrals to RCRA since
2010. Of those 23 deferrals, we could not locate four in RCRAInfo. Of the
19 sites we could locate in RCRAInfo, six had not been updated in RCRAInfo
since before the SEMS deferral date. In other words, there was no indication in
RCRAInfo that the RCRA program had appropriately managed these sites after
their deferral from Superfund to RCRA. In total, we found that ten of the 23 sites
we reviewed either could not be found in RCRAInfo or had no entries after the
deferral dates.
Without confirmation of the RCRA deferrals returning to regulatory oversight by
the RCRA program, the units do not appear to be tracked. As a result, there is no
evidence that human health and the environment are being protected at these sites.
Our reconciliation of Superfund sites in RCRAInfo was challenged by the lack of
a crosswalk of site identifications between the two systems that would correlate
the identification numbers in both systems when they differ for the same facility.
The EPA can develop such a crosswalk, as the Office of Mission Support
maintains Envirofacts. a single point of access to query across multiple EPA
information systems. Facilities in multiple systems may be identified by their
Facility Registry System identification number, which the EPA assigns to
facilities in multiple systems based on address criteria. We contacted the EPA's
Office of Mission Support for assistance in developing a crosswalk, and it was
able to provide a spreadsheet that identifies whether a RCRAInfo identification
was available for all active SEMS sites in Envirofacts. The spreadsheet provided
by the Office of Mission Support contains identifications for 4,083 SEMS sites
that match RCRAInfo facilities. Of these, 2,172 have identical identifications in
both systems, while the remainder have different identifications. We found that
this spreadsheet was much more efficient in identifying facilities between SEMS
and RCRAInfo than using Envirofacts to query one facility at a time.
The OIG has previously identified this inability to readily identify deferrals to the
RCRA program from the Superfund program as a concern. The OIG's March 31,
1999 report, Superfund Sites Deferred to RCRA, said that "because there is no
crosswalk between the two automated systems, Agency officials will have to
manually search program files to ensure that all deferred sites are accounted for."
More than 20 years later, the lack of a crosswalk between the two systems still
exists. As a result, it is difficult for both the Superfund and RCRA programs to
confirm that:
• Referrals from RCRAInfo to SEMS and deferrals from SEMS to
RCRAInfo have occurred.
• Sites are being appropriately monitored for the continued protection of
human health and the environment.
21-P-0114
17
-------
Environmental Indicator and Ready-for-Reuse Accomplishments
Differ or May Be Double-Counted Between Programs and Result in
Confusing Risk Communication Messages to the Public
The EPA's oversight of RCRA facilities
undergoing corrective action that were also on
the Superfimd National Priorities List was
ineffective. The Superfimd National Priorities
List is a list of the most serious sites identified
for long-term cleanup. In our analysis, we
identified 56 TSDFs, including 17 with RCRA
units closed with waste in place, that were
referred to the RCRA Corrective Action
Program that were also on the Superfimd
National Priorities List.
Both the RCRA Corrective Action and the
Superfund Programs track and publicly report
on key accomplishments, including:
• Current human exposure under control.
• Contaminated groundwater migration
under control.
• Determination of whether the site is
ready for anticipated use.
One region informed us that it verifies that
RCRA Corrective Action Program facilities
are not also tracked as Superfund sites to
ensure that the programs do not:
• Double-count accomplishments.
• Have different milestones for similar
goals, which could create confusion for
the public.
For the 56 duplicate RCRA Corrective Action
and Superfund facilities, we compared the
results for three environmental indicators that
totaled 168 accomplishments for all
56 facilities. The three monitored indicators
were:
• Human exposure under control.
• Groundwater releases under control.
• Sitewide ready for anticipated use.
Environmental Indicators
Current Human Exposure Is Under
Control
Sites are assigned to this category
when assessments for human
exposures indicate there are no
unacceptable human exposure
pathways and the region has
determined the site is under control
for current conditions sitewide.
Contaminated Groundwater
Migration Is Under Control
Indicates that all information on
known and reasonably expected
groundwater contamination has been
reviewed and that the migration of
contaminated groundwater is
stabilized and there is no unacceptable
discharge to surface water and
monitoring will be conducted to
confirm that affected groundwater
remains in the original area of
contamination.
