Office of Inspector General Semiannual Report to Congress: October 1, 2020-March 31, 2021


OFFICE OF
INSPECTOR GENERAL
Semiannual
Report to Congress
October 1, 2020-March 31, 2021
EPA-350-R-21-001
May 2021

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Index of Reporting Requirements
Inspector General Act of 1978, as amended
Requirement
Subject
Page
Section 5(a)(1)
Significant problems, abuses, and deficiencies
12-32
Section 5(a)(2)
Significant recommendations for corrective action
3,12-21,26-27,30-32
Section 5(a)(3)
Reports with corrective action not completed
4-9, 51-62
Section 5(a)(4)
Matters referred to prosecutive authorities
22-27,42—43, 63
Section 5(a)(5)
Information or assistance refused
11
Section 5(a)(6)
List of reports issued
44-45
Section 5(a)(7)
Summaries of significant reports
3,13-21,26-27,30-31
Section 5(a)(8)
Audit, inspection, and evaluation reports—questioned costs
41
Section 5(a)(9)
Audit, inspection, and evaluation reports—funds to be put to better use
41
Section 5(a)(10)
Prior audit, inspection, and evaluation reports (1) for which no management decision was
made by the end of the reporting period, (2) for which no establishment comment was
returned within 60 days, and (3) for which there are unimplemented recommendations.
46-62
Section 5(a)(11)
Significant revised management decisions
None
Section 5(a)(12)
Significant management decisions with which OIG disagreed
None
Section 5(a)(14—16)
Peer reviews conducted
64
Section 5(a)(17—18)
Statistics on investigative reports, referrals, prosecutions, and indictments
40
Section 5(a)(19)
Substantiated investigations involving senior government employees
22
Section 5(a) (20)
Instances of whistleblower retaliation
11
Section 5(a) (21)
Any establishment attempts to interfere with independence
11
Section 5(a) (22)
Closed audits, evaluations, and investigations not disclosed to public
63
Abbreviations
CDC
CSB
EPA
FY
OIG
SES
u.s.c
Centers for Disease Control and Prevention
U.S. Chemical Safety and Hazard Investigation Board
U.S. Environmental Protection Agency
Fiscal Year
Office of Inspector General
Senior Executive Service
United States Code
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Message to Congress
Sean W. O'Donnell
The halfway mark between one fiscal year and the next presents a natural
opportunity to pause and take measure, ensuring that we are achieving our mission
of preventing and detecting fraud, waste, abuse, mismanagement, and misconduct
related to the programs and operations of the U.S. Environmental Protection
Agency and the U.S. Chemical Safety and Hazard Investigation Board. As the
inspector general for the EPA and the CSB, I am proud to report that staff have
remained true to our mission. The coronavirus pandemic is still an ever-present
concern, first and foremost in terms of employee safety but also in evaluating how
the EPA and CSB have adapted their efforts to execute their missions. We also
persist in identifying fraud schemes related to the pandemic, such as
misrepresentations of the EPA's endorsement of products. Our collective oversight efforts extend beyond
our pandemic-related work, however. We highlight our significant work over the past six months in the
pages of this semiannual report.
The OIG's Oversight Plan. During the first half of fiscal year 2021, the Office of Inspector General
upgraded from a traditional Annual. Plan to an Oversight Plan, which strategically maps out our ongoing
and future audits and evaluations to address the top challenges the EPA faces in executing its mission. These
top management challenges—which, after a systemic analysis of our body of work and input from Agency,
congressional, and other stakeholders, we presented in OIG Report No. 20-N-0231—are the bedrock of our
work efforts this fiscal year. Through continuous reassessment of our work efforts against the dynamic
environmental landscape, we ensure that our work remains relevant, timely, and of value.
Scientific Integrity and the OIG. The Agency's scientific integrity policy asserts that the EPA's "ability
to pursue its mission to protect human health and the environment depends upon the integrity of the science
on which it relies/' The OIG, with its statutory mandate to investigate
allegations of mismanagement or abuse of authority, plays a critical
role in protecting the Agency's scientific integrity. Consistent with our
statutory responsibilities, EPA policy states that each employee has
the duty to promptly report allegations of wrongdoing or irregularities,
including those involving scientific misconduct, to the OIG. The OIG
can provide a greater assurance of confidentiality to complainants than
alternative reporting mechanisms and help protect them against retaliation. As an independent office, the
OIG can also receive and act on complaints against senior EPA officials without fear of undue influence.
In addition, by being fully cognizant of all allegations made, we can identify systemic scientific integrity
issues and then initiate audits or evaluations to assess and make recommendations to correct the root causes
of these issues. To facilitate transparency, we continue our practice, started in our previous semiannual
report, of providing a summary of our oversight of scientific integrity at the Agency.
Consistent with the OIG's statutory
responsibilities, EPA policy states that
each employee has the duty to promptly
report allegations of wrongdoing or
irregularities, including those involving
scientific misconduct, to the OIG.
Palpable OIG Impacts. The OIG's work does not exist in a vacuum; rather, it improves how the Agency's
operations and programs protect human health and the environment. Our investigations, audits, and
evaluations have real impacts—some big, some small, but all ensuring that the EPA is a faithful steward of
American tax dollars. For example, during this semiannual period:
• Our Office of Investigations completed a far-reaching, in-depth investigation into allegations of
time-and-attendance misconduct by two former senior EPA officials. We determined that the

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
officials, by making and using official timesheets and personnel forms that contained materially
false statements and representations, arranged for the EPA to improperly pay two former employees
after their employment at the EPA was terminated. We also determined that one of the former
senior officials committed time-and-attendance misconduct by not recording absences from the
official"s duty station.
• OIG Report No. 20-P-0173. Further Efforts Needed to Uphold Scientific Integrity Policy at EPA,
published on May 20, 2020, still reverberates. On March 23, 2021, EPA Administrator Michael S.
Regan sent an email to all EPA employees, which outlined several actions in response to a
presidential memorandum. These actions also address core findings in our report, namely employee
concerns regarding the EPA's culture of scientific
integrity, the EPA's management of federal advisory
committees, the ability of EPA staff to express
scientific opinions, and retaliation after reporting a
potential scientific integrity violation.
• In response to OIG Report No. 21-P-0094. EPA
Improperly Awarded and Managed Information
Technology Contracts, published on March 10,
2021, which found that the EPA spent $52.5 million
in taxpayer funds under three contracts without
proper approvals and did not adequately manage
equipment purchases, the EPA immediately
instituted cost-effective measures by moving
information technology equipment from the vendor's location to the EPA's Research Triangle Park
National Computer Center. This move allowed the EPA to avoid vendor overhead costs. The OIG
report also identified nearly $642,000 of information technology equipment that the EPA purchased
but had not inventoried. This equipment could have been left in the vendor's possession. The EPA
disseminated this equipment to EPA programs, reducing the need for new equipment purchases.
The Way Ahead. In the final six months of fiscal year 2021, my staff and I will continue to work toward
significant goals. We have begun the important process of identifying the EPA's top management
challenges for fiscal year 2022. We are carefully evaluating our organizational structure to make sure we
are adequately and effectively positioned to address the EPA's programs and operations. We will publish
the results of a number of significant, far-reaching audits and evaluations, as detailed in our quarterly
Expected Report Issuance document. Above all, we are eager to continue our critical work of serving as a
premier oversight organization trusted to speak the truth, promote good governance, and contribute to
improved human health and environment.
LS&HJ
SeanW. O'Donnell
Inspector General
OIG Accomplishments, First Half of FY 2021
• Questioned costs and potential monetary
benefits (includes results from single audits):
$145.47 million
• Total fines and recoveries (includes
EPA-only and joint investigations):
$0,695 million
• Reports issued: 19 reports
• Investigative cases closed: 81 cases
• Administrative actions resulting from
investigative cases: 12 actions
• Hotline contacts referred for action:
214 referrals

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Table of Contents
About EPA and Its Office of Inspector General		1
Scoreboard of Results		2
OIG's Oversight Plan Links Audits and Evaluations
to EPA's Management Challenges		3
Status of OIG Unimplemented Recommendations		4
Furthering EPA's Efforts to Protect Human Health and Environment		10
Instances of Whistleblower Retaliation and Interference with Independence...	11
Significant OIG Activity		12
Congressionally Requested Activities		12
Coronavirus Pandemic: Oversight Activities		13
Human Health and Environmental Issues		16
Agency Business Practices and Accountability		20
Investigations		22
Hotline Activities		26
U.S. Chemical Safety and Hazard Investigation Board		30
Other Activity		32
Other Results of OIG Work		33
Follow-Up Is an Important Aspect of OIG Efforts		33
Single Audit Reporting Efforts Make Impact		34
Agency Best Practices		35
Scientific Integrity and Misconduct Issues		36
Scientific Integrity Allegations		36
Scientific Misconduct Allegations Received by OIG		39
Statistical Data		40
Profile of Activities and Results		40
Audit Report Resolution		41
Summary of Investigative Results		42
-continued-

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Appendices		44
Appendix 1—Reports Issued		44
Appendix 2—Reports Issued Without Management Decisions		46
Appendix 3—Reports with Corrective Action Not Completed		51
Appendix 4—Closed Investigations Involving Senior Employees		63
Appendix 5—Peer Reviews Conducted		64
Appendix 6—OIG Mailing Addresses and Telephone Numbers		65

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
About EPA and Its
Office of Inspector General
U.S. Environmental Protection Agency
The mission of the U.S. Environmental Protection Agency is to protect human health and
the environment. As America's steward for the environment since 1970, the EPA has
endeavored to ensure that the public has air that is safe to breathe, water that is clean and
safe to drink, food that is free from dangerous pesticide residues, and communities that are
protected from toxic chemicals.
EPA Office of Inspector General
The Office of Inspector General, established by the Inspector General Act of 1978, as
amended, 5 U.S.C. app., is an independent office of the EPA that detects and prevents fraud,
waste, and abuse to help the Agency protect human health and the environment more
efficiently and effectively. OIG staff are based at EPA headquarters in Washington, D.C.; the
EPA's ten regional offices; Research Triangle Park, North Carolina; and Cincinnati, Ohio.
The EPA inspector general also serves as the inspector general for the U.S. Chemical Safety
and Hazard Investigation Board. Our vision, mission, and goals are as follows:
Vision
Be a premier oversight organization trusted to speak the truth, promote good
governance, and contribute to improved human health and environment.
Mission
Conduct independent audits, evaluations, and investigations; make evidence-based
recommendations to promote economy, efficiency, and effectiveness; and prevent and
detect fraud, waste, abuse, mismanagement, and misconduct for the EPA and the CSB.
Goals
1. Contribute to improved EPA and CSB programs and operations protecting human
health and the environment and enhancing safety.
2. Conduct audits, evaluations, and investigations that enable the EPA and the CSB to
improve business practices and accountability.
3. Improve OIG processes, resource allocation, and accountability to meet stakeholder
needs.
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Scoreboard of Results
The information below shows return on investment to the taxpayer for work performed by the EPA OIG during the first
half of fiscal year 2021 compared to the FY 2021 annual performance goal targets. All results reported are based on
goals and plans established under the Government Performance and Results Act.
Annual Performance Goal 1:
Environmental and business outcome actions taken; changes, corrections, or improvements made; and
risks reduced, eliminated, or influenced by OIG work
Target:3 140
Reported: 72
(51.4% of goal)
Supporting measures
5 Environmental/health improvements realized or influenced by OIG work
66 Environmental, chemical safety, or business policy, practice, or process change made,
or decision implemented based on OIG recommendations
1 Legislative or regulatory changes
Annual Performance Goal 2:
Recommendations, challenges, best practices, or risks identified for action
Target:3 840
Reported: 329
(39.2% of goal)
Supporting measures
9 Environmental/management verifications
*91 Recommendations for improvement (including risk identified)
0 Referrals to the Agency based on OIG work
*229 Findings and recommendations to the Agency from external reports
Annual Performance Goal 3:
Return on investment: potential dollar return as percentage of OIG budget
Target: $80,427,200
(160% of budget)
Reported: $142,622,425
(177.3% of target)
Supporting measures (in millions)
OIG budget: $55,086
Potential return: $145.47
*$0,771 Questioned costs
$2,198 Potential monetary benefits and cost efficiencies identified in OIG reports
$142.5 Monetary actions taken or resolved prior to report issuance
$0 Cost savings the Agency achieved after implementing recommendations
$0.017 Costs the Agency avoided after implementing recommendations or based on investigative
results
$0 Fines, penalties, settlements, and restitutions—EPA OIG-only investigations
$0,695 Fines, penalties, settlements, and restitutions—EPA OIG joint investigations
Annual Performance Goal 4:
Criminal, civil, and administrative actions reducing risk, and loss of resources
and operational integrity taken or influenced by OIG work
Target:3 93
Reported: 26
(28.0% of goal)
Supporting measures
0 Allegations disproved
9 Indictments, informations, and complaints
5 Criminal convictions
0 Civil actions
9 Administrative actions taken (other than suspension or debarment actions)
3 Suspension or debarment actions
Other (no targets established)
Savings and recommendations sustained:11
•	*92 sustained environmental or business recommendations for action
•	*$0.819 million in sustained questioned costs
•	$1.181 million in sustained potential monetary benefits
Sources: The OIG Performance Measurement Results System and the Inspector General Enterprise Management System. (EPA OIG table)
* These measures include single audits, which are audits of nonfederal entities performed by private firms.
a The target was adjusted by OIG leadership since the issuance of the EPA OIG's April 1, 2020-September 30, 2020 Semiannual Report
to Congress (Report No. EPA-350-R-20-002V
b Use of "sustained" indicates agreement, in whole or in part, by the Agency to an OIG-identified questioned cost, recommendation, or
benefit.
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
OIG's Oversight Plan Links Audits and
Evaluations to EPA's Management Challenges
Issued March 2021
Our Fiscal Year 2021 Oversight Plan describes the oversight work we intend to conduct this
fiscal year, as well as our ongoing and completed audits and evaluations as of March 2021.
Previously, we published Annual Plans to guide our oversight work. This fiscal year, we
present an Oversight Plan to categorize, by top management challenge for the Agency, our
oversight work. In Report No. 20-N-0231. EPA's FYs 2020-2021 Top Management
Challenges, published July 21, 2020, we identify what we consider to be the EPA's eight
most significant challenges in accomplishing its mission for FYs 2020-2021:
• Maintaining operations during pandemic and natural disaster responses.
• Complying with key internal control requirements, including developing risk
assessments, ensuring quality data, and creating effective operational policies and
procedures.
• Overseeing states, territories, and tribes responsible for
implementing EPA programs.
• Improving workforce/workload analyses to accomplish
the EPA's mission efficiently and effectively.
• Enhancing information technology security to combat
cyberthreats.
• Communicating risks to allow the public to make
informed decisions about its health and the environment.
• Fulfilling mandated reporting requirements.
• Integrating and leading environmental justice across the
Agency and government.
In addition to considering these top management challenges when planning our oversight
work, we review and consider our own research and previous work; key Agency strategic
documents, such as strategic plans and budgets; oversight work from other organizations;
and congressional hearings, legislation, and feedback. When considered collectively, these
resources help ensure that we undertake audits and evaluations to address the EPA's most
pressing challenges. It is important to note that our Oversight Plan is not static, and our
projects may be modified throughout the year as new management challenges and risks for
the EPA emerge.
In this semiannual report, we identify which management challenges our audits and
evaluations address, as applicable, next to the following symbol: O
We focus on the EPA in our
Oversight Plan, as the
majority of our resources
are dedicated to oversight
of the EPA. However, in
OIG Report No. 20-N-0218.
Fiscal Year 2020 U.S.
Chemical Safety and
Hazard Investigation Board
Management Challenges,
issued July 6,2020, we
identify what we consider to
be the top three
management challenges for
the CSB. We also address
our CSB oversight projects
in a separate section in the
Oversight Plan.
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Status of OIG Unimplemented
Recommendations
OIG audits and evaluations provide recommendations to improve EPA or CSB programs
and operations. The EPA, the CSB, and the public benefit from the implementation of these
recommendations. The OIG recommendations listed in Appendix 3, however, remain
unimplemented. We analyzed that list of unimplemented recommendations and provide the
results of that analysis below. Unimplemented recommendations are those that have been
agreed to by the Agency but for which corrective action has not been completed.
Recommendations that are unresolved are not counted as unimplemented
recommendations. Unresolved recommendations are those with which the Agency
disagrees, the Agency did not provide a formal written response, the Agency response is
incomplete, or with which the OIG does not agree that the Agency's proposed corrective
actions are responsive to the recommendation. Recommendations that remain unresolved
six months after the associated final report is issued are listed in Appendix 2.
Unimplemented recommendations as of March 31, 2021
(presented by fiscal year issued)
80
70
60
50
40
d H3 _ _
? % 30
20
10
0
0 0 0
FYs 2008- FY 2015
2014
FY 2016 FY 2017
FY 2018 FY 2019
FY 2020
For the semiannual reporting period ending March 31, 2021, the EPA cumulatively had
115 unimplemented recommendations and the CSB had two unimplemented
recommendations. The potential monetary benefits of these recommendations are
approximately $48.8 million for the EPA and $0 for the CSB. The below table shows the
status of the unimplemented recommendations, which fall into six categories. The two CSB
recommendations are included in the "Management and Operations" category.
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Category
Total
Number of
unimplemented
recommendations
Potential
monetary
benefits
(in $000s)
EPA Unimplemented Recommendations
1. Management and Operations
49
$20,959
2. Water Quality
5
$0
3. Environmental Contamination and
Cleanup
12
$27,800
4. Toxics, Chemical Safety, and
Pesticides
13
$0
5. Air Quality
25
$0
6. Research and Laboratories
11
$0
EPA subtotal
115
$48,759
CSB Unimplemented Recommendations
Management and Operations
2
$0
CSB subtotal
2
$0
TOTAL
117
$48,759
Category 1—Management and Operations
Of the recommendations we have issued related to management and operations, 51 across
18 reports remain unimplemented. Two of these unimplemented recommendations were
issued to the CSB in two reports, while 49 were issued to the EPA in 16 reports. When
implemented, these recommendations will lead to more effective and efficient operations
and potential monetary benefits of approximately $21 million for the EPA:
• Improve oversight of:
1.	Grant work plans from tribes in Regions 1 and 5 (Report No. 20-P-0335).
2.	Procurement of supplies and guidance for emergency responses during the
pandemic (Report No. 20-E-0332).
3.	Security of Region S's local area network (Report No. 20-E-0309). The
potential monetary benefit of one of the unimplemented recommendations
issued in this report is approximately $11.5 million.
4.	Region 5's records management program (Report No. 20-E-0295).
5.	Intergovernmental Personnel Act assignments (Report No. 20-P-0245).
6.	Agencywide Quality System (Report No. 20-P-0200).
7.	Improper payments reporting (Report No. 20-P-0167).
8.	Time-and-attendance system for compliance with Information Technology
Investment Requirements (Report No. 20-P-0134). The potential monetary
benefit of one of the unimplemented recommendations issued in this report
is approximately $1.2 million.
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
9.	Reporting under the Grants Oversight and New Efficiency Act and
timeliness of expired grant closeouts (Report No. 20-P-0126). The potential
monetary benefit of one of the unimplemented recommendations issued in
this report is approximately $8.3 million.
10.	Implement management controls to verify and report Border 2020 Program
accomplishments (Report No. 20-P-0083).
11.	FYs 2019 and 2018 (restated) consolidated financial statements (Report
No. 20-F-0033).
12.	Records management policy (Report No. 19-P-0283).
13.	Companies with multiple cleanup liabilities that self-insure
(Report No. 18-P-0059).
14.	Emergency and rapid response contracts (Report No. 14-P-0109).
• Implement better processes for information technology regarding:
15.	Risk management and incident response information security functions
(Report No. 20-P-0120).
During the semiannual reporting period ending March 31, 2021, we found
that the Agency falsely certified that it completed corrective actions for
Recommendations 1 and 2 from OIG Report No. 20-P-0120, EPA Needs to
Improve Its Risk Management and Incident Response Information Security
Functions, issued March 24, 2020:
•	For Recommendation 1, the Agency agreed to implement a two-part
corrective action but had only implemented one part when it certified
the recommendation was completed.
•	For Recommendation 2, the Agency certified that the corrective
action had been completed as of its originally scheduled milestone
date. However, our oversight work on the EPA's compliance in FY 2020
with the Federal Information Security Modernization Act (Project
No. QA&E-FY20-0033) identified that the action had, in fact, not
been completed.
16.	CSB's information security program, specifically risk management,
identity-and-access management, and incident response
(Report No. 20-P-0077).
17.	Pesticide registration fee, vulnerability mitigation, and database security for
the Federal Insecticide, Fungicide, and Rodenticide Act and Pesticide
Registration Improvement Act systems (Report No. 19-P-0195).
18.	CSB's information security program, specifically incident response and
identity-and-access management (Report 19-P-0147).
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Category 2—Water Quality
Of the recommendations we have issued related to water quality, five across three reports
remain unimplemented. When implemented, these recommendations will lead to improved
human health and environment, as well as more effective and efficient operations:
1.	Improve oversight of notice to the public on drinking water risks to better protect
human health (Report No. 19-P-03 IS).
2.	Improve management of the Oil Pollution Prevention program
(Report No. 12-P-0253).
3.	Revise outdated or inconsistent EPA-state clean water memorandums of agreement
(Report No. 10-P-0224).
Category 3—Environmental Contamination and Cleanup
Of the recommendations we have issued related to environmental contamination and
cleanup, 12 across five reports remain unimplemented. When implemented, these
recommendations will lead to improved human health and environment, more effective and
efficient operations, and potential monetary benefits of $27.8 million:
1.	Stop the use of unapproved slag at Anaconda Co. Smelter Superfund Site and
inform the public of the health risks of using the slag (Report No. 20-N-0030).
2.	Implement more efficient and effective methods to assess the impact of unregulated
pollutants in land-applied biosolids (Report No. 19-P-0002).
3.	Finish prioritization and resource allocation methodologies for abandoned uranium
mine sites on or near Navajo lands (Report No. 18-P-0233).
4.	Revise risk management inspection guidance to recommend minimum inspection
scope and provide detailed examples of minimum reporting (Report No. 13-P-0178).
5.	Make better use of Stringfellow Superfund Special Accounts
(Report No. 08-P-0196). The potential monetary benefit of this unimplemented
recommendation is $27.8 million.
Category 4—Toxics, Chemical Safety, and Pesticides
Of the recommendations we have issued related to toxics, chemical safety, and pesticides,
13 across eight reports remain unimplemented. When implemented, these recommendations
will lead to improved human health and environment:
1. Improve data controls for the annual Toxics Release Inventory national analysis
(Report No. 20-P-0337).
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Semiannual Report to Congress
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2. Develop plans to meet Toxic Substances Control Act deadlines
(Report No. 20-P-0247).
3. Implement formal goals and additional oversight for the Safer Choice Program
(Report No. 20-P-0203).
4. Develop circuit rider inspector guidance (Report No. 20-P-0012).
5. Effectively implement the Lead-Based Paint Renovation, Repair and Painting Rule
(Report No. 19-P-0302).
6. Determine strategies and level of support for overseeing State Managed Pollinator
Protection Plans (Report No. 19-P-0275).
7. Evaluate the impact of the revised Agricultural Worker Protection Standard on
pesticide exposure incidents (Report No. 18-P-0080).
8. Take additional measures to prevent deaths and serious injuries from residential
fumigations (Report No. 17-P-0053).
Category 5—Air Quality
Of the recommendations we have issued related to air quality, 25 across ten reports remain
unimplemented. When implemented, these recommendations will lead to improved human
health and environment:
1. Improve oversight of how states implement air emissions regulations for municipal
solid waste landfills (Report No. 20-P-0236).
2. Improve processing times for New Source Air Permits in Indian Country (Report
No. 20-P-0146).
3. Inform residents living near ethylene oxide-emitting facilities about health
concerns and actions to address those concerns (Report No. 20-N-0128).
4. Improve emergency planning to better address air quality concerns during future
disasters (Report No. 20-P-0062).
5. Improve oversight for particulate matter emissions compliance testing (Report
No. 19-P-0251).
6. Develop required cost-and-benefit analyses and assess air quality impacts on
children's health for Proposed Glider Repeal Rule allowing used engines in
heavy-duty trucks (Report No. 20-P-0047).
7. Enhance verification of continuous monitoring system performance for air
emissions data (Report No. 19-P-0207).
8. Improve the on-road heavy-duty vehicle compliance program (Report No. 19-P-0168).
9. Improve controls to address strategic risks in the light-duty vehicle compliance
program and achieve compliance with mobile source regulations
(Report No. 18-P-0181).
10. Meet certain statutory requirements to identify environmental impacts of the
Renewable Fuel Standard (Report No. 16-P-0275).
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Semiannual Report to Congress
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Category 6—Research and Laboratories
Of the recommendations we have issued related to research and laboratories, 11 across
two reports remain unimplemented. When implemented, these recommendations will lead
to improved human health and environment, as well as more effective and efficient
operations:
1.	Improve efforts to uphold scientific integrity policy (Report No. 20-P-0173).
2.	Develop a comprehensive vision and strategy for citizen science that aligns with the
Agency's strategic objectives on public participation (Report No. 18-P-0240).
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Furthering EPA's Efforts to Protect Human
Health and Environment
When planning and conducting audits and evaluations, we consider how our oversight work
can support the EPA's mission-related efforts to protect human health and the environment.
In the table below and throughout the pages of this report, we show how our reports issued
during the semiannual period ending March 31, 2021, support particular Agency efforts with
the following symbol: i®. Also, some of the work we conducted this semiannual period is
required by law or executive order; these mandatory reporting requirements are identified in
the table below and elsewhere in this semiannual report by the following symbol:
OIG-lssued Reports Related to EPA Programs and Operations
Report title
Report no.
Improving
air quality
Ensuring
clean/safe
water
Cleaning up/
revitalizing
land
Ensuring
safety of
chemicals
Improving
EPA research
programs
Compliance
with the law
Partnering
with states/
others
Operating
efficiently/
effectively
EPA's Fiscal Years 2020 and 2019
Jin (Restated) Consolidated Financial
Statements
21-F-0014







A
EPA's Initial Plans for Returning to the Office
Incorporate CDC Guidance but Differ by
Location
21-E-0030







A
EPA Needs to Improve Oversight of Invoice
Reviews and Contractor Performance
Evaluation
21-E-0031







A
Region 2's Hurricanes Irma and Maria
Response Efforts in Puerto Rico and U.S.
Virgin Islands Show the Need for Improved
Planning, Communications, and Assistance
for Small Drinking Water Systems
21-P-0032

A




A
A
EPA Needs to Improve Its Planning and
Management of Laboratory Consolidation
Efforts
21-E-0033







A
EPA Needs to Substantially Improve
Oversight of Its Military Leave Processes to
Prevent Improper Payments
21-P-0042





A

A
Evaluation of EPA's Compliance with
the Executive Order 13950 on
Combating Race and Sex Stereotyping
21-E-0044





A


EPA's Fiscal Years 2019 and 2018
Jljp Hazardous Waste Electronic Manifest
System Fund Financial Statements
21-F-0045







A
Office of Research and Development
Initiatives to Address Threats and Risks to
Public Health and the Environment from
Plastic Pollution Within the Waters of the
United States
21-N-0052

A


A



EPA Mostly Adheres to Regulations When
Assessing Risks of New Pesticides but Should
Improve Internal Controls
21-P-0070



A




EPA Is at Risk of Not Achieving Special Local
Needs Program Goals for Pesticides
21-E-0072



A




EPA Improperly Awarded and Managed
Information Technology Contracts
21-P-0094





A

A
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
21-P-0114


A



A
A
EPA Does Not Always Adhere to Its
Established Action Development Process for
Rulemaking
21-P-0115





A

A
10

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Instances of Whistleblower Retaliation and
Interference with Independence
Whistleblower Retaliation
Section 5(a)(20) of the Inspector General Act of 1978, as amended, requires a detailed
description of any instances of whistleblower retaliation noted by the EPA OIG.
This requirement includes reporting information about any officials found to have
engaged in retaliation and the consequences the Agency imposed to hold such officials
accountable. There were no whistleblower retaliation cases closed within the semiannual
period ending March 31, 2021. No officials were found to have engaged in retaliation.
Interference with Independence
Section 5(a)(21) of the Inspector General Act requires a detailed description of any
attempt by the Agency to interfere with the independence of the EPA OIG, including
"incidents where the establishment has resisted or objected to oversight activities of the
[OIG] or restricted or significantly delayed access to information, including the
justification of the establishment for such action."
In our Semiannual Report to Congress published one year ago in May 2020 (Report
No. EPA-350-R-20-001). we recounted our issuance of a "Seven-Day Letter" to the EPA
administrator, which identified a senior Agency official's refusal to participate in
investigation and audit interviews as interference with the OIG's independence.
Then-Administrator Andrew Wheeler sent the Seven-Day Letter to Congress,
accompanied by a memorandum from the EPA general counsel, which adopted an
unacceptably narrow interpretation of the OIG's authority to access information and
interview Agency personnel. Three committee chairs in the U.S. House of
Representatives subsequently urged the Agency to withdraw the general counsel's
memorandum, observing that, "if accepted, [it] would eviscerate the authority of the
Inspector General and undermine the ability of EPA to function in a transparent manner."
As noted in the subsequent Semiannual Report to Congress
published November 2020 (Report No. EPA-350-R-20-002). if
left in place, this memorandum would signal to EPA employees
that they do not need to fully cooperate with the OIG in the
pursuit of its mission to detect and prevent fraud, waste, and
abuse. Although the Agency did not withdraw the general
counsel's memorandum during the semiannual reporting period
ending March 31, 2021, the Agency's acting general counsel
withdrew the memorandum in April 2021.
What Is a "Seven-Day Letter"?
Section 5(d) of the Inspector General Act
requires an inspector general to report to
the head of the agency instances of
"particularly serious or flagrant problems,
abuses, or deficiencies relating to the
administration of programs and
operations of such establishment." The
agency head then must transmit the
report "to the appropriate committees or
subcommittees of Congress within seven
calendar days." This report is therefore
commonly called a "Seven-Day Letter."
11

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Significant OIG Activity
Congressionally Requested Activities
Each time the OIG receives a request from Congress to undertake discretionary work, we
must consider whether we have enough resources—people, time, and funds—to conduct
our work in a timely fashion and whether undertaking the requested work would preclude
our doing other crucial work. We must also consider the many OIG projects that are
statutorily mandated. For every discretionary review the OIG decides to undertake, there
will be others we cannot. We therefore must make difficult decisions about whether to
initiate work requested by Congress.
In the semiannual period ending March 31, 2021, we did not publish any reports based on
congressionally requested work.
Briefings, Requests, and Inquiries
During this reporting period, the OIG provided 15 briefings to Congress on the OIG's
oversight work. Briefings involved OIG staff meeting with congressional staff to better
understand their perspectives, provide information about the OIG, and establish the
foundation for an open dialogue. Other briefings included discussions with congressional
staff of recent, ongoing, and future OIG work. During this reporting period, the OIG
received one congressional request.
12