Sitewide Ready for Anticipated Use
1. All cleanup goals in the Record(s) of
Decision or other remedy decision
documents have been achieved for
media that may affect current and
reasonably anticipated future land
uses of the site, so that there are no
unacceptable risks.
2. All institutional or other controls
required in the Record(s) of Decision
or other remedy decision documents
have been put in place.
Sources:
EPA "Sitewide Ready for Anticipated Use"
webpage.
EPA, Participant Manual. RCRA Corrective
Action Training Program: Getting to YES!,
November 2009.
21-P-0114
18
-------
We compared the results reported by each program for these three indicators. We
found seven differences between the RCRA Corrective Action and Superfund
designations for human exposure under control, 14 differences for groundwater
exposure under control, and 21 differences for ready for anticipated use
(Figure 4). In total, 42 of 168 (25 percent) differences between designations
existed (Appendix B). The EPA uses these milestones to communicate site status,
and because the indicators are used as a measure of risk communication, the
results present public confusion about the state of these sites.
Further, the 126 milestones that are consistent between Corrective Action and
Superfund Program sites could represent the EPA double-counting
accomplishments. Because the EPA uses these milestones to communicate site
status to the public, communities living near these sites could reach different
conclusions about the contamination or cleanup status of a site when the
accomplishments differ in the two programs.
Figure 4: Facilities and sites listed on both the Corrective Action Program and
the National Priorities List
CA-NPL Site Milestones
60
cn
a n
on
—
jU
on
I ll
Z-\J
i n
±u
rt
H
HE GWM RAU
¦ Same ¦ Different
Source: OIG analysis of RCRAInfo data. (EPA OIG image)
One example of potential confusion caused by differing entries is the National
Zinc Corporation Superfund site, which is also a RCRA Corrective Action facility
with a different name with units closed with waste in place. The RCRA and
Superfund information is listed in the EPA's Cleanups in My Community public
query, but the Corrective Action information lists a ready-for-anticipated-use date
in 2009 while the Superfund information indicates that the site is not ready for
anticipated use (Figure 5).
There may be some legitimate explanations for facilities in both systems. For
example, some Superfund sites indicate that all future cleanup activities will be
performed under RCRA Corrective Action and the sites will be deleted from the
National Priorities List, and one Corrective Action site indicates referral to the
21-P-0114
19
-------
Superfund program. Further, according to the EPA, RCRA Corrective Action and
Superfund cleanups may occur at the same facility at the same time. However, in
all cases, the indicators still appear to be counted in both systems. Other
differences may also explain the presence of sites in both systems, such as a
Corrective Action site located within a large Superfund site. Nonetheless, there
should be clear acknowledgement in site information available to the public that
the sites are in both programs to inform the public of possible overlaps.
Figure 5: Example of an EPA Cleanups in My Community public query
Listing from EPA's Cleanups in My Community
Location
5ut«
Rrnwnfiplii*
Sufwrfund
Ctojunup Nam*
Add««n
T1TW ST
C*ty N»m»
C«d«
Cod*
County Niwti*
f PA 10
link
RCRA link
Link
NATIONAL ZINC
CORP.
&
VWGINIA
STREET
eAfllLESWH
OK
74003
WAS WINS j ION
CXDC0C«2
-------
• Documentation of program identifications that are inconsistent between
SEMS and RCRAInfo.
• Possible double-counting or inconsistent data for accomplishments of the
RCRA Corrective Action program and the Superfund National Priorities
List.
Because some of the EPA's identified accomplishments may be listed in error, the
EPA's risk communication of the status of sites may lead the public to believe a
site is ready for reuse when it is not and human health and the environment may
not be protected at some sites.
Recommendations
We recommend that the assistant administrator for Land and Emergency
Management:
3. Develop and implement controls to verify that the Resource Conservation
and Recovery Act referrals to the Superfund program are added to
Superfund Enterprise Management System for further Superfund program
attention, as necessary.
4. Develop and implement controls to verify that the Superfund program
deferrals to the Resource Conservation and Recovery Act are added to
RCRAInfo for further Resource Conservation and Recovery Act attention,
as necessary.