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Coronavirus Pandemic: Oversight Activities
EPA's Initial Plans for Returning to the Office Incorporate CDC Guidance
but Differ by Location
Report No, 21-E-0030, issued November 30, 2020
£l Operating efficiently and effectively
{o} Maintaining operations during pandemic and natural disaster responses
All 13 EPA locations we
reviewed had developed
reopening plans—which
incorporate the health and
safety measures outlined in
the Centers for Disease
Control and Prevention's
Interim Guidance—
to protect their workforces
from the coronavirus
pandemic. How these plans
implement some of the (DCs measures, such as face coverings and social distancing,
differs substantially, however. The Agency disagreed with some of the facts reflected in
our report but agreed with our recommendation to determine whether the location-specific
reopening plans should be revised to address the differences.
CSB Discontinued Information Recovery Testing and Off-Site Backup Storage
During the Coronavirus Pandemic
Report No. 2.1-E-Q016, issued November 18, 2020
The CSB did not perform disaster recovery testing on major information systems during
FY 2020, nor did it store copies of backup media at an off-site location. The CSB
indicated that the coronavirus pandemic impeded its
efforts to complete these tasks. The OIG contractor
that completed this evaluation recommended that
the CSB test its disaster recovery' plan at least
annually and evaluate alternate methods to store
backup media off-site. Hie CSB agreed with these
recommendations.
EPA OIG and CDC images.
Source: OIG analysis of EPA data. (EPA OIG images)
Report Addresses: EPA mission-related effort {o OIG-identified management challenge for EPA. Mandatory reporting requirements.
13

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
OIG Investigations Related to Pandemic
The Office of Investigations opened a number of cases to investigate allegations of fraud
related to the coronavirus pandemic. Allegations investigated included schemes to
defraud Americans through, among other things, the misuse of the EPA logo or seal. The
office investigated many of these cases jointly with the EPA Criminal Investigation
Division or other law enforcement agencies, and it coordinated with and referred matters
to the EPA, as appropriate.
The pie chart below reflects the conclusions of the 15 pandemic-related cases closed
during this semiannual reporting period.
Results of closed cases involving the coronavirus pandemic
Source: EPA OIG Office of Investigations. (EPA OIG graphic)
OIG Transparency Efforts
Webpage: EPA OIG's Response to the COVID-19 Pandemic
Launched May 2020, continually updated
To ensure transparency and keep the public up to date on our efforts, we maintain a
website of our work related to the pandemic. This website lists potential audit or
evaluation topics, recently announced projects, potential investigation targets, and issued
reports.
COVID-19 Pandemic Report: Summary of Oversight Activities as of March 2021
Updated March 2021
This summary report captures the OIG's work to meet the challenges posed by the
coronavirus pandemic. The OIG continues to initiate audits, evaluations, and
14

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
investigations related to the impact of the coronavirus pandemic on the EPA and the
CSB. We are examining and identifying how the pandemic has impacted Agency
programs and operations, as well as potential misconduct and criminal activity. Some
subjects we have looked at or may look at include the EPA's responses to emergency
incidents, such as hurricanes and wildfires; releases of hazardous substances; air quality
enforcement; and potential misconduct and criminal activity. To accomplish these
pandemic-focused oversight initiatives, we are working and coordinating with other
federal OIGs, the Pandemic Response Accountability Committee under the Council of
the Inspectors General on Integrity and Efficiency, and the U.S. Government
Accountability Office.
15

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Human Health and Environmental Issues
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. issued March 29, 2021
£3 Cleaning up and revitalizing land; Partnering with states and other stakeholders;
Operating efficiently and effectively
|o Overseeing states implementing EPA programs; Communicating risks;
Integrating and leading environmental justice
The EPA did not consistently verify the continued protection of human health and the
environment at hazardous waste treatment, storage, or disposal facilities. Specifically,
49.3 percent of these facilities with management units—for example, landfills—that have
been closed with hazardous waste in place were not inspected as often as required by
federal statute or set forth in EPA policy, and the Agency's regional oversight of such
inspections was inconsistent. A lack of inspections could cause a hazardous waste leak
from a compromised unit to go undetected for years. In addition, the EPA did not
effectively track the hazardous waste treatment, storage, or disposal facilities that were
either managed by both the Supcrfund program and the Resource Conservation and
Recovery Act program or transferred between the two programs. The Agency agreed
with three of our recommendations, while it did not agree with the other three. Resolution
efforts are in progress.
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Hazardous waste facilities with units closed with waste in place. Green represents operating
facilities, and brown represents nonoperating facilities. Source: OIG data from RCRAInfo mapped
by EPA technical staff. (EPA OIG image)
Report Addresses: EPA mission-related effort {o OIG-identified management challenge for EPA. Mandatory reporting requirements.
16

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Region 2's Hurricanes Irma and Maria Response Efforts in Puerto Rico and U.S.
Virgin Islands Show the Need for Improved Planning, Communications, and
Assistance for Small Drinking Water Systems
Report No, 21-P-0032, issued December 3, 2020
Ensuring clean and safe water; Partnering with states and other stakeholders;
Operating efficiently and effectively
{§) Overseeing states and territories implementing EPA programs; Communicating risks
After Hurricanes Irma and Maria hit Puerto Rico and the U.S. Virgin
Islands in September 2017, Region 2 assessed the operational status of the
islands" drinking water and wastewater systems; conducted water
sampling and analyses; and
Translation
Espariol
B helped small, rural drinking water systems
obtain generators. However, some small,
j rural drinking water systems were still not
operational more than nine months after the
I I -jfBrl storms made landfall; the EPA's internal
t j review processes delayed public health
announcements, and Region 2 did not fully
engage its local staff on the islands.
Left: Hurricane Maria. (National Oceanic and Atmospheric
Administration photo). Right: A rural water system in Puerto Region 2 agreed with our three
Rico. (EPA OIG photo) recommendations.
EPA Does Not Always Adhere to Its Established Action Development Process
for Rulemaking
Report No. 21-P-Q115, issued March 31, 2021
Compliance with the law; Operating efficiently and effectively
Complying with key internal control requirements (data quality; policies and procedures)
Pod cast
O
Average Adherence to
EPA's Rulemaking
Process
The EPA did not consistently follow its Action Development Process
during rulemaking, a process meant to result in high-quality rules. Using
a checklist to assess adherence for 58 rules, we found approximately
81 percent adherence, 14 percent nonadherence, and 6 percent undetermined adherence to
steps in the rulemaking process* In addition, major milestones of the process were
skipped, and documentation was not
properly maintained in the tracking database.
One recommendation is resolved with
corrective actions pending, and four
recommendations are unresolved with
resolution efforts in progress.
Average Nonadherence
to EPA's Rulemaking
Process
Average Undetermined
Adherence to EPA's
Rulemaking Process
Variation in the EPA's adherence to its Action Development
Process checklist steps ranged from 44 to 100 percent.
(EPA OIG graphic)
* Due to rounding, percentages do not total 100
percent.
Report Addresses: EPA mission-related effort {o OIG-identified management challenge for EPA. Mandatory reporting requirements.
17

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
EPA Mostly Adheres to Regulations When Assessing Risks of New Pesticides
but Should Improve Internal Controls
Report No. 2.1-P-0070, issued February 8, 2021
Ensuring the safety of chemicals
Complying with key internal control requirements (data quality)
For the nine unconditional pesticide registrations we reviewed, we found that the EPA's
Office of Pesticide Programs mostly adhered to applicable regulations, policies, and
procedures in assessing the risks of the pesticides to human health and the environment
during the issuance process for unconditional pesticide
In accordance with the Federal Insecticide, reglstrations. Of the eight criteria outlined in federal
Fungicide, and Rodenticide Act, the EPA can ° °
unconditionally register a pesticide if the regulations for unconditional pesticide registrations, the
application is complete and all criteria are met Office of Pesticide Programs fully complied with four,
or conditionally register a pesticide if
additional data are needed while two were not applicable to the registrations we
reviewed. The other two criteria address, in part,
toxicology and ecological data requirements. We verified that the office met all
toxicology data requirements, but we could not verify that it met all ecological data
requirements. In addition, the Office of Pesticide Programs lacked a standard operating
procedure governing how to conduct initial pesticide registrations. The Agency agreed
with our two recommendations.
EPA Is at Risk of Not Achieving Special Local Needs Program Goals for Pesticides
Report No. 2.1-E-0072, issued February 10, 2021
Ensuring the safety of chemicals
-------
Semiannual Report to Congress
October 1, 2020-March 31, 2021
Office of Research and Development Initiatives to Address Threats and Risks to
Public Health and the Environment from Plastic Pollution Within the Waters of
the United States
Report No. 21-N-0052, issued January 6, 2021
Ensuring clean and safe water; Improving EPA research programs
{o} Complying with key internal control requirements (risk assessments)
The EPA's research into plastics is in its early stages. The Office of Research and
Development has not conducted enough research to determine risks to public health and
the environment from plastic exposure. The 2019-2022 Safe and Sustainable Water
Resources Strategic Research Action Plan commits the Office of Research and
Development to deliver recommendations for best practices and standardized
methodologies to characterize micro/nanoplastics in sediment and surface water. We
issued no recommendations as a result of our findings.
Report Addresses: ^ EPA mission-related effort, s } OIG-identified management challenge for EPA. Mandatory reporting requirements.
19
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Agency Business Practices and Accountability
EPA Needs to Improve Its Planning and Management of Laboratory
Consolidation Efforts
Report No. 21-E-0033, issued December 7, 2020
Operating efficiently and effectively
{ '? Complying with key internal control requirements (data quality)
In 2015, the EPA estimated that it could save approximately $409 million
in avoided costs and savings over 30 years by consolidating its laboratory
facilities. For the three laboratory consolidation projects we reviewed,
however, the Agency had not developed a master plan for one $2 million project, nor did
it have documentation explaining its management decisions concerning consolidation
projects. In addition, two projects were delayed and incurred over $8 million in cost
overruns. Because the Agency did not have specific procedures and requirements for
planning and tracking consolidations, the EPA is at risk of not meeting projected costs
and savings goals. The Agency agreed with our recommendation to develop detailed
procedures for planning and managing laboratory consolidation efforts.
Cost overruns for two laboratory consolidation efforts
Consolidation effort
Planned costs
Actual costs
Costs overruns
Corvallis, Oregon
$12,457,600
$19,448,817
$6,991,217
Athens, Georgia
4,562,586
6,056,076
1,493,490
Total
$17,020,186
$25,504,893
$8,484,707
Source: OIG analysis of EPA's Corvallis and Athens laboratory consolidation cost data.
(EPA OIG table)
EPA's Fiscal Years 2019 and 2018 Hazardous Waste Electronic Manifest System
Fund Financial Statements
Report No. 21-F-0045, issued January 5, 2021 Jft*;
Operating efficiently and effectively
> Fulfilling mandated reporting requirements
We rendered an unmodified opinion on the EPA's FYs 2019 and 2018 e-Manifest Fund
financial statements, meaning that the statements were fairly presented and free of
material misstatement. We did note three material weaknesses:
• The EPA made errors in its financial statement preparation process.
• The EPA improperly recorded accounts receivable and earned revenue.
• An EPA posting error creates the appearance of an Antideficiency Act violation.
The Agency agreed with our six recommendations.
Pod cast
v
Report Addresses: ^ EPA mission-related effort, s } OIG-identified management challenge for EPA. Mandatory reporting requirements.
20
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
EPA Needs to Substantially Improve Oversight of Its Military Leave Processes to
Prevent Improper Payments
Report No. 21-P-0042, issued December 28, 2020
Compliance with the law; Operating efficiently and effectively
{3} Complying with key internal control requirements (policies and procedures)
The EPA did not establish effective internal controls to
implement federal laws related to military leave and pay,
relying instead on its reservists, their supervisors, and its federal
payroll provider to comply with federal requirements. Based on
the transactions we reviewed for 48 EPA reservists, the Agency
had a 75-percent error rate related to military leave
requirements, resulting in about $129,000 in potential improper
payments. The Agency agreed with our nine recommendations. qig image
V
r ""5
,V
EPA's Fiscal Years 2020 and 2019 (Restated) Consolidated Financial Statement
Report No. 21-F-0014, issued November 16, 2020 jfr
Operating efficiently and effectively
> Fulfilling mandated reporting requirements
We rendered an unmodified opinion on the EPA's consolidated financial statements
for FYs 2020 and 2019 (restated), meaning they were fairly presented and free of
material misstatement. We did note two significant deficiencies:
• The EPA continues to make misstatements and adjustment errors during its
consolidated financial statement and component financial statement preparation
processes.
• The EPA improperly recorded adjustments totaling over $141 million of
unearned revenue.
The EPA agreed with our recommendations but disagreed with some of our statements
about the first significant deficiency listed above.
Evaluation of EPA's Compliance with the Executive Order 13950 on Combating
Race and Sex Stereotyping
Report No. 21-E-0044, issued December 29, 2020
Compliance with the law
The EPA was compliant with the applicable requirements of Executive Order 13950,
Combating Race and Sex Stereotyping.
Report Addresses: EPA mission-related effort, s } OIG-identified management challenge for EPA. Mandatory reporting requirements.
21
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Investigations
EPA Senior Officials Arranged for Post-Termination Payment for Two Former
EPA Employees, Committed Time-and-Attendance Misconduct
The EPA OIG received an allegation that the Agency continued paying a former EPA
employee after that individual's employment was terminated by the EPA. During the
investigation, we identified a second former EPA employee who also received pay after
that individual's employment was terminated by the EPA. We substantiated the allegation,
finding that two senior officials in the Office of the Administrator, one serving as a
noncareer member of the Senior Executive Service and one serving as a GS-15 of the
General Schedule, made material misrepresentations so that the EPA would continue
paying the former employees after their employment was terminated.
Based on additional information obtained during the investigation, we initiated a
subsequent investigation involving the senior GS-15 official. Specifically, we found that,
after being assigned to a new position and duty station, the senior GS-15 official engaged
in time-and-attendance misconduct. In addition, we found that, at the direction of the
senior SES official, the senior GS-15 official improperly received a four-step pay
increase, allowing the individual to keep the same salary despite being at a duty station
with a lower locality pay.
We referred these cases to various districts and divisions of the U.S. Department of
Justice on six different occasions, and the Department of Justice declined to prosecute
each time. We then submitted our investigative results to the Agency for consideration
and decision as to whether administrative action is warranted.
Date OIG referred
Date Department of Justice declined
Referrals based on improper post-termination pay investigation
2/14/19
2/14/19
3/22/19
3/22/19
4/11/19
6/6/19
8/19/19
9/25/19
Referrals based on time-and-attendance misconduct investigation
11/19/18
9/26/19
10/9/20
10/21/20
22
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Former Director Pleads Guilty to Embezzlement and Theft of EPA Funds
On October 30, 2020, a former executive director for the Kiowa, Comanche, and Apache
Intertribal Land Use Committee pleaded guilty in U.S. District Court, Western District of
Oklahoma, to one count of embezzlement and theft from an Indian tribal organization.
From November 2016 through August 2017, the individual converted and embezzled
tribal funds for personal benefit. Some of these funds involved EPA money—granted to
the Kiowa, Comanche, and Apache Intertribal Land Use Committee by the Oklahoma
Department of Environmental Quality—for Brownfield remediation and asbestos removal.
This investigation was conducted jointly with the Comanche Nation Police Department.
Former Director Pleads Guilty to Embezzlement of EPA Grant Funds
On December 10, 2020, a former interim executive director for the Hancock County
Planning Commission pleaded guilty in federal court to wire fraud and federal government
program theft. From June 2015 through April 2019, this individual embezzled more than
$250,000 from the Hancock County Planning Commission and another nonprofit
organization where the individual worked. The individual perpetrated the scheme by
fraudulently transferring funds from one organization to another and converting the funds
for personal use. During the relevant period, the Hancock County Planning Commission
received federal grant monies from both the EPA and the U.S. Department of Agriculture,
including a total of $400,000 in EPA grant funds to conduct inventory of, characterize, and
assess Brownfields sites in Hancock County, Maine.
This investigation was conducted jointly with the Ellsworth Police Department, the Federal
Bureau of Investigation, and the Department of Agriculture OIG.
Businessman Indicted for Submitting False Reports on EPA Research Grant
On December 3, 2020, a Lexington, Kentucky businessman was indicted in the
U.S. District Court, Eastern District of Kentucky, on 15 charges of conspiracy, wire
fraud, money laundering, and making false claims. From December 2017 through
May 2019, the individual allegedly submitted false reports to the EPA to justify payments
totaling $100,000 from an EPA research grant. Prior false submissions by the individual
to the U.S. Department of Energy resulted in a loss of federal research grant funding
totaling more than $1 million.
This investigation was conducted jointly with the Department of Energy OIG and the
U.S. Department of Defense OIG's Defense Criminal Investigative Service.
23
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Individuals Indicted for Unlawfully Enriching Themselves from EPA Contracts
On December 8, 2020, four individuals were indicted in the U.S. District Court, Southern
District of Florida, on one charge of conspiracy to commit mail and wire fraud,
five charges of wire fraud, and one charge of conspiracy to commit money laundering.
From about March 2015 to December 2015, the defendants allegedly conspired to
unlawfully enrich themselves by obtaining payments from construction companies—who
were the beneficiaries of federal government contracts, including from the EPA—in
exchange for issuing purportedly valuable surety bonds that were, in fact, secured by
worthless gold certificates.
This investigation was conducted jointly with the U.S. Department of Veterans Affairs
OIG; the U.S. Department of Transportation OIG; the U.S. Department of the Treasury,
Internal Revenue Service Criminal Investigation Division; and The Port Authority of New
York and New Jersey OIG.
Research Company Pleaded Guilty to Providing False Statements to EPA
On March 23, 2021, aNorth Carolina-based research company, Bio-Adhesive, pleaded
guilty to two counts of providing false statements to the EPA and the National Science
Foundation. Between 2013 and 2017, the company applied for and received Small
Business Innovation Research and Small Business Technology Transfer grant awards
from the EPA and the National Science Foundation totaling $1,375,000. Bio-Adhesive
submitted multiple proposals that contained misrepresentations regarding its eligibility to
seek Small Business Innovation Research and Small Business Technology Transfer grant
awards from the National Science Foundation and the EPA.
This investigation was conducted jointly with the National Science Foundation OIG.
Reports of Investigation—Employee integrity
A Report of Investigation documents the facts and findings of an OIG investigation and
generally involves an employee integrity matter. When the OIG's Office of Investigations
issues a Report of Investigation that has at least one "supported" allegation, it requests
that the entity receiving the report—whether it is an office within the EPA, the CSB, or
the OIG—provide a notification to the OIG within 60 days regarding the administrative
action taken or proposed to be taken in the matter. This section provides information on
how many Reports of Investigation with at least one supported allegation were issued to
the EPA, the CSB, or the OIG, as well as how many of those Reports of Investigation did
not receive a response within the 60-day period.
24
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
For the reporting period ending March 31, 2021, the Office of Investigations issued one
Report of Investigation and received no responses outside the 60-day window:
Agency and OIG Reports of Investigation
Reports of Investigation
with findings issued
10/1/21-3/31/21
Responses received/oendina after 60-dav response period
To EPA
To OIG
Received from
EPA*
Pending from
EPA, as of 3/31/21
Received from
OIG*
Pending from
OIG, as of 3/31/21
1
0
0
0
0
0
* The Agency or the OIG will or will not take an action or will conduct a supplemental investigation.
25
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Hotline Activities
Section 8M of the Inspector General Act of 1978, as amended, requires each OIG to
maintain a direct link on the homepage of its website for individuals to report fraud, waste,
and abuse. Individuals may also report complaints to the EPA OIG via telephone,
facsimile, email, and postal mail. We refer to these means of receiving information
collectively as the "OIG Hotline." The purpose of the hotline is to receive complaints of
fraud, waste, or abuse in EPA and CSB programs and operations, including
mismanagement or violations of law, rules, or regulations by Agency employees or
program participants. The hotline also encourages suggestions for assessing the efficiency
and effectiveness of Agency programs. Complaints and requests may be submitted by
anyone, including EPA and CSB employees, participants in EPA and CSB programs,
Congress, organizations, and the public. As a result of these contacts, the OIG may
conduct audits, evaluations, and investigations.
Reports Initiated via OIG Hotline
EPA Improperly Awarded and Managed Information Technology Contracts
Report No. 21-P-0094, issued March 10, 2021
£» Operating efficiently and effectively; Compliance with the law
{o} Complying with key internal control requirements (policies and procedures)
The EPA improperly provided government-issued equipment on a contract for CGI
Federal after stating during the solicitation process that equipment would not be
provided. The Agency spent $641,680 in federal funds to purchase equipment under an
expiring information technology
contract awarded to CGI Federal
and transferred the equipment to
one of two subsequent but related
contracts, also awarded to CGI
Federal. The EPA also issued
task orders under all three
contracts without proper
approvals, spending
$52.5 million in taxpayer funds.
The Agency agreed with our
ten recommendations.
$52.5M I S642K
Awarded without Equipment purchased
FITARA approval ' outside contract scope
¦¦¦¦¦¦ m J5L
fflSfJi
mill ^
The EPA spent $52.5 million in taxpayer dollars without
the proper approvals required under the Federal
Information Technology Acquisition Reform Act and
purchased $641,680 of equipment under an expiring
contract. (EPA OIG image)
Report Addresses: EPA mission-related effort, {o} OIG-identified management challenge for EPA. Mandatory reporting requirements.
26
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
EPA Needs to Improve Oversight of Invoice Reviews and Contractor
Performance Evaluation
Report No. 21-E-0031, issued December 1, 2020
Operating efficiently and effectively
{3} Complying with key internal control requirements (policies and procedures)
The EPA did not perform some required contract management duties for its contract with
Attain, an information technology support contractor, including an invoice review during
the task order's base year period and the contractor performance evaluation. The Agency
also lacked processes to inform
contract management when
these duties were not
completed. As a result,
incoming contracting officers
were unaware of critical tasks
that needed to be completed.
The Agency agreed with our
recommendations.
Improvements are needed in invoice reviews and
contractor performance evaluation. (EPA OIG graphic)
Hotline Statistics
The OIG Hotline is contacted with complaints of fraud, waste, abuse, mismanagement,
and misconduct in EPA and CSB programs and operations. The figures below detail the
number and type of contacts that the hotline received and referred for review by OIG
investigation, audit, and evaluation staff; EPA program offices; and other government
agencies during the first half of FY 2021. In this reporting period, of 1,267 contacts
received, the OIG made 214 referrals. A contact can be referred to more than one entity.
Hotline Contacts Received

10/1/20-
3/31/21
1 inn

1ZUU
1125
1094

1050
975
900
825
750 -
675
600
525
450
375
300
225
150
75
n

u
Emails
Telephone Calls
Hotline Contacts Referred
10/1/20-3/31/21
180
M

I 3? I , ,

Referrals to OIG offices Referrals to EPA Referrals to other federal,
program offices state, and local agencies
Report Addresses: EPA mission-related effort, {o} OIG-identified management challenge for EPA. Mandatory reporting requirements.
27
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Semiannual Report to Congress October 1, 2020-March 31, 2021
Categories of the 158 hotline contacts referred to OIG offices
0
2 4
6
S
S 10 12 14 16
Abuse of power

Bribery
¦
1

Bribery/gratuities - other
¦
1

Computer - intrusion

Computer - security

Computer crimes (ElectronicCrimes Division)
1 3

Computer fraud
¦
1

Conflict of interest
¦
1

Contract fraud

Contract improprieties - administration
1 2

Coronavirus pandemic

Employee - personnel action fraud
¦
1

Employee - travel/per diem fraud

Employee ethics

Employee misconduct
1 11

Environmental - Clean Air Act

Environmental - Resource Conservation Recovery Act
¦
1

Environmental - Safe Drinking Water Act

Environmental - Toxic Substances Control Act

Environmental - Water Pollution Control Act
1 3

Environmental (Criminal Investigation Division)

Environmental justice
¦
1

False claims

False statements

Falsifying official documents

Fraud
1 9

Grant fraud

Harassment

Impersonation

Lab fraud
¦
1

Misconduct - personnel

Programmatic and operational issues
1 3

Qui tam*

Scientific misconduct/integrity

Stolen credentials and/or government equipment
1 3

Threats and Workplace Violence

Unethical conduct
¦
1

* Iri a qui tam action, a private person brings legal action against an alleged wrongdoer on behalf of the federal government.
28
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Individuals who contact the hotline are not required to identify themselves and may
request confidentiality when submitting allegations. However, the OIG encourages those
who report allegations to identify themselves so that they can be contacted if the OIG has
additional questions. Pursuant to Section 7 of the Inspector General Act, the OIG will not
disclose the identity of an EPA or CSB employee who provides information unless that
employee consents or the inspector general determines that such disclosure is
unavoidable during the course of an investigation. As a matter of policy, the OIG will
provide comparable protection to employees of contractors, grantees, and others who
provide information to the OIG and request confidentiality. Pursuant to Section 8M of the
Inspector General Act, the OIG will also not disclose the identity of an individual who
provides information via the OIG's online complaint form unless that individual consents
or the inspector general determines that such disclosure is unavoidable during the course
of an investigation. Individuals concerned about confidentiality or anonymity with regard
to electronic communication may submit allegations by telephone or regular mail.
EPA OIG Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
Email: OIG Hotline@epa.gov
Phone: (888) 546-8740 or (202) 566-2476
Fax: (202)566-0814
Online: EPA OIG Hotline
Mail: EPA OIG Hotline
1200 Pennsylvania Avenue, NW
Mail Code 2431T
Washington, DC 20460
EPA Whistleblower Protection Coordinator
The EPA whistleblower protection coordinator can be reached at:
Phone: (202)566-1513 En
Email: whistleblower protection@.epa.qov
29
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
The CSB was created by the Clean Air Act
Amendments of 1990. The CSB's mission is to
investigate accidental chemical releases at facilities,
report the root causes to the public, and recommend
measures to prevent future occurrences. Since
FY 2004, Congress has designated the EPA inspector
general to serve as the inspector general for the CSB. As a result, the EPA OIG has the
responsibility to audit, evaluate, inspect, and investigate the CSB's programs and to
review proposed laws and regulations to determine their potential impact on the CSB's
programs and operations. Details on our work involving the CSB are available on this
OIG webpagc.
Audit of the U.S. Chemical Safety and Hazard Investigation Board's Fiscal
Years 2020 and 2019 Financial Statements
Report No. 21-F-0015, issued November 16, 2020 jfr
The OIG contractor that audited the CSB's financial statements for FYs 2020 and 2019
found the statements to be fairly presented and free of material misstatements. The
contractor did not identify any instances of noncompliance with applicable laws,
regulations, contracts, and grant agreements or any deficiencies in internal control over
financial reporting that would be considered material weaknesses.
U.S. Chemical Safety and Hazard Investigation Board's Compliance in Fiscal
Year 2020 with Improper Payments Legislation and Guidance
Report No. 21-E-0084, issued February 23, 2021 ^
The CSB was fully compliant with improper payments legislation and guidance during
FY 2020. Specifically, the CSB published its FY 2020 Performance and Accountability
Report on its website and conducted a risk assessment for programs with annual outlays
greater than $10 million. We issued no recommendations.
Evaluation of CSB's Compliance with Executive Order 13950 on Combating Race
and Sex Stereotyping
Report No. 21-E-0043, issued December 29, 2020
The CSB was compliant with the applicable requirements of Executive Order 13950,
Combating Race and Sex Stereotyping.
Report Addresses: Mandatory reporting requirements.
30
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
CSB's Information Security Program Is Mot Consistently Implemented;
Improvements Are Needed to Address Four Weaknesses
Report No. 21-E-0071, issued February 9, 2021
The CSB's information security program was assessed as "Level 2, Defined,which
means that its policies, procedures, and strategies are formalized and documented but not
consistently implemented. Specifically, the CSB:
• Lacked a governance structure to facilitate an organization wide risk-
management monitoring and reporting process.
• Did not have a documented process for remediating flaws.
• Lacked processes to provide privacy awareness training to all users and
specialized training for individuals who support information security- or
technology-related areas.
• Discontinued information recovery testing and off-site backup storage during the
coronavirus pandemic.
The CSB agreed with all five recommendations made to address these four weaknesses.
Needs Improvement
A
Risk
Management
e»\
Needs Improvement...
Contingency#
_, i Planning
Level 1: Ad hoc
Level 2: Defined
Level 3: Consistently Implemented
Level 4: Managed and Measurable
Level 5: Optimized
Needs Improvement
Security
Training

Needs Improvement.
Configuration
Management
The CSB's information security program is not yet consistently implemented. Improvements are
needed in risk management, configuration management, security training, and contingency
planning. (EPA OIG image)
Report Addresses: Mandatory reporting requirements.
31
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Other Activity
Legislation and Regulations Reviewed
Section 4(a) of the Inspector General Act requires the inspector general to review existing
and proposed legislation and regulations relating to the program and operation of the
EPA and to make recommendations concerning their impact. We also review drafts of
Office of Management and Budget circulars, memorandums, executive orders, program
operations manuals, directives, and reorganizations. The primary bases for our comments
are the audit, evaluation, investigation, and legislative experiences of the OIG, as well as
our participation on the Council of the Inspectors General on Integrity and Efficiency.
During the reporting period ending March 31, 2021, we reviewed two proposed changes
to legislation, regulations, policy, procedures, or other documents that could affect the
EPA or the inspector general, and we provided comments on neither.
32
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Other Results of OIG Work
Follow-Up Is an Important Aspect of OIG Efforts
It is important for the OIG to follow up on certain previously issued reports to ensure that
appropriate and effective corrective actions have been taken. The following reports issued
during the semiannual reporting period ending March 31, 2021, involved follow-up on
prior OIG reports.
Report number
Report title
Date issued
21-E-0071
CSB's Information Security Program Is Not Consistently Implemented;
Improvements Are Needed to Address Four Weaknesses
February 9,
2021
21-N-0052
Office of Research and Development Initiatives to Address Threats and
Risks to Public Health and the Environment from Plastic Pollution Within
the Waters of the United States
January 6,
2021
21-F-0045
EPA's Fiscal Years 2019 and 2018 Hazardous Waste Electronic Manifest
System Fund Financial Statements
January 5,
2021
21-P-0032
Region 2's Hurricanes Irma and Maria Response Efforts in Puerto Rico
and U.S. Virgin Islands Show the Need for Improved Planning,
Communications, and Assistance for Small Drinking Water Systems
December 3,
2020
21 -F-0015
Audit of the U.S. Chemical Safety and Hazard Investigation Board's Fiscal
Years 2020 and 2019 Financial Statements
November 16,
2020
21-F-0014
EPA's Fiscal Years 2020 and 2019 (Restated) Consolidated Financial
Statements
November 16,
2020
33
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Single Audit Reporting Efforts Make Impact
In accordance with the Single Audit Act of 1984 and Office of Management and Budget
guidance, nonfederal entities that expend more than $750,000 in federal funds are required to
have a comprehensive annual audit of their financial statements and comply with major
federal program requirements. The entities receiving the funds include states, local
governments, tribes, and nonprofit organizations. The Act provides that grantees are to be
subject to one annual comprehensive audit of all their federal programs versus a separate
audit of each federal program—hence the term "single audit." The single audits are
performed by private firms. Federal agencies rely upon the results of single audit reporting
when performing their grants management oversight of these entities.
The OIG provides an important service to the EPA by performing technical reviews of
single audit reports, on the basis of which the OIG issues memorandums for audit
resolution and corrective action. These memorandums recommend that EPA action
officials confirm corrective actions have been taken. If the corrective actions have not
been implemented, the EPA needs to obtain a corrective action plan, with milestone dates,
for addressing the findings in a single audit report. The following is a summary of single
audit reporting actions during the semiannual reporting period ending March 31, 2021.
Summary of single audit activity in the first half of FY 2021