5. Develop and maintain a crosswalk of Superfund Enterprise Management
System and corresponding RCRAInfo identification numbers.
6. Develop and implement controls to identify and eliminate overlap of
environmental indicators between Resource Conservation and Recovery
Act Corrective Action and Superfund Programs and include this
information in public queries, such as Cleanups in My Community.
Agency Response and OIG Assessment
The acting assistant administrators for the Office of Land and Emergency
Management and the Office of Enforcement and Compliance Assurance jointly
responded to our draft report. We included this response, as well as our full
analysis of this response, in Appendix C. The Agency agreed with
Recommendations 3 and 4 and provided acceptable planned corrective actions
and estimated completion dates. These recommendations are resolved with
corrective actions pending.
21-P-0114
21
-------
The Agency agreed with Recommendation 5 and proposed a corrective action
with an estimated completion date. We disagree with the proposed corrective
action; this recommendation, therefore, remains unresolved. The proposed
corrective action assumes that the crosswalk only applies to referrals and deferrals
between the two programs. The purpose of the crosswalk is to allow identification
of any site or facility in both programs. The Agency proposed an alternate to
Recommendation 6 and provided a corrective action with an estimated completion
date. We disagree with the alternate recommendation and the proposed corrective
action; this recommendation, therefore, remains unresolved. While the Agency
has proposed clarifications, it has not delineated how it will identify and eliminate
the double-counting and the inconsistencies.
21-P-0114
22
-------
Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
Potential
Monetary
Benefits
(in $000s)
1
15
In collaboration with the Office of Enforcement and Compliance
Assurance, develop RCRAInfo reports for regular distribution to
EPA regions that identify the inspection frequency status of
nonoperating treatment, storage, or disposal facilities with
respect to the time frames stated in the Office of Enforcement
and Compliance Assurance's Compliance Monitoring Strategy.
R
Assistant Administrator for
Land and Emergency
Management
12/31/21
2
15
In collaboration with the Office of Land and Emergency
Management, establish mechanisms to ensure that all
inspections are completed within the required time frame of two
years for operating treatment, storage, or disposal facilities or the
policy time frame of three years for nonoperating treatment,
storage, or disposal facilities.
U
Assistant Administrator for
the Office of Enforcement
and Compliance Assurance
3
21
Develop and implement controls to verify that the Resource
Conservation and Recovery Act referrals to the Superfund
program are added to Superfund Enterprise Management
System for further Superfund program attention, as necessary.
R
Assistant Administrator for
Land and Emergency
Management
3/31/22
4
21
Develop and implement controls to verify that the Superfund
program deferrals to the Resource Conservation and Recovery
Act are added to RCRAInfo for further Resource Conservation
and Recovery Act attention, as necessary.
R
Assistant Administrator for
Land and Emergency
Management
9/30/23
5
21
Develop and maintain a crosswalk of Superfund Enterprise
Management System and corresponding RCRAInfo identification
numbers.
U
Assistant Administrator for
Land and Emergency
Management
6
21
Develop and implement controls to identify and eliminate overlap
of environmental indicators between Resource Conservation and
Recovery Act Corrective Action and Superfund Programs and
include this information in public queries, such as Cleanups in
My Community
U
Assistant Administrator for
Land and Emergency
Management
1 C = Corrective action completed.
R = Recommendation resolved with Corrective Action pending.
U = Recommendation unresolved with resolution efforts in progress.
21-P-0114
23
-------
Appendix A
Internal Control Assessment
Which internal control components are
significant to the audit objective(s)?
Which internal control principles are sianificant to the audit
objective(s)?
Control Environment
The control environment is the foundation
for an internal control system. It provides
the discipline and structure to help an entity
achieve its objectives.
1. The oversight body and management should demonstrate
a commitment to integrity and ethical values.
2. The oversight body should oversee the entity's internal
control system.
3. Management should establish an organizational structure,
assign responsibilities, and delegate authority to achieve
the entity's objectives.
4. Management should demonstrate a commitment to
recruit, develop, and retain competent individuals.
5. Management should evaluate performance and hold
individuals accountable for their internal control
responsibilities.