October 1, 2020-
March 31, 2021
Number of single audit memorandums issued to EPA
101
Number of single audit findings reported to EPA
246
Questioned costs reported to EPA
$0
Number of quality reviews of single audit reports done by OIG
4
Deficiency letters issued to single auditors by OIG
4
Source: EPA OIG analysis. (EPA OIG table)
34
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Agency Best Practices
During this semiannual reporting period, OIG reports highlighted Agency best practices
that have potential value and applicability to other components in the EPA or elsewhere:
• Desk officers within the Office of Policy's Regulatory Management Division
noted that their director, after assuming the role in April 2019, developed useful
work aids, such as written procedures with screenshots and directions for
database tracking. Interviewees also lauded the Regulatory Steering Committee
for providing valuable cross-agency input and information on rulemakings and
the Regulatory Management Division's director for working through the
Regulatory Steering Committee to further improve the Action Development
Process. (Report No. 21-P-0115)
• When determining whether the CSB conducted improper payment risk
assessments for each program with annual outlays greater than $10,000,000, we
found that, although it was required to conduct only one such risk assessment in
three years, the CSB proactively conducted such an assessment annually. The
CSB determined that it did not meet the $10 million threshold for significant
improper payments reporting. The CSB additionally noted that recent audits and
reviews of CSB activities had not identified significant improper payment
concerns. (Report No. 21-E-0084)
35
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Scientific Integrity and Misconduct Issues
Scientific integrity at the EPA helps ensure that the development and use of science in the
Agency's decision-making is of the highest quality. Scientific integrity is crucial because
it helps to safeguard objective science that is free from bias, fabrication, falsification,
plagiarism, outside interference, and
suppression. The EPA issued its
Scientific Integrity Policy in
February 2012. The policy sets the
expectation that all EPA employees
will adhere to the terms of the policy,
including reporting policy breaches.
In addition, the EPA has a Scientific
Integrity Program, which consists of
the Agency's scientific integrity official, deputy scientific integrity officials from each of
the Agency's program and regional offices, and program staff that support implementing
the Scientific Integrity Policy.
As part of its mission to detect and deter waste, fraud, abuse, and mismanagement, the
EPA OIG conducts investigations related to "research misconduct" or "scientific
misconduct," including fabrication, falsification, or plagiarism. EPA Order 3120.5
contains the Agency's policy and procedures for addressing research misconduct,
including the duty of EPA employees to promptly report allegations of wrongdoing or
irregularities, such as those involving scientific misconduct, to the OIG. The OIG may
refer various scientific integrity allegations that it receives to the scientific integrity
official. With certain exceptions, the OIG has, through coordination procedures, delegated
the initial investigation of scientific misconduct allegations involving plagiarism to the
scientific integrity official. The scientific integrity official and OIG staff meet quarterly to
discuss the status of cases.
This section reports the status of scientific integrity allegations received by the scientific
integrity official and any scientific misconduct cases received by the OIG.
Scientific Integrity Allegations
The Scientific Integrity Program allegation process contains two paths: (1) advice and
assistance and (2) a procedure for reporting and adjudicating allegations. The purpose of
advice and assistance is to avert adjudicating allegations by addressing issues early with
minimal senior-level involvement. Someone with a scientific integrity concern can
receive advice from the Scientific Integrity Program to ascertain whether the issue
concerns scientific integrity and to address the issue before it rises to the level of an
"Science is the backbone of the EPA's decision-making.
The Agency's ability to pursue its mission to protect
human health and the environment depends upon the
integrity of the science on which it relies. The
environmental policies, decisions, guidance, and
regulations that impact the lives of all Americans every
day must be grounded, at a most fundamental level, in
sound, high quality science."
—EPA Scientific Integrity Policy. Section II
36
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
allegation. If an allegation is reported, the Scientific Integrity Program conducts an initial
screening to determine whether the allegation is covered under the policy. This initial
screening may then be followed by a preliminary inquiry to gather additional facts. If
needed, the scientific integrity official can convene a review panel with the deputy
scientific integrity officials to determine whether a violation has occurred and to
recommend corrective scientific actions and preventive measures.
Trends in Scientific Integrity Inquiries Received by the Scientific
Integrity Official
Scientific integrity inquiries by topic since Scientific Integrity Policy inception
Category
Total inquires received by the scientific integrity official
from FY 2012 (policy inception) through March 31, 2021
Percentage (number) of
formal allegations
Percentage (number) of
inquiries for advice
Authorship
15% (16)
9% (26)
Data quality
8% (8)
7% (19)
Delay/suppression
15% (16)
17% (48)
Interference
37% (39)
45% (126)
Plagiarism
2% (2)
2% (5)
Other
14% (15)
13% (36)
Not scientific integrity
9% (10)
7% (19)
TOTAL
106 allegations
279 inquiries
Source: EPA. (EPA OIG table)
Note: Percentages in this table were rounded.
Scientific integrity inquiries by topic during semiannual reporting period ending
March 31, 2021
Category
Received by the scientific integrity official during
semiannual reporting period ending March 31, 2021
Percentage (number) of
formal allegations
Percentage (number) of
inquiries for advice
Authorship
-
5% (2)
Data quality
-
2% (1)
Delay/suppression
-
5% (2)
Interference
71% (5)
52% (23)
Plagiarism
-
7% (3)
Other
29% (2)
25% (11)
Not scientific integrity
-
5% (2)
TOTAL
7 allegations
44 inquiries
Source: EPA. (EPA OIG table)
Note: Percentages in this table were rounded.
37
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Number of scientific integrity inquiries by fiscal year since policy inception
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
¦ Advice ¦ Allegation
Source: EPA. (EPA image)
Status of Scientific Integrity Inquiries Received by the Scientific
Integrity Official
For the semiannual reporting period ending March 31, 2021, the scientific integrity
official received seven new allegations and 44 new requests for advice. Also during this
semiannual reporting period, two allegations were closed or resolved, both of which were
received in this reporting period. The tables below summarize the status of these requests
for advice and allegations. Of the two allegations that were closed or resolved in this
reporting period, one was substantiated and one was referred to the OIG. There are
currently 22 open allegations, 17 from prior reporting periods and five from the current
reporting period. All but one of the 22 open allegations deal with high-profile issues or
senior officials, and one of these allegations was provided to the OIG. As recommended
in the OIG's May 2020 audit report, the Scientific Integrity Program is currently in the
process of developing procedures to address these types of allegations.
The Scientific Integrity Program publishes an annual report, which includes status
statistics and summarized resolution information. The latest annual report can be found
on the EPA's Scientific Integrity Program website.
Requests for advice or allegations received by the scientific integrity official are not
necessarily referred to the OIG. See the next section for information about the OIG's
actions on scientific misconduct allegations during this semiannual reporting period.
38
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Semiannual Report to Congress October 1, 2020-March 31, 2021
Status of allegations and requests for advice for semiannual period ending March 31, 2021
Al legations
Status
Number as of
March 31, 2021
Open/Active*
22
Closed - substantiated
1
Closed - not substantiated
0
Withdrawn
0
Transferred to OIG
1
Not scientific integrity
0
Requests for advice
Status
Number as of
March 31, 2021
Converted to allegation
0
Not scientific integrity
2
Advice provided
42
TOTAL
44
Source: OIG summary of EPA data. (EPA OIG tables)
* This number includes the total open/active allegations remaining from the current and previous reporting periods.
Scientific Misconduct Allegations Received by OIG
EPA policy states that each employee is responsible for promptly reporting allegations of
wrongdoing or irregularities, including those involving scientific misconduct, to the OIG.
In addition, coordination procedures between the scientific integrity official and the OIG
state that upon receipt of a research misconduct allegation, the scientific integrity official
will, within seven calendar days, refer the allegation to the OIG Hotline. Likewise, the
OIG is to forward, within seven calendar days, any allegation of research misconduct it
receives to the scientific integrity official. The offices will evaluate the allegations in
accordance with Section 7 of EPA Order 3120.5.
For the semiannual reporting period ending March 31, 2021, the OIG received zero
allegations involving potential scientific misconduct from Agency employees or the
scientific integrity official. The OIG has two open allegations involving potential
scientific misconduct that it is investigating.
The OIG had zero results of investigations that it conducted or oversaw to report to the
Agency for a determination of appropriate action. The OIG had zero results of
investigations that it conducted involving criminal misconduct to refer to the Department
of Justice, pursuant to the Inspector General Act of 1978, as amended.
39
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Semiannual Report to Congress
Statistical Data
Profile of Activities and Results
October 1, 2020-March 31, 2021
OIG audits and evaluations3
($ in millions)
October 1, 2020-
March 31, 2021
Questioned costs'1 $0,771
Potential monetary benefits0 $144,698
Audit and evaluation reports issued by OIGd 18
a Section 5(a)(22) requires detailed descriptions of the particular
circumstances of each inspection, evaluation, and audit conducted by
the OIG that was closed and not publicly disclosed. There were no
instances of inspections, evaluations, or audits that were closed and
not publicly disclosed during the semiannual period ending March 31,
2021. Investigations involving senior employees that were closed
during this semiannual reporting period are in Appendix 4.
b This measure includes single audits, which are audits of nonfederal
entities performed by private firms.
c This measure includes potential monetary benefits identified in
reports and monetary actions taken or resolved prior to report
issuance.
d This measure includes performance and financial audits conducted in
accordance with generally accepted government auditing standards,
as well as evaluations conducted in accordance with the Quality
Standards of Inspection and Evaluation. Appendix 1 lists all reports
issued.
Investigative operations

($ in millions)

October 1, 2020-March 31, 2021

EPA OIG

only
Joint*
Total
Total fines and recoveries
$0,000
$0,695
$0,695
Costs Agency avoided based on
$0,017
$0,000
$0,017
investigative results

Civil settlements
$0,000
$0,000
$0,000
Cases opened during period
40
13
53
Cases closed during period
55
26
81
Indictments/informations/complaints
0
9
9
Convictions
0
5
5
Civil judgments/settlements/filings
0
0
0
* With one or more federal agencies.
40
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Audit Report Resolution
Table 1: OIG-issued reports with questioned costs for semiannual period ending
March 31, 2021 ($ in thousands)
Report category
Number
of reports
Questioned
costs*
Unsupported
costs
A.
For which no management decision was made by
October 1, 2020**
16
$252
$21
B.
New reports issued during period
19
$771
$129
Subtotals (A + B)
35
$1,023
$150
C.
For which a management decision was made during
the reporting period:
26

(i) Dollar value of disallowed costs

$900
$150

(ii) Dollar value of costs not disallowed

$0
$0
D.
For which no management decision was made by
March 31, 2021***
9
$124
$0
* Questioned costs include unsupported costs.
** Any difference in the number of reports and the amounts of questioned costs between this report and our previous
semiannual report results from corrections made to data in our audit tracking system.
*** Due to rounding, this number may not appear to be the exact sum.
Table 2: OIG-issued reports with recommendations that funds be put to better use for
semiannual period ending March 31, 2021 ($ in thousands)
Report category
Number of
reports
Funds to put to
better use
A. For which no management decision was made by October 1, 2020*
16
$41,521
B. New reports issued during the reporting period
19
$145,461
Subtotals (A + B)
35
$186,982
C. For which a management decision was made during the reporting period:
26

(i) Dollar value of recommendations from reports that were
agreed to by management
9
$186,858
(ii) Dollar value of recommendations from reports that were
not agreed to by management
$0
D. For which no management decision was made by March 31, 2021
$124
* Any difference in the number of reports and the amounts of funds put to better use between this report and our previous
semiannual report results from corrections made to data in our audit tracking system.
41
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Summary of Investigative Results
Summary of investigative activity for semiannual period ending March 31, 2021
Cases open as of October 1, 2020
165
Cases opened during period
53
Cases closed during period
81
Cases open as of March 31, 2021
137

Complaints open as of October 1, 2020*
5
Complaints opened during period
27
Complaints closed during period
30
Complaints open as of March 31, 2021
2
* Adjusted from prior period.
Results of prosecutive actions

EPAOIG only
Joint*
Total
Criminal indictments/informations/complaints**
0
9
9
Convictions
0
5
5
C ivi I j u d g me nts/settle me nts/fi lings
0
0
0
Criminal fines and recoveries
$0
$695,387
$695,387
Civil recoveries
$0
$0
$0
Prison time
0 months
24 months
24 months
Prison time suspended
0 months
0 months
0 months
Home detention
0 months
0 months
0 months
Probation
0 months
60 months
60 months
Community service
0 hours
0 hours
0 hours
* With one or more federal agencies.
** Sealed indictments are not included in this category.
Administrative actions

EPA OIG only
Joint*
Total
Suspensions
1
2
3
Debarments
0
0
0
Other administrative actions
8
1
9
Total
9
3
12
Administrative recoveries
$0
$0
$0
Cost savings
$16,747
$0
$16,747
* With one or more federal agencies.
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Semiannual Report to Congress October 1, 2020-March 31, 2021
Summary of investigative reports issued and referrals for prosecution*
Number of investigative reports/referrals issued**
3
Number of persons referred to Department of Justice for criminal prosecution
16
Number of persons referred to state and local authorities for criminal prosecution
1
Number of criminal indictments and informations resulting from any prior referrals to
prosecutive authorities
6
* Investigative reports comprise final, interim, and supplemental Reports of Investigation, as well as Final Summary
Reports.
** This number may differ from the numbers reported in the Reports of Investigation section. In calculating the number of
referrals, corporate entities were counted as "persons."
Employee integrity cases*

Political
appointees
SES
GS-14/15
GS-13 and
below
Misc.
Total
Pending as of October 1, 2020
8
4
2
16
2
32
Opened*
2
0
2
4
6
14
Closed*
3
1
2
11
0
17
Pending as of March 31, 2021 **
10
2
3
9
9
33
* Employee integrity investigations involve allegations of criminal activity or serious misconduct by Agency employees that
could threaten the credibility of the Agency, the validity of executive decisions, the security of personnel or business
information entrusted to the Agency, or financial loss to the Agency (such as abuse of government bank cards or theft of
Agency funds). Allegations against former employees are included under "Misc."
** Pending numbers as of March 31, 2021, may not add up due to investigative developments resulting in subjects being
added or changed.
The chart below provides a breakdown by grade and number of employees who are the subject of
employee integrity investigations.
Employee integrity cases: Breakdown by grade and number of employees
43
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Appendices
Appendix 1—Reports Issued
Section 5(a)(6) of the Inspector General Act of 1978, as amended, requires a listing, subdivided according to subject matter, of each
report issued by the OIG during the reporting period. For each report, where applicable, the Inspector General Act also requires a listing
of the dollar value of questioned costs and the dollar value of recommendations that funds be put to better use.
Questioned costs Potential
Report

monetary
number
Report title
Date
Ineligible
Unsupported
Unreasonable
benefits
EVALUATIONS IN ACCORDANCE WITH

QUALITY STANDARDS FOR INSPECTION AND EVALUATION

21-E-0016
CSB Discontinued Information Recovery Testing and Off-Site Backup
11/18/20
$0.00
$0.00
$0.00
$0.00

Storage During the Coronavirus Pandemic

21-E-0030
EPA's Initial Plans for Returning to the Office Incorporate CDC
11/30/20
0.00
0.00
0.00
0.00

Guidance but Differ by Location

21-E-0031
EPA Needs to Improve Oversight of Invoice Reviews and Contractor
12/1/20
0.00
0.00
0.00
0.00

Performance Evaluation

21-E-0033
EPA Needs to Improve Its Planning and Management of Laboratory
12/7/20
0.00
0.00
0.00
0.00

Consolidation Efforts

21-E-0043
Evaluation of CSB's Compliance with Executive Order 13950 on
12/29/20
0.00
0.00
0.00
0.00

Combating Race and Sex Stereotyping

21-E-0044
Evaluation of EPA's Compliance with the Executive Order 13950 on
12/29/20
0.00
0.00
0.00
0.00

Combating Race and Sex Stereotyping

21-E-0071
CSB's Information Security Program Is Not Consistently Implemented;
2/9/21

Improvements Are Needed to Address Four Weaknesses

21-E-0072
EPA Is at Risk of Not Achieving Special Local Needs Program Goals
2/10/21

for Pesticides

21-E-0084
U.S. Chemical Safety and Hazard Investigation Board's Compliance in
2/23/21
0.00
0.00
0.00
0.00

Fiscal Year 2020 with Improper Payments Legislation and Guidance

SUBTOTAL=9

$0.00
$0.00
$0.00
$0.00
FINANCIAL AUDITS IN ACCORDANCE WITH

GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS

21 -F-0014
EPA's Fiscal Years 2020 and 2019 (Restated) Consolidated Financial
11/16/20
$0.00
$0.00
$0.00
$142,493,425.00