Risk Assessment
Management assesses the risks facing the
entity as it seeks to achieve its objectives.
This assessment provides the basis for
developing appropriate risk responses.
6. Management should define objectives clearly to enable
the identification of risks and define risk tolerances.
7. Management should identify, analyze, and respond to
risks related to achieving the defined objectives.
8. Management should consider the potential for fraud when
identifying, analyzing, and responding to risks.
9. Management should identify, analyze, and respond to
significant changes that could impact the internal control
system.
X
Control Activities
The actions management establishes
through policies and procedures to achieve
objectives and respond to risks in the
internal control system, which includes the
entity's information system.
X
10. Management should design control activities to achieve
objectives and respond to risks.
X
11. Management should design the entity's information
system and related control activities to achieve objectives
and respond to risks.
X
12. Management should implement control activities through
policies.
Information and Communication
The quality information management and
personnel communicate and use to support
the internal control system.
13. Management should use quality information to achieve
the entity's objectives.
14. Management should internally communicate the
necessary quality information to achieve the entity's
objectives.
15. Management should externally communicate the
necessary quality information to achieve the entity's
objectives.
X
Monitoring
Activities management establishes and
operates to assess the quality of
performance overtime and promptly
resolve the findings of audits and other
reviews.
X
16. Management should establish and operate monitoring
activities to monitor the internal control system and
evaluate the results.
17. Management should remediate identified internal control
deficiencies on a timely basis.
Source: Based on internal control components and principles outlined in GAO-14-704G, Standards for Internal
Control in the Federal Government, which is also known as the "Green Book", issued September 10, 2014.
21-P-0114
24
-------
Appendix B
Sites on the Corrective Action Program and the
National Priorities List
RCRA ID
Handler Name
SEMS ID
NPL Status
HE
GWM
RAU
DED980551667
AKZO CHEMICALS INC
DED980551667
Final NPL
Same
Same
Same
ALD008161176
AKZO NOBEL FUNCTIONAL
CHEMICALS LLC
ALD008161176
Final NPL
Same
Same
Same
TXD008123168
ALCOA POINT COMFORT
OPERATIONS
TXD008123168
Final NPL
Same
Same
Same
IL0210090049
ALLIANT TECHSYSTEMS
INC
IL0210090049
Final NPL
Same
Same
Same
WV0170023691
ALLIANT TECHSYSTEMS
OPERATIONS LLC, ABL
OPERATIONS
WV0170023691
Final NPL
Same
Same
Same
OKD000829440
AMERICAN ZINC
RECYCLING CORP (AZR)
OKD000829440
Proposed
NPL
Same
Different
Different
ORD050955848
ATI MILLERSBURG
ORD050955848
Final NPL
Same
Different
Same
ALD001221902
BASF CORP
ALD001221902
Final NPL
Same
Same
Different
MND000686196
BRAINERD-TIE PLANT SITE
- BURLINGTON NOR
MND000686196
Final NPL
Same
Same
Same
PRD090282757
CARIBE GENERAL
ELECTRIC PRODUCT
JUAN A Dl
PRD090282757
Deleted
NPL
Same
Same
Different
IL1570024157
CHANUTE AIR FORCE
BASE
IL1570024157
Proposed
NPL
Different
Same
Same
NCD001810365
CLARIANT CORPORATION
MT HOLLY EAST PLANT
NCD001810365
Deleted
NPL
Same
Same
Different
ALD000828848
ERP COMPLIANT COKE,
LLC BIRMINGHAM
ALN000410750
Proposed
NPL
Different
Different
Different
NJD004362059
FISHER SCIENTIFIC CO
LLC - FAIR LAWN PLANT
NJD980654107
Final NPL
Same
Same
Same
MND000686071
FLINT HILLS PINE BEND,
LLC
MND000686071
Deleted
NPL
Same
Same
Same
IDD070929518
FMC IDAHO LLC
IDD984666610
Final NPL
Same
Different
Same
IL8143609487
GENERAL DYNAMICS- OTS,
A13
IL8143609487
Final NPL
Same
Different
Different
MSD990866329
GREENFIELD
ENVIRONMENTAL
MULTISTATE TRUST LLC
FORMERLY TRONOX
COLUMBUS
MSD990866329
Final NPL
Different
Different
Same
MSD007037278
GRENADA
MANUFACTURING LLC
MSD007037278
Final NPL
Different
Different
Same
NJD002349058
HERCULES INC - FORMER
GIBBSTOWN PLANT
NJD002349058
Final NPL
Different
Different
Same
IA7213820445
IOWA ARMY AMMUNITION
PLANT
IA7213820445
Final NPL
Same
Different
Same
FL6170024412
JACKSONVILLE NAS
FL6170024412
Final NPL
Same
Different
Same
WA9214053465
JOINT BASE LEWIS
MCCHORD
WA9214053465
Deleted
NPL
Same
Different
Different
WID006073225
KOHLER CO
WID006073225
Final NPL
Same
Same
Different
SCD003353026
KOPPERSINC
SCD003353026
Deleted
NPL
Same
Same
Same
21-P-0114
25
-------
RCRA ID
Handler Name
SEMS ID
NPL Status
HE
GWM
RAU
WVD004336749
KOPPERS INC.