Statements

21-F-0015
Audit of the U.S. Chemical Safety and Hazard Investigation Board's
11/16/20
0.00
0.00
0.00
$0.00

Fiscal Years 2020 and 2019 Financial Statements

21-F-0045
EPA's Fiscal Years 2019 and 2018 Hazardous Waste Electronic
1/5/21
0.00
0.00
0.00
$1,017,000.00

Manifest System Fund Financial Statements

SUBTOTAL=3

$0.00
$0.00
$0.00
$143,510,425.00
PERFORMANCE AUDITS IN ACCORDANCE WITH

GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS

21-P-0032
Region 2's Hurricanes Irma and Maria Response Efforts in Puerto
12/3/20
$0.00
$0.00
$0.00
$0.00

Rico and U.S. Virgin Islands Show the Need for Improved Planning,

Communications, and Assistance for Small Drinking Water Systems

21-P-0042
EPA Needs to Substantially Improve Oversight of Its Military Leave
12/28/20
0.00
129,000.00
0.00
0.00

Processes to Prevent Improper Payments

21-P-0070
EPA Mostly Adheres to Regulations When Assessing Risks of New
2/8/21
0.00
0.00
0.00
0.00

Pesticides but Should Improve Internal Controls

21-P-0094
EPA Improperly Awarded and Managed Information Technology
3/10/21
0.00
0.00
641,680.00
$1,180,575.00

Contracts

44
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Report
number
Report title
Date
Questioned costs Potential
monetary
Ineligible Unsupported Unreasonable benefits
21-P-0114 EPA Does Not Consistently Monitor Hazardous Waste Units Closed 3/29/21
with Waste in Place or Track and Report on Facilities That Fall Under
the Two Responsible Programs
21-P-0115 EPA Does Not Always Adhere to Its Established Action Development 3/31/21
Process for Rulemaking
SUBTOTAL=6
0.00
0.00
0.00
0.00
0.00
0.00
$0.00 $129,000.00 $641,680.00
0.00
0.00
$1,180,575.00
PROJECTS NOT IN ACCORDANCE WITH
GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS
OR QUALITY STANDARDS FOR INSPECTION AND EVALUATION
21 -N-0052 Office of Research and Development Initiatives to Address Threats
and Risks to Public Health and the Environment from Plastic Pollution
Within the Waters of the United States
1/6/21
$0.00
$0.00
$0.00
$0.00
SUBTOTAL = 1
$0.00
$0.00
$0.00
$0.00
TOTAL REPORTS ISSUED = 19
$0.00 $129,000.00 $641,680.00 $144,691,000.00
45
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Appendix 2—Reports Issued Without Management Decisions
For Reporting Period Ending March 31, 2021
Section 5(a)(10)(A) of the Inspector General Act of 1978, as amended, requires a summary of each audit, inspection,
and evaluation report issued before the commencement of the reporting period for which no management decision
had been made by the end of the reporting period, an explanation of the reasons such management decision had not
been made, and a statement concerning the desired timetable for achieving a management decision on each such
report. Office of Management and Budget Circular A-50 requires resolution within six months of a final report being
issued. In this section, we report on audits and evaluations with no management decision or resolution within
six months of final report issuance. In the summaries below, we provide the resolution status of management
decisions not made as of March 31, 2021, which the OIG desires to resolve as soon as possible.
Section 5(a)(10)(B) of the Inspector General Act of 1978, as amended, requires a summary of each audit, inspection,
and evaluation report issued before the commencement of the reporting period for which no establishment comment
was returned within 60 days of providing the report to the establishment. The OIG interprets this provision to apply to
reports for which the end date of the 60-day agency comment period occurs during the semiannual period. There was
no report for which we did not receive a response within a 60-day period that ended during this semiannual period.
Office of Air and Radiation
Report No. 20-P-0047. EPA Failed to Develop Required Cost and Benefit Analyses and to Assess Air Quality
Impacts on Children's Health for Proposed Glider Repeal Rule Allowing Used Engines in Heavy-Duty Trucks,
December 5, 2019
Summary: The EPA did not comply with requirements of Executive Orders 12866 and 13045 when developing and
issuing the proposed Glider Repeal Rule. Additionally, the EPA did not follow its principal rulemaking guidance—the
Action Development Process—in developing the proposed Glider Repeal Rule, nor did it meet Federal Records Act
requirements. According to EPA managers and officials, the then-EPA administrator directed the Glider Repeal Rule
to be promulgated as quickly as possible. The proposed repeal rule would relieve industry of compliance requirements
of the Phase 2 rule, which set emissions standards and production limits for gliders beginning January 1, 2018.
EPA officials were aware that the available information indicated the proposed Glider Repeal Rule was "economically
significant;" however, the then-EPA administrator directed the Office of Air and Radiation to develop the proposed rule
without conducting the analyses required by the executive orders. The lack of analyses caused the public to not be
informed during the public comment period of the proposed rule's benefits, costs, potential alternatives, and impacts
on children's health. While the proposed Glider Repeal Rule was listed on the EPA's Fall 2019 Regulatory Agenda as
"economically significant," the rule was withdrawn from the Spring 2020 Regulatory Agenda.
We recommended that the Agency identify for the public the substantive change to the proposed rule made at the
suggestion or recommendation of the White House's Office of Information and Regulatory Affairs, conduct the
required analyses prior to finalizing the repeal, provide the public a means to comment on the analyses supporting
the rulemaking, and document the decisions made. The Agency provided sufficient planned corrective actions for two
recommendations, while one recommendation remains unresolved.
Resolution Status: Resolution efforts are in progress for the remaining unresolved recommendation.
Report No. 20-P-0236. EPA Needs to Improve Oversight of How States Implement Air Emissions Regulations
for Municipal Solid Waste Landfills, July 30, 2020
Summary: We identified 12 active municipal solid waste landfills in the two states we audited, Georgia and Texas,
that could be operating without the required Title V permits. The Georgia and Texas state agencies responsible for
issuing Title V permits to municipal solid waste landfills did not always obtain the data needed to verify whether the
landfills required a Title V permit and whether landfill emissions exceeded allowable levels. In four instances, the
regulatory requirements were misinterpreted.
The EPA did not identify deficiencies in how Georgia and Texas implemented Clean Air Act regulations to control air
emissions from municipal solid waste landfills. For example, to oversee state implementation of the 1996 regulations
to address emissions from existing municipal solid waste landfills, EPA Regions 4 and 6 should have—but did not—
verify whether Georgia and Texas submitted (1) complete state plans requesting approval to implement these
regulations and (2) the required annual progress reports. An EPA review of these documents is necessary to provide
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
assurance that states have an adequate plan for and are effectively implementing and enforcing municipal solid
waste landfill emissions regulations in accordance with federal requirements.
Without effective state implementation and EPA oversight of Clean Air Act regulations for municipal solid waste
landfills, these landfills could operate for years without required emissions controls. As a result, municipal solid waste
landfills could emit more air pollutants than allowed under a Title V permit, and state efforts to meet the EPA's air
quality standards for ozone and fine particulate matter could be hindered. The EPA revised its Clean Air Act
regulations for municipal solid waste landfills in 2016 and requested that states submit new plans for existing
municipal solid waste landfills. Implementation of the revised regulations provides the EPA with an opportunity to
verify that the new plans are complete, annual progress reports are submitted, and proper oversight is conducted.
We recommended that the regional administrators for Regions 4 and 6 require that Georgia and Texas determine
whether the municipal solid waste landfills identified in the report need to obtain Title V permits and install emissions
controls. We also recommended that the EPA develop guidance for Clean Air Act requirements for municipal solid
waste landfills that addresses the review and oversight of the Title V permitting process, the approval of state plans,
the review of annual progress reports, and the periodic review of implementation and enforcement. We consider four
of our seven recommendations resolved with corrective actions pending. Three recommendations made to the Office
of Air and Radiation are unresolved.
Resolution Status: The Office of Air and Radiation provided a response on September 28, 2020, including proposed
corrective actions. Based on the information and supporting documentation provided, the OIG determined that the
three recommendations remain unresolved. The OIG issued a memorandum on December 14, 2020, that explained
why the planned actions did not meet the intent of the recommendations. On January 21, 2021, the OIG met with the
Office of Air and Radiation to discuss the three unresolved recommendations. Resolution efforts are underway.
Office of General Counsel; Office of the Administrator
Report No. 20-E-0333. Improved EPA Oversight of Funding Recipients' Title VI Programs Could Prevent
Discrimination, September 28, 2020
Summary: The EPA's External Civil Rights Compliance Office, known as ECRCO, has not fully implemented an
oversight system to provide reasonable assurance that organizations receiving EPA funding are properly implementing
Title VI. As an initial matter, ECRCO does not conduct proactive compliance reviews to determine funding recipients'
compliance with Title VI. Instead, only once an investigation has been lodged will ECRCO review the foundational
elements of the recipient's nondiscrimination program using a checklist. This checklist documents the existence of a
nondiscrimination program but does not necessarily document the successful implementation of Title VI. We used the
checklist to conduct a limited review of the nondiscrimination programs in all 50 states and three territories. We found
that 81 percent lacked some of the required foundational elements on their websites. Meanwhile, ECRCO does not
systematically collect program data from EPA funding recipients, and state personnel told us they need training and
guidance to help them address discrimination complaints related to permits and cumulative impacts. Three of the
seven states we interviewed indicated that they had not received training from ECRCO.
Since ECRCO assumed management of the EPA's Title VI program in December 2016, it has focused its efforts on
reducing a significant backlog of discrimination complaints while simultaneously developing policy and guidance
documents. It resolved a backlog of 61 cases from FYs 2017 through 2019. Improved oversight could prevent future
case backlogs at the EPA and help assure funding recipients comply with Title VI.
To improve oversight of the Title VI program, we recommended that the Office of the Administrator develop a plan to
coordinate across Agency program offices to develop guidance on permitting and cumulative impacts. We also
recommended that ECRCO use systematic compliance reviews, develop performance measures to assess its
ongoing pilot program working with the states on foundational elements of nondiscrimination, address potential
noncompliance with funding applicants, develop guidance on the use of data collection, and outline a plan to ensure
that the staff take Title VI training. The Agency did not provide a formal response to our draft report. The EPA
provided a formal response to the final report on November 27, 2020, which is available on our website. All six
recommendations were unresolved when the subject report was issued. Recommendation 1 was issued to the
associate deputy administrator, and the remaining five recommendations were issued to the general counsel.
• For the five recommendations issued to the general counsel:
Resolution Status: The Office of General Counsel provided a response on November 27, 2020. Based on
the information and supporting documentation provided, the OIG determined that none of the five
recommendations issued to the general counsel are resolved. The OIG issued a memorandum on
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
February 9, 2021, that explained why the planned actions did not meet the intent of the recommendations.
The five recommendations issued to the Office of General Counsel remain unresolved.
• For the one recommendation issued to the associate deputy administrator:
Resolution Status: While the Office of General Counsel's November 27, 2020 response provided comments
regarding the recommendation issued to the associate deputy administrator, it did not resolve the
recommendation. Because the recommendation was issued to the associate deputy administrator, further
resolution efforts must be coordinated and communicated by the Office of the Administrator. We have not
received a response from the Office of the Administrator.
The inspector general sent a memorandum to the acting general counsel on February 9, 2021, stating that the
five recommendations issued to the Office of the General Counsel and the recommendation issued to the Office
of the Administrator were unresolved and that the Agency should follow the dispute process laid out in EPA
Manual 2750. The OIG was contacted by the deputy general counsel for Operations on February 16, 2021, about
delaying audit dispute resolution. The deputy inspector general responded in a memorandum on March 22,
2021, stating that the OIG will hold the audit dispute resolution in abeyance until April 16, 2021, to allow the
Agency time to revisit the recommendations. The deputy general counsel for Operations reached out again to the
OIG on March 31, 2021, to request additional time to develop a plan to address the OIG's recommendations.
The inspector general agreed to give the Agency additional time to address the report recommendations.
Office of Land and Emergency Management; Region 6 Regional Administrator
Report No. 20-P-0062. EPA Needs to Improve Its Emergency Planning to Better Address Air Quality Concerns
During Future Disasters, December 16, 2019
Summary: Most air toxic emission incidents during Hurricane Harvey occurred within a five-day period of the storm's
landfall. The majority of these emissions were due to industrial facilities shutting down and restarting operations in
response to the storm and storage tank failures. However, state, local, and EPA mobile air monitoring activities were
not initiated in time to assess the impact of these emissions. The air monitoring data collected did not indicate that the
levels of individual air toxics after Hurricane Harvey exceeded the health-based thresholds established by the State of
Texas and the EPA. However, these thresholds do not consider the cumulative impact of exposure to multiple air
pollutants at one time. Consequently, the thresholds may not be sufficiently protective of residents in communities
that neighbor industrial facilities and experience repeated or ongoing exposures to air toxics. We did not identify
instances of inaccurate communication from the EPA to the public regarding air quality after Hurricane Harvey.
However, public communication of air monitoring results was limited.
We recommended that the assistant administrator for Land and Emergency Management develop guidance for
emergency air monitoring in heavily industrialized areas, develop a plan to provide public access to air monitoring
data, and assess the availability and use of remote and portable monitoring methods. We also recommended that the
Region 6 regional administrator develop a plan to inform communities near industrial areas of adverse health risks
and to limit exposure to air toxics in these communities and conduct environmental justice training. We recommended
that the associate administrator for Public Affairs establish a process to communicate the resolution of public
concerns. Four recommendations, which we revised after we issued our draft report, remain unresolved.
• Three recommendations issued to the Office of Land and Emergency Management remain unresolved.
Resolution Status: The EPA provided a formal response on February 28, 2020. The response is under
review by the OIG. Resolution efforts are underway.
• The one recommendation issued to the Region 6 regional administrator remains unresolved.
Resolution Status: The EPA provided a formal response on February 28, 2020. On April 1, 2021, Region 6
provided a second response indicating that corrective actions have been implemented. Both responses are
currently under review by the OIG.
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Office of Mission Support
Report No. 20-P-0065. EPA Needs to Improve Management and Monitoring of Time-Off Awards,
December 30, 2019
Summary: The EPA successfully implemented interim policies and procedures for reviewing and approving monetary
awards that total more than $5,000 in a fiscal year for any one employee. However, the Agency does not follow
U.S. Office of Personnel Management guidance for valuing time-off awards. Specifically, the EPA does not assess a
value for time-off awards as part of its awards program. The Agency, therefore, cannot determine whether its time-off
awards are consistently assessed, approved at the appropriate level when combined with monetary awards, and
commensurate with employee achievements.
We also found that the Agency does not monitor time-off awards as a resource. From calendar years 2015 through
2017, the Agency awarded 355,511 hours—a total of over 170 full-time positions—in time-off awards. However, these
awards are not managed or monitored in regard to Agency productivity or workload management. A large number of
time-off hours awarded results in lost productivity, which can adversely impact the Agency's mission.
We recommended that the assistant administrator for Mission Support (1) revise EPA Manual 3130 A2, Recognition
Policy and Procedures Manual, to establish a methodology to determine the equivalent value of time-off awards;
(2) update its 2016 interim policy to include the combined value of all awards—both monetary and time-off—when
determining the appropriate level of review and approval, and incorporate this update into EPA Manual 3130 A2; and
(3) establish internal control procedures to monitor time-off awards as part of EPA resource management.
Resolution Status: The Agency provided a memorandum on August 7, 2020, which outlined the EPA's planned
corrective actions and estimated milestone dates for three recommendations. The OIG reviewed the Agency's
response and concluded that the planned actions did not meet the intent of the recommendations. The OIG issued a
memorandum on August 27, 2020, that explained why the planned actions did not meet the intent of the
recommendations. These recommendations remained unresolved. Subsequently, the Office of Mission Support
submitted this to the Office of the Chief Financial Officer for dispute resolution. The OIG is awaiting determination by
the Office of the Chief Financial Officer.
Office of the Chief Financial Officer; Office of Chief of Staff
Report No. 19-P-0155. Actions Needed to Strengthen Controls over the EPA Administrator's and Associated
Staff's Travel, May 16, 2019
Summary: The OIG identified 40 trips and $985,037 in costs associated with the then-administrator's travel for the
ten-month period from March 1, 2017, to December 31, 2017. This covered 34 completed and six canceled trips and
included costs incurred not only by the administrator but also by his Protective Service Detail and other staff. We
estimated excessive costs of $123,942 regarding use of first/business-class travel by the then-administrator and
accompanying Protective Service Detail agents; the exception that allowed for the travel accommodation was granted
without sufficient justification and, initially, without appropriate approval authority. Although the EPA's travel policy is
sufficiently designed to prevent fraud, waste, and abuse and is consistent with the Federal Travel Regulation, we
found that the policy did not initially outline who had the authority to approve the administrator's travel authorizations
and vouchers. This report made recommendations to two offices that remain unresolved:
• Of the ten recommendations issued to the Office of the Chief Financial Officer, eight were unresolved when
we issued our final report, and four remain unresolved.
Resolution Status: The Office of the Chief Financial Officer provided a response on March 31, 2020. The OIG
reviewed the Agency's proposed corrections and concluded that four of the recommendations are now
resolved. On June 29, 2020, the OIG issued a memorandum to the Agency advising it that the Office of the
Chief Financial Officer's planned corrective actions did not meet the intent of the remaining four
recommendations. The OIG met with the Office of the Chief Financial Officer on July 29, 2020, and
September 16, 2020, to discuss the unresolved recommendations. Resolution efforts are ongoing.
• The two recommendations issued to the Office of Chief of Staff in the Office of the Administrator remain
unresolved.
Resolution Status: The OIG's meeting with the Office of the Chief Financial Officer on June 29, 2020,
included staff from the Office of the Administrator and a discussion of the unresolved recommendations.
Resolution efforts are ongoing.
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Office of Water
Report No. 20-E-0246. EPA's 2018 BEACH Act Report to Congress Does Not Fully Meet Statutory
Requirements, August 13, 2020
Summary: In a January 2018 OIG report, we found that the EPA had not reported to Congress on progress related to
the Beaches Environmental Assessment and Coastal Health Act of 2000, referred to as the BEACH Act, as statutorily
required. We recommended that the EPA submit the mandated reports to Congress. As part of its corrective actions
in response to our January 2018 report recommendations, the EPA issued a BEACH Act report to Congress in
July 2018. However, during this follow-up evaluation, we found that the EPA's July 2018 report to Congress does not
fully meet the reporting requirements of the BEACH Act and the Plain Writing Act of 2010. The report also does not
adhere to federal internal control principles. Specifically:
• The report does not evaluate federal and local efforts to implement the BEACH Act.
• Although the report lists recommendations for additional water quality criteria and improved monitoring
methodologies, communication of these recommendations could be improved by using plain language
principles, which would help readers to more easily understand the recommendations.
• The report recommendations do not specify who needs to take action or what the barriers to
implementation are.
In addition, we concluded that the EPA's Office of Water staff did not reach out to congressional staff members to
inquire about what information Congress needs from the Agency to make informed decisions regarding the BEACH
Act program. By issuing a report that did not fully meet the requirements of the BEACH and Plain Writing Acts, the
EPA missed the opportunity to provide Congress with the information needed for effective decision-making.
We recommended that the assistant administrator for Water develop and adopt a written strategy to verify that future
BEACH Act reports to Congress fully meet the reporting requirements of the BEACH Act, expectations that federal
agencies comply with the Plain Writing Act, and federal internal control principles. We also recommended that the
EPA submit a report in 2022 that evaluates efforts to implement the BEACH Act. The Agency disagreed with our
recommendations and did not provide acceptable corrective actions and planned completion dates.
Resolution Status: The Office of Water provided a response on October 8, 2020, that communicated its disagreement
with the findings and recommendations. The Agency's response did not include proposed corrective actions. The
recommendations remain unresolved.
Total reports issued before reporting period for which no management decision had been made as of
March 31,2021 =7
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Appendix 3—Reports with Corrective Action Not Completed
In compliance with reporting requirements of Sections 5(a)(3) and 5(a)(10)(C) of the Inspector General Act of 1978,
as amended, we are to identify each significant recommendation described in previous semiannual reports on which
corrective action has not been completed, as well as a summary of each audit, inspection, and evaluation report for
which there are any outstanding unimplemented recommendations. We are also to identify the aggregate potential
monetary benefits of the unimplemented recommendations.
This appendix contains separate tables of unimplemented recommendations for the EPA and the CSB, which were
issued in 46 OIG audit reports from 2008 through March 31, 2021.
There is a total of 115 unimplemented recommendations for the EPA with total potential monetary benefits of
approximately $48.8 million, $0 of which was sustained and redeemed by the Agency. Use of "sustained" in this case
indicates agreement, in whole or in part, by the Agency to an OIG-identified monetary benefit. There is a total of two
unimplemented recommendations for the CSB, with total potential monetary benefits of $0.
Below is a list of the responsible EPA offices and regions responsible for the recommendations in the following
tables. While a recommendation may be listed as unimplemented, the Agency may be on track to complete
agreed-upon corrective actions by the planned due date.
Responsible EPA Offices:
AA Associate Administrator
ADA Associate Deputy Administrator (within the Office of the Administrator)
AO Office of the Administrator
DA Deputy Administrator (within the Office of the Administrator)
OAR Office of Air and Radiation
OCFO Office of the Chief Financial Officer
OCSPP Office of Chemical Safety and Pollution Prevention
OECA Office of Enforcement and Compliance Assurance
OGC Office of General Counsel
OITA Office of International and Tribal Affairs
OLEM Office of Land and Emergency Management
OMS1 Office of Mission Support
ORD Office of Research and Development
OW Office of Water
Region 1
Region 4
Region 6
Region 8
Region 9
Region 10
Science Advisor
1 Effective November 26, 2018, the former Office of Environmental Information and Office of Administration and
Resources Management were merged into the Office of Mission Support. In this appendix, any recommendations
originally issued to the former offices will be listed as under the purview of OMS.
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Semiannual Report to Congress October 1, 2020-March 31, 2021
EPA Reports with Unimplemented Recommendations
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date*
Revised
completion
date
Potential
monetary
benefits
(in $000s)
Category 1—Management and Operations
Regions 1 and 5 Need to Require Tribes
to Submit More Detailed Work Plans for
Grants
20-P-0335, September 29.2020
Region 1
2. For future grants, require the Passamaquoddy Tribe to submit
detailed work plans that include estimated funding amounts for
each work plan component.
2/28/21
5/31/21