WVD004336749
Deleted
NPL
Same
Same
Different
OHD000720607
LEAR CORPORATION
OHD980794598
Final NPL
Same
Same
Different
ORD052221025
LOCKHEED MARTIN
CORPORATION
ORD052221025
Deleted
NPL
Same
Same
Different
TX7213821831
LONE STAR ARMY
AMMUNITION PLANT
TX7213821831
Final NPL
Same
Same
Different
NC6170022580
MARINE CORPS BASE
CAMP LEJEUNE
NC6170022580
Final NPL
Same
Same
Same
NJD043584101
MATLACK INC
NJD043584101
Final NPL
Same
Same
Same
NC1170027261
MCABEAST - MCAS
CHERRY POINT
NC1170027261
Final NPL
Same
Same
Same
TN0210020582
MILAN ARMY AMMUNITION
PLANT
TN0210020582
Final NPL
Same
Same
Different
MTD006230346
MONTANA
ENVIRONMENTAL TRUST
GROUP LLC
MTD006230346
Final NPL
Same
Same
Different
FL5170022474
NAVFAC SOUTHERN
DIVISION - CECIL FIELD
FL5170022474
Final NPL
Same
Same
Same
ALD008188708
OLIN CHLOR ALKALI
PRODUCTS, INC. -
MCINTOSH PLANT
ALD008188708
Final NPL
Same
Same
Same
PRD090398074
PFIZER
PHARMACEUTICALS LLC-
ARECIBO
PRD980301154
Final NPL
Same
Same
Different
KYD006370167
POLYONE CORPORATION
AND GOODRICH
CORPORATION
KYD006370167
Final NPL
Same
Same
Same
GAD001700699
PRAYON INC
GAD001700699
Deleted
NPL
Same
Same
Different
PRD090370537
RCA DEL CARIBE INC
PRD090370537
Deleted
NPL
Same
Same
Same
GA1570024330
ROBINS AIR FORCE BASE
GA1570024330
Final NPL
Same
Same
Different
C07890010526
ROCKY FLATS SITE - US
DOE
C07890010526
Final NPL
Same
Same
Same
C05210020769
ROCKY MOUNTAIN
ARSENAL
C05210020769
Final NPL
Same
Same
Same
OK1571724391
TINKER AIR FORCE BASE
OK1571724391
Final NPL
Same
Same
Different
UT3213820894
TOOELE ARMY DEPOT
UT3213820894
Final NPL
Same
Different
Different
PAD041421223
TYCO ELEC
PAD041421223
Deleted
NPL
Same
Same
Different
TN1890090003
U.S. DOE, OAK RIDGE
NATIONAL LABORATORY
TN1890090003
Final NPL
Same
Same
Same
WYD061112470
UNION PACIFIC RAILROAD
LARAMIE TIMBER
TREATING PLANT
WYD061112470
Deleted
NPL
Same
Same
Same
C07570090038
US AIR FORCE PLANT-
PJKS
C07570090038
Final NPL
Same
Same
Same
TX4890110527
US DEPARTMENT OF
ENERGY PANTEX PLANT
TX4890110527
Final NPL
Same
Same
Different
WA1891406349
US DOE BPA ROSS
COMPLEX
WA1891406349
Deleted
NPL
Same
Different
Same
FL9170024567
US NAVAL AIR STATION
PENSACOLA
FL9170024567
Final NPL
Same
Same
Same
MND051441731
VITASYN
MND051441731
Final NPL
Different
Same
Same
21-P-0114
26
-------
RCRA ID
Handler Name
SEMS ID
NPL Status
HE
GWM
RAU
WID000808568
WID990829475
WM Wl- OMEGA HILLS LF
WRR ENVIRONMENTAL
SERVICES CO INC
WID000808568
WID990829475
Deleted
NPL
Deleted
NPL
Same
Different
Same
Different
Same
Same
NJD002173276
WYETH HOLDINGS LLC
NJD002173276
Final NPL
Same
Same
Same
Source: OIG analysis of EPA data.