EPA Has Sufficiently Managed
Emergency Responses During the
Pandemic but Needs to Procure More
Supplies and Clarify Guidance
20-E-0332, September 28.2020
OLEM
2. In coordination with all EPA regions, develop and implement
communication mechanisms to identify and clarify concerns that
on-scene coordinators have that are not addressed in the existing
guidelines, and make these communications available to all on-
scene coordinators.
3/31/21
6/30/21

3. In coordination with all EPA regions, ensure that guidance and
planning address deployment of on-scene coordinators in the event
of large incidents during pandemics, including overcoming travel
restrictions to respond to large incidents.
U
6/30/22

EPA Needs to Improve Processes for
Securing Region 8's Local Area Network
20-E-0309, September 10,2020
OMS
3. Develop and implement procedures to verify that the internet
protocol addresses being tested contain all the location's
networked equipment.
4/15/21

4. Identify deficiencies preventing the Office of Mission Support
vulnerability tests from producing complete results, and create
plans of action and milestones to correct identified deficiencies in
the Agency's vulnerability testing and reporting process.
10/31/21

OCFO
6. Coordinate with regions to implement internal controls to
determine whether personally identifiable information is protected
on regional Superfund Cost Recovery Package Imaging and Online
System servers.
10/30/20
4/30/21
$11,477
Management Alert: EPA Region 5 Needs
to Implement Effective Internal Controls to
Strengthen Its Records Management
Program
20-E-0295. Auaust 31. 2020
OMS
5. Update the Agency records management policy, procedures,
and guidance to include requirements for the program and regional
offices to report to the agency records officer the actual, suspected,
and accidental loss or destruction of records.
6/30/21

EPA Needs to Strengthen Controls Over
Required Documentation and Tracking of
Intergovernmental Personnel Act
Assignments
20-P-0245. Auaust 10. 2020
OMS
1. Evaluate the EPA's Intergovernmental Personnel Act Policy and
Procedures Manual (IPA), including the checklist, to determine
whether the required documents, the consequences for
noncompliance, the responsible offices, and the individual roles
and responsibilities remain relevant and appropriate, and update
the Manual accordingly.
10/15/21

2. Strengthen controls throughout the EPA's Intergovernmental
Personnel Act assignment process to verify that required
documents are properly submitted and maintained as required by
the EPA's Intergovernmental Personnel Act Policy and Procedures
Manual (IPA) and that the consequence for nonsubmittal of
required documents is enforced.
10/15/21

3. Strengthen controls over the tracking of EPA employees on
Intergovernmental Personnel Act assignments.
1/15/22

EPA Needs to Address Internal Control
Deficiencies in the Agencywide Quality
System
20-P-0200. June 22. 2020
OMS
1. Develop and implement a strategic plan and objectives for the
agencywide Quality System.
12/31/21

2. Develop and implement a standard operating procedure to
conduct annual reviews of program and regional quality systems.
6/30/22

3. Determine the skillsets needed to fulfill responsibilities for
developing and coordinating the agencywide Quality System.
12/31/21

4. Work with the Office of the Chief Financial Officer to conduct a
workload analysis for the agencywide Quality System.
12/31/21

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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date*
Revised
completion
date
Potential
monetary
benefits
(in $000s)

5. Conduct and document an internal control risk assessment on
the agencywide Quality System based on the Office of Mission
Support's strategic plan for the Quality System.
12/31/21

6. Develop and implement a plan and timeline to review and act on
all outdated quality policies, procedures, and guidance documents.
6/30/22

7. Develop and deploy agencywide training modules.
6/30/22

8. Develop and require training for new Quality System personnel.
1/15/20
12/31/21

11. Address the three unimplemented recommendations from the
2014 program evaluation by the outside contractor to work with
program partners to define the role of the Office of Mission Support
and clarity Quality System guidance, develop a comprehensive
staffing plan to address vacancies and skill gaps in the Quality
System, and rebrand the EPA's Quality System to increase support
from project personnel and senior managers.
12/31/21

12. Develop and implement a means to track Quality System
Assessments.
12/31/21

13. Complete Quality System Assessments for organizations that
are outside of the required three-year assessment time frame.
6/30/25

EPA Complied with Improper Payments
Legislation, but Internal Controls Need
Substantial Improvement to Ensure More
Accurate Reporting
20-P-0167, Mav 13, 2020
OCFO
1. Revisit the previous recommendation in EPA OIG Report No. 19-
P-0163, EPA Complied with Improper Payments Legislation but
Stronger Internal Controls Are Needed, to implement internal
controls for training reviewers and annually verifying that reviewers
are knowledgeable and proficient in the identification and reporting
of improper payments, and verify all corrective actions are
completed.
U
Date to be
determined,
pending
FY 2021
audit results

EPA May Have Overpaid for Its $13
Million Time and Attendance System by
Not Following Information Technology
Investment Requirements
20-P-0134, April 13, 2020
OCFO
1. Perform the required cost analysis over the full life cycle of
PeoplePlus. Also, determine whether the PeoplePlus operations
and maintenance contract should not be extended for any
remaining option years.
6/30/21

2. Perform an alternatives analysis to determine whether solutions
from the Department of Interior's Interior Business Center and
other federal shared service centers would be the best value option
to meet the time and attendance needs of the Agency and decide
whether the PeoplePlus operations and maintenance contract
should not be extended for any remaining option years.
6/30/21

$1,200

EPA Did Not Accurately Report Under the
Grants Oversight and New Efficiency Act
and Needs to Improve Timeliness of
Expired Grant Closeouts
20-P-0126, March 31,2020
OMS
1. Correct and resubmit the 2017 and 2018 Grants Oversight and
New Efficiency Act reporting to the Office of Management and
Budget.
12/31/20
6/30/21

2. Establish internal controls to verify that accurate information on
grant awards is submitted in future Annual Financial Reporting.
12/31/20
6/30/21

3. Implement controls as required by EPA Order 5700.6 A2 CHG 2,
Policy on Compliance, Review and Monitoring, to obtain closeout
strategies when Grants Management Offices are not meeting the
closeout metrics for grant awards.
U
6/30/21

4. Develop and implement Office of Grants and Debarment policy
specific to grant closeouts that have been delayed one year or
longer to escalate such instances to the Office of Grants and
Debarment for action in support of closeout efforts (regardless of
future collection of funds, audits, or reviews, as well as of property
management and disposition processes).
U
6/30/21
$8,282
53
-------
Semiannual Report to Congress
October 1, 2020-March 31, 2021
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date*
Revised
completion
date
Potential
monetary
benefits
(in $000s)
Management Controls Needed to Verify
and Report Border 2020 Program
Accomplishments
20-P-0083, February 18.2020
OITA
1. Establish and implement management controls to increase
reliability of the Border 2020: U.S.-Mexico Environmental Program
action plans by standardizing the action plan format to include key
data, such as the relevant goal, objective, subobjective, requests
for proposal, grant amount, and project status.
12/31/20
6/30/21

2. Establish and implement management controls to determine how
and when Policy Forums action plans will be developed.
12/31/20
6/30/21

3. Develop performance measures to track progress toward Border
2020: U.S.-Mexico Environmental Program goals and objectives.
10/1/20
6/30/21

4. Establish and implement management controls to increase
transparency of the Border 2020: U.S.-Mexico Environmental
Program by sharing the North American Development Bank
subgrantee fact sheets on the EPA's Border 2020 Program
website.
12/31/20
6/30/21

5. Establish and implement management controls to increase
transparency of the Border 2020: U.S.-Mexico Environmental
Program by providing stakeholder and public access, as
appropriate, to the program's funded products such as studies,
reports, and videos on the EPA's Border 2020 Program website.
12/31/20
6/30/21

EPA Needs to Improve Its Risk
Management and Incident Response
Information Security Functions
20-P-0120. March 24. 2020
OMS
1. Develop and maintain an up-to-date inventory of the software
and associated licenses used within the Agency.
10/15/21

2. Establish a control to validate that Agency personnel are
creating the required plans of action and milestones for
weaknesses that are identified from vulnerability testing but not
remediated within the Agency's established time frames per the
EPA's information security procedures.
12/31/21

EPA's Fiscal Years 2019 and 2018
(Restated) Consolidated Financial
Statements
20-F-0033, November 19.2019
OCFO
1. Evaluate and improve the EPA's process for preparing financial
statements.
7/31/20
9/30/21

3. Update the accounting models to properly record collections and
not reduce an account receivable account.
9/30/21

4. Establish accounting models to properly record e-Manifest
account receivables and recognize earned revenue at the
transaction level.
9/30/21

5. Establish accounting models to properly classify and record
interest, fines, penalties and fees.
9/30/21

6. Establish accounting models to properly record receivables,
collections and earned revenue from federal versus nonfederal
vendors.
9/30/21

Follow-Up Audit: EPA Took Steps to
Improve Records Management.
19-P-0283.Auaust27.2019
OGC
1. Issue an updated agency Freedom of Information Act policy and
procedure.
12/5/19
3/31/20

Pesticide Registration Fee, Vulnerability
Mitigation and Database Security Controls
for EPA's FIFRA and PRIA Systems Need
Improvement
19-P-0195, June 21. 2019
OCSPP
2. Complete the actions and milestones identified in the Office of
Pesticide Programs' PRIA Maintenance Fee Risk Assessment
document and associated plan regarding the fee payment and
refund posting processes.
12/31/20
5/31/22