Note: Identical values are indicated as "Same" while differing values are identified as "Different."
21-P-0114
27
-------
Appendix C
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MEMORANDUM
SUBJECT:
FROM;
Response to Office of Inspector General Draft Project No. OA&E-FY19-0323
"EPA Does Not Consistently Monitor Hazardous Waste Units in Place or Consistently
Track and Report on Facilities Between the Two Responsible Programs," dated February
4,2021
Barry N. Breen, Acting Assistant Administrator
Office of Land and Emergency Management
BARRY
BREEN
Digitally signed by
BARRY BREEN
Date: 2021.03.11
17:32:08-05'00'
Lawrence E, Starfield, Acting Assistant Administrator LAWRENCE uwrence8starfield
Office of Enforcement and Compliance Assurance
STARFIELD
Date: 2021.03.11
16:30:01 -05W
TO:
Sean W. O'Donnell
Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the
subject draft audit report (report). We also appreciate the prior engagement we have had with
your staff, including the recent discussion on February 19th. Thank you for agreeing that the
Assistant Administrator for OECA should be the lead action official for Recommendation #2.
The following is a general response to the report, along with responses to each of the report
recommendations. For the report recommendations, we have provided high-level intended
corrective actions and estimated completion dates. For your consideration, we have included a
Technical Comments Attachment to supplement this response in the form of redline/strikeout on
the draft report.
OVERALL POSITION
We appreciate the Office of Inspector General's (OIG) attention to EPA's oversight of
hazardous waste units closed with waste in place. Effective oversight of these units is essential
for ensuring that environmental obligations are met, and human health and the environment are
protected.
We wish to raise four points of emphasis. First, as the OIG notes in its report, the
Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) programs often work together to address
cleanup of contaminated sites. At any one facility/site, each program may have different roles for
21-P-0114
28
-------
different areas, and roles and areas may change over time. Thus, what appear as potential
inconsistencies in the respective data systems may in fact be valid and meaningful differences in
cleanup status for different areas managed by the respective program. Nevertheless, the Office of
Land and Emergency Management (OLEM) recognizes communication regarding these
differences, particularly with the public, could be improved.
OIG Response 1: The report acknowledges that there may be legitimate reasons for facilities
and sites to be in both systems.
Second, the report should clearly distinguish the difference between statutorily mandated
inspections and inspections recommended through guidance. We agree that operating
Treatment, Storage, and Disposal Facilities (TSDFs) are required by statute to be inspected every
two years. As the data indicates, the agency's compliance rate for this requirement is 96%. The
RCRA Compliance Monitoring Strategy (CMS) is a guidance document that does not establish
new "requirements," but sets an inspection goal for non-operating TSDFs that have been closed
with waste in place. As the three-year timeframe is established in a guidance document and not
in a regulation, the recommendation should not imply that the three-year review frequency is
mandatory. Clarifications are offered in the technical comments to address this point. We agree
that OECA can improve its oversight of regions and states with respect to TSDFs that are closed
and include units with waste in place. We have offered alternative language for Recommendation
#2 that addresses the need for improved oversight of the CMS strategy.
OIG Response 2: We have modified text, as suggested here and in the technical comments, to
clarify that the OECA Compliance Monitoring Strategy inspection goal is a policy, not a
mandatory requirement.
Third, although the CMS suggests certain inspection types may be more appropriate than
others depending on the circumstances, a variety of compliance monitoring tools can be utilized
to assess closed TSDFs. We have completed our own analysis of the OIG dataset and believe the
OIG did not include all on-site inspection types in its inspection analysis of TSDFs with RCRA
units closed with waste in place. For instance, it does not appear that OIG included corrective
action compliance evaluations or case development inspections. Our calculation indicates an
inspection rate of more than 80% — a much higher rate than the 49% rate the OIG calculated.
OECA would appreciate the opportunity to discuss the data analysis in more detail with the OIG.
OIG Response 3: We will be pleased to meet with OECA and discuss the data and our
analyses. We used GME and OAM inspections as the basis of our analysis of the three-year
inspection rates for nonoperating postclosure TSDFs because these were referenced as
appropriate in the OECA Compliance Monitoring Strategy. We also found that, based on our
evaluation of multiple recent CEIs at nonoperating TSDFs with units closed with waste in place
and existing policies at multiple regions, that CEIs at these TSDFs were large quantity
generator inspections that did not look at the units closed with waste in place.
Fourth, we are concerned with the conclusions drawn on page 14 of the report with
respect to inspections of closed facilities and environmental justice. EJSCREEN (based on 11
21-P-0114
29
-------
environmental indicators and six demographic indicators) is used as an initial step in identifying
areas which may have potential environmental concerns. The screening-level results have
significant limitations and are not intended or designed to provide a risk assessment. The report
suggests that the agency should have used the demographic index (an amalgam of only two of
the demographic indicators) to prioritize inspections. We do not believe it is appropriate to draw
conclusions based on that analysis or to imply there is an agency shortcoming on this point.
OIG Response 4: The intent of the EJSCREEN analysis was not to imply that the demographic
index should be used to prioritize inspections. It was included simply as a factual analysis of
demographic information in EJSCREEN.
OLEM and OECA believe that the OIG's report and broader investigations have
highlighted the need for improved program monitoring and use and understanding of the data in
this area. To this end, we accept the OIG's recommendations in the draft report as described
below and agree that actions undertaken in response to these recommendations will support
ongoing efforts and strengthen overall program management.
RESPONSE TO REPORT RECOMMENDATIONS
Our offices indicate acceptance of the OIG recommendations, as qualified, in the table
below.
Agreements
No.
OIG
Qualifications/Co
High-Level Intended
Estimated
Recommendation
mments for OIG
Recommendation
Corrective Action(s)
Completion by
Quarter and FY
1
Develop RCRAInfo
Suggest
OLEM/ORCR, in
1st Quarter
reports for regular
rephrasing
collaboration with OECA,
FY2022
distribution to EPA
Recommendation
will develop in RCRAInfo
regions that identify
1 to be: "Develop
and distribute to the EPA
non-operating
RCRAInfo
Regions a report that
treatment, storage,
reports for regular
identifies the inspection
or disposal facilities
distribution to
frequency status of non-
that have not been
EPA regions that
operating treatment,
inspected within 3
identify the
storage, or disposal
years, as required by
inspection
facilities within the
the Office of
frequency status
timeframes as stated in the
Enforcement and
of non-operating
Office of Enforcement and
Compliance
treatment,
Compliance Assurance's
Assurance
storage, or
Compliance Monitoring
Compliance
disposal facilities
Strategy.
Monitoring
within the
Strategy.
timeframes as
stated in the
Office of
Enforcement and
21-P-0114
30
-------
Compliance
Assurance's
Compliance
Monitoring
Strategy."
2
Establish
mechanisms to
ensure that all
required inspections
are completed
within the required
time frame of
2 years for operating
treatment, storage,
or disposal facilities
and 3 years for non-
operating treatment,
storage, or disposal
facilities.
OECA submits
alternative
language for
Recommendation
2: "Establish
mechanisms to
improve oversight
of regional and
state monitoring
at closed facilities
that include units
with waste closed
in place
consistent with
OECA's CMS
guidance."
OLEM/ORCR, in
collaboration with OECA,
will develop in RCRAInfo
and distribute to the EPA
Regions a report that
identifies the inspection
frequency status of non-
operating treatment,
storage, or disposal
facilities within the
timeframes as stated in the
Office of Enforcement and
Compliance Assurance's
Compliance Monitoring
Strategy.
1st Quarter
FY2022
3
Verify that the
Resource
Conservation and
Recovery Act
referrals to the
Superfund program
are added to
Superfund
Enterprise
Management
System for further
Superfund program
attention, as
necessary.
OIG should
correct error in
the spelling of
RCRA:
"Conservancy"
should be
"Conservation."
OLEM/OSRTI will: (1)
update the Superfund
Program Implementation
Manual (SPIM) as
appropriate to include
clearer timelines on
updating the RCRAInfo
identification number
currently tracked in the
Superfund Enterprise
Management System
(SEMS); (2) verify sites
referred from RCRA to
Superfund are added to
SEMS for further
Superfund program
attention, as necessary;
and (3) revise OSRTI-
managed SEMS public
search tools and publicly
available SEMS computer
reports to include the
SEMS RCRAInfo
identification number
variable.
2nd Quarter
FY2022
21-P-0114
31
-------
4
Verify that the
OIG should
OLEM/ORCR will (1)
4th Quarter
Superfund program
correct two
evaluate the existing
FY2023
deferrals to the
instances of error
policies and process for
Resource
in the spelling of
Superfund deferrals to
Conservation and
RCRA:
RCRA; (2) identify gaps;
Recovery Act are
"Conservancy"
and, (3) identify corrective
added to RCRAInfo
should be
measures, as needed, to
for further Resource
"Conservation."
meet program needs, such
Conservation and
as identifying Superfund
Recovery Act
program deferrals to
attention, as
RCRA in RCRAInfo.
necessary.
5
Develop and
EPA assumes this
Upon completion of
2nd Quarter
maintain a
recommendation
corrective actions #3 and
FY2024
crosswalk of
would only apply
#4, OLEM will ensure a
Superfund
to sites which
crosswalk of SEMS and
Enterprise
have been
RCRAInfo identification
Management
referred/deferred
numbers can be achieved
System and
from one program
for referral s/deferrals
corresponding
to the other.
between the two programs.
RCRAInfo
identification
numbers.
6
Implement controls
EPA assumes this
OLEM will standardize
3 rd Quarter
to identify and
recommendation
communications on the
FY2022
eliminate overlap of
would only apply
Cleanups in My
environmental
to sites which
Community webpage
indicators between
have been
regarding the intersection
Resource
referred/deferred
of RCRA Corrective
Conservation and
from one program
Action and Superfund
Recovery Act
to the other.
cleanup programs,
Corrective Action
including environmental
and Superfund
EPA recommends
indicator designations at
programs and
substituting
sites.
include this
"eliminate" with
information in
"clarify" in
public queries such
Recommendation
as Cleanups in My
6 to read as
Community.
follows:
"Implement
controls to
identify and
clarify overlap of
environmental
indicators..."
21-P-0114
32
-------
CONTACT INFORMATION
If you have any questions regarding this response, please contact Kecia Thornton (OLEM) at
thornton.kecia@epa.gov or 202-566-1913 or Gwendolyn Spriggs (OECA) at
spriggs.gwendolyn@epa.gov or 202-564-2439.
Attachment:
Technical Comments
21-P-0114
33
-------
Appendix D
Distribution
The Administrator
Associate Deputy Administrator
Assistant Deputy Administrator
Chief of Staff
Deputy Chief of Staff
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Continuous Improvement, Office of the Chief Financial Officer
Assistant Administrator for Land and Emergency Management
Principal Deputy Assistant Administrator for Land and Emergency Management
Deputy Assistant Administrator for Land and Emergency Management
Assistant Administrator for Enforcement and Compliance Assurance
Principal Deputy Assistant Administrator for Enforcement and Compliance Assurance
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Enforcement and Compliance Assurance
Audit Follow-Up Coordinator, Office of Land and Emergency Management
21-P-0114
34
------- |