54
-------
Semiannual Report to Congress
October 1, 2020-March 31, 2021
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date*
Revised
completion
date
Potential
monetary
benefits
(in $000s)
Self-Insurance for Companies with
Multiple Cleanup Liabilities Presents
Financial and Environmental Risks for
EPA and the Public
18-P-0059. December 22. 2017
OLEM
3. Update standard operating procedures and data systems to
accommodate the changes implemented for risk management
actions.
9/30/21

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

OECA
5. Develop or update existing standard operating procedures to
outline the Office of Land and Emergency Management and Office
of Enforcement and Compliance Assurance roles and
responsibilities for overseeing the validity of Resource
Conservation and Recovery Act and Superfund financial assurance
instruments, where needed.
6/30/20
9/30/21

6. Develop and include procedures for checking with other regions
for facilities/sites with multiple self-insured liabilities in the standard
operating procedures created for Recommendation 5.
6/30/20
9/30/21

7. Develop and include instructions on the steps to take when an
invalid financial assurance instrument (expired, insufficient in dollar
amount, or not provided) is identified in the standard operating
procedures created for Recommendation 5 and collect information
on the causes of invalid financial assurance.
6/30/20
9/30/21

8. Train staff on the procedures and instructions developed for
Recommendations 5 through 7.
9/30/20
9/30/21

Internal Controls Needed to Control Costs
of Emergency and Rapid Response
Services Contracts, as Exemplified in
Region 6
14-P-0109, February 4,2014
Region 6
3. Direct contracting officers to require that the contractor adjust all
its billings to reflect the application of the correct rate to team
subcontract other direct costs.
9/30/24

Category 2—Water Quality
EPA Must Improve Oversight of Notice to
the Public on Drinking Water Risks to
Better Protect Human Health
19-P-0318. September 25.2019
OW
5. Update and revise the 2010 Revised State Implementation
Guidance for the Public Notification Rule to include:
a. Public notice delivery methods that are consistent with
regulations.
b. Information on modern methods for delivery of public notice.
9/30/20
9/30/22

6. Update and revise the 2010 Public Notification Handbooks to
include:
a. Public notice delivery methods that are consistent with
regulations.
b. Information on modern methods for delivery of public notice.
c. Public notice requirements for the latest drinking water
regulations.
d. Procedures for public water systems to achieve compliance
after violating a public notice regulation.
e. Up-to-date references to compliance assistance tools.
f. Additional resources for providing public notice in languages
other than English.
9/30/20
9/30/22

OECA
7. Conduct a national review of the adequacy of primacy agency
implementation, compliance monitoring, reporting, and
enforcement of the Safe Drinking Water Act's public notice
requirements.
12/31/20
6/30/21

EPA Needs to Further Improve How It
Manages Its Oil Pollution Prevention
Program
12-P-0253, February 6,2012
OLEM
1. Improve oversight of facilities regulated by the EPA's oil pollution
prevention program by:
d. Producing a biennial public assessment of the quality and
consistency of Spill Prevention, Control, Countermeasure Plans,
and Facility Response Plans based on inspected facilities.
U
6/30/20
10/2/20
4/30/21

55
-------
Semiannual Report to Congress
October 1, 2020-March 31, 2021
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date*
Revised
completion
date
Potential
monetary
benefits
(in $000s)
EPA Should Revise Outdated or
Inconsistent EPA-State Clean Water
Memoranda of Agreement
10-P-0224, September 14.2010
OW
2-2. Develop a systematic approach to identify which states have
outdated or inconsistent memorandums of agreements; renegotiate
and update those Memorandums of Agreements using the
Memorandum of Agreements template; and secure the active
involvement and final, documented concurrence of headquarters to
ensure national consistency.
9/28/18
9/30/20
9/30/22

Category 3—Environmental Contamination and Cleanup
Management Alert: Unapproved Use
of Slag at Anaconda Co. Smelter
Superfund Site
20-N-0030. November 18.2019
Region 8
1. Notify any individuals or businesses known to be involved in the
collection or sale of the slag that those are not approved uses of
slag. The OIG recommends that Region 8 identify any other
federal, state, or local agencies with oversight on this matter and
notify those entities accordingly.
3/31/20

2. Determine how long and approximately how many souvenir bags
of slag have been sold and determine what should be done to
inform purchasers of the health risks that the slag souvenirs may
pose to them.
3/31/20

3. Create and distribute, both in hard copy and via the EPA's
website, a fact sheet for the public that describes the potential
hazards associated with souvenir bags of slag, noting any
precautions that are needed, especially for children; how to
properly dispose of the bags; and any other information necessary
to inform the public of any potential hazards from the possession,
use, handling, or storage of the bags of slag.
3/31/20

EPA Unable to Assess the Impact of
Hundreds of Unregulated Pollutants in
Land-Applied Biosolids on Human Health
and the Environment
19-P-0002. November 15.2018
OW
3. Complete development of the probabilistic risk assessment tool
and screening tool for biosolids land application scenarios.
12/31/21

4. Develop and implement a plan to obtain the additional data
needed to complete risk assessments and finalize safety
determinations on the 352 identified pollutants in biosolids and
promulgate regulations as needed.
12/31/22

6. Publish guidance on the methods for the biosolids pathogen
alternatives 3 and 4.
12/31/20
5/31/21

8. Issue updated and consistent guidance on biosolids fecal
coliform sampling practices.
12/31/20
5/31/21

EPA Needs to Finish Prioritization and
Resource Allocation Methodologies for
Abandoned Uranium Mine Sites on or
Near Navajo Lands
18-P-0233.Auaust22.2018
Regions 6
and 9
1. Complete the necessary removal site evaluations and
engineering evaluations/cost analyses.
12/31/20
12/31/21

2. Fully develop and implement prioritization and resource
allocation methodologies for the Tronox abandoned uranium mine
sites on or near Navajo Nation lands.
12/31/21
5/31/22

Improvements Needed in EPA Training
and Oversight for Risk Management
Program Inspections
13-P-0178. March 21. 2013
OLEM
7. Coordinate with the assistant administrator for Enforcement and
Compliance Assurance to revise inspection guidance to
recommend minimum inspection scope for the various types of
facilities covered under the program and provide detailed examples
of minimum reporting.
7/31/14
2/25/19
6/30/22

8. Coordinate with the assistant administrator for Enforcement and
Compliance Assurance to develop and implement an inspection
monitoring and oversight program to better manage and assess the
quality of program inspections, reports, supervisory oversight, and
compliance with inspection guidance.
9/30/14
2/28/20
6/30/23

Making Better Use of Stringfellow
Superfund Special Accounts
08-P-0196. Julv 9. 2008
Region 9
2. Reclassify or transfer to the Trust Fund, as appropriate,
$27.8 million (plus any earned interest less oversight costs) of the
Stringfellow special accounts in annual reviews, and at other
milestones including the end of fiscal year 2010, when the record of
decision is signed and the final settlement is achieved.
12/31/12
9/30/23
27,800

56
-------
Semiannual Report to Congress
October 1, 2020-March 31, 2021
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date*
Revised
completion
date
Potential
monetary
benefits
(in $000s)
Category 4—Toxics, Chemical Safety, and Pesticides
Data Used for Annual Toxics Release
Inventory National Analysis Are 99
Percent Complete, but EPA Could
Improve Certain Data Controls
20-P-0337. September 30.2020
OCSPP
3. In coordination with the assistant administrator for Water, revise
the Toxics Release Inventory reporting instructions by removing the
option for reporting facilities to not disclose the publicly owned
treatment works distribution percentages used in their reports.
4/30/21

4. In coordination with the assistant administrator for Water,
develop and implement procedures to:
a. Annually review Toxics Release Inventory reports where
publicly owned treatment works distribution percentages differ
from the default values, especially when publicly owned
treatment works distribution percentages do not align with other
facilities reporting transfers of the same chemical to the same
publicly owned treatment works, and require corrections as
appropriate.
b. Annually review whether default values for the publicly owned
treatment works distribution percentages need to be updated.
7/31/21

Lack of Planning Risks EPA's Ability to
Meet Toxic Substances Control Act
Deadlines
20-P-0247.Auaust 17.2020
OCSPP
1. Complete and publish the 2021 Annual Existing Chemical Risk
Evaluation Plan by the beginning of calendar year 2021 and
include the anticipated implementation efforts and financial and
staff resources to implement the actions detailed in the plan.
1/31/21

3. Specify what skill gaps must be filled to achieve the Toxic
Substances Control Act implementation capacity and how and
when those gaps will be filled in the fiscal year 2021 workforce plan
that the EPA agreed to develop in its corrective action plan to the
U.S. Office of Personnel Management.
3/31/21

EPA's Safer Choice Program Would
Benefit from Formal Goals and Additional
Oversight
20-P-0203. June 30. 2020
OCSPP
1. Develop goals and performance measures that capture the
impacts of the Safer Choice program.
U
1/31/22

Tribal Pesticide Enforcement Comes
Close to Achieving EPA Goals, but Circuit
Rider Inspector Guidance Needed
20-P-0012. October 29.2019
OECA
1. Require circuit riders to include the pesticide needs and risks of
each tribe on their circuit in the development of their priority-setting
plans, which are a required component of tribal pesticide
enforcement cooperative agreements.
12/31/22

2. Develop and implement tribal circuit rider guidance for pesticide
inspectors that includes expectation-setting and communication
with tribes that are being served under a tribal pesticide
enforcement cooperative agreement.
12/31/22

3. Develop and implement regional processes to receive feedback
directly from tribes using pesticide circuit riders.
12/31/22

EPA Not Effectively Implementing the
Lead-Based Paint Renovation, Repair and
Painting Rule
19-P-0302. September 9.2019
OECA
1. Identify the regulated universe of Lead-Based Paint Renovation,
Repair and Painting Rule firms in support of regional targeting
strategies, in coordination with the Office of Chemical Safety and
Pollution Prevention.
U
12/31/21

2. Establish Lead-Based Paint Renovation, Repair and Painting
Rule enforcement objectives, goals, and measurable outcomes.
U
7/1/21

EPA Needs to Determine Strategies and
Level of Support for Overseeing State
Managed Pollinator Protection Plans
19-P-0275.Auaust15.2019
OCSPP
5. Determine how the EPA can use the Managed Pollinator
Protection Plan survey results to advance its National Program
Manager Guidance goals and its regulatory mission.
6/30/21

EPA Needs to Evaluate the Impact of the
Revised Agricultural Worker Protection
Standard on Pesticide Exposure Incidents
18-P-0080. February 15.2018
OCSPP
1. In coordination with the Office of Enforcement and Compliance
Assurance, develop and implement a methodology to evaluate the
impact of the revised Agricultural Worker Protection Standard on
pesticide exposure incidents among target populations.
U
12/31/22

57
-------
Semiannual Report to Congress
October 1, 2020-March 31, 2021
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date*
Revised
completion
date
Potential
monetary
benefits
(in $000s)
Additional Measures Can Be Taken to
Prevent Deaths and Serious Injuries from
Residential Fumigations,
17-P-0053, December 12,2016
OCSPP
3. Conduct an assessment of clearance devices to validate their
effectiveness in detecting required clearance levels, as part of the
Office of Pesticide Programs ongoing reevaluation of structural
fumigants.
11/30/17
8/31/21

Category 5—Air Quality
EPA Needs to Improve Oversight of
How States Implement Air Emissions
Regulations for Municipal Solid Waste
Landfills
20-P-0236. Julv 30. 2020
Region 4
1. Require the Georgia Environmental Protection Division to
determine whether the municipal solid waste landfill identified by
the OIG as having a design capacity exceeding the Title V permit
regulatory capacity threshold should apply for a Title V permit and
install emissions controls. If a permit is required, verify with the
Georgia Environmental Protection Division whether the municipal
solid waste landfill applied for a permit.
9/30/20

2. Require the Texas Commission on Environmental Quality to
determine whether the 11 municipal solid waste landfills identified
by the OIG as having design capacities exceeding the Title V
permit regulatory capacity threshold should apply for a Title V
permit and install emissions controls. If permits are required, verify
with the Texas Commission on Environmental Quality whether the
municipal solid waste landfills applied for a permit.
12/31/20
12/31/21

3. Assist the State of Arkansas in developing and submitting a state
plan to implement the 2016 municipal solid waste landfill Emission
Guidelines. If Arkansas does not submit a state plan, implement
the federal plan for the 2016 municipal solid waste landfill Emission
Guidelines once the federal plan is effective.
6/30/22

7. Develop and implement a process to review implementation of
the 2016 municipal solid waste landfill Emission Guidelines and
New Source Performance Standards to provide assurance that
states are effectively implementing these regulations.
1/30/21

EPA's Processing Times for New Source
Air Permits in Indian Country Have
Improved, but Many Still Exceed
Regulatory Time Frames
OAR
2. Establish and implement an oversight process to verify that the
regions update the tribal-New-Source-Review permit tracking
system on a periodic basis with the correct and required
information.
3/31/22

20-P-0146.ADril22.2020

3. Develop and implement a strategy to improve the application
process and permitting timeliness for tribal-New-Source-Review
permits, taking into consideration the findings and
recommendations from the Lean event. The strategy should
include procedures to measure results.
6/30/22

4. Provide guidance to the regions on how to accurately determine
and document the application completion date that should be used
for tracking the tribal-New-Source-Review permitting process and
assessing timeliness.
9/30/21

5. Develop and implement a plan, in consultation with the Office of
Enforcement and Compliance Assurance and the EPA regions, to
periodically coordinate with tribes to identify facilities that are
operating in Indian Country without the required tribal-New-Source-
Review permit.
9/30/22

6. Develop and implement a plan, in consultation with the Office of
Enforcement and Compliance Assurance and the EPA regions, to
periodically conduct outreach to industry groups to educate them
on the tribal-New-Source-Review permit requirements for facilities
that are constructed or modified in Indian Country.
9/30/22

58
-------
Semiannual Report to Congress
October 1, 2020-March 31, 2021
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date*
Revised
completion
date
Potential
monetary
benefits
(in $000s)
Management Alert: Prompt Action Needed
to Inform Residents Living Near Ethylene
Oxide-Emitting Facilities About Health
Concerns and Actions to Address Those
Concerns
20-N-0128, March 31.2020
ADA
1. Improve and continue to implement ongoing risk communication
efforts by promptly providing residents in all communities near the
25 ethylene oxide-emitting facilities identified as high-priority by the
EPA with a forum for an interactive exchange of information with
the EPA or the states regarding health concerns related to
exposure to ethylene oxide.
U
3/31/21 **

EPA Needs to Improve Its Emergency
Planning to Better Address Air Quality
Concerns During Future Disasters
20-P-0062. December 16. 2019
AAof
Public
Affairs
5. Revise the EPA's Crisis Communication Plan to include a
communication process to inform affected communities about the
resolution of community concerns raised during an emergency.
12/30/20

EPA Failed to Develop Required Cost and
Benefit Analyses and to Assess Air
Quality Impacts on Children's Health for
Proposed Glider Repeal Rule Allowing
Used Engines in Heavy-Duty Trucks
20-P-0047, December 5. 2019
OAR
1. In consultation with the associate administrator for Policy, for the
proposed Glider Repeal Rule, per identify for the public (e.g., via
the public substantive change of economic significance submitted
to the Office of Information and review and the action subsequently
whether that change was made at the recommendation of the
Office of Affairs.
12/31/19
3/31/21

More Effective EPA Oversight Is Needed
for Particulate Matter Emissions
Compliance Testing
19-P-0251, Julv 30, 2019
OECA
1. Develop and implement a plan for improving the consistency of
stack test reviews across EPA regions and delegated agencies.
3/31/22

OAR
2. Assess the training needs of EPA regions and state, local, and
tribal agencies concerning stack test plans and report reviews and
EPA test methods and develop and publish a plan to address any
training shortfalls.
3/31/22

3. Develop stack test report checklists for EPA Method 5 and other
frequently used EPA methods to assist state, local, and tribal
agencies in their review of stack test plans and reports.
6/30/21

Region 10
5. Develop a communication plan to make all state and local
agencies within Region 10 aware of EPA requirements and
guidance for conducting stack testing oversight.
5/31/22

6. Develop and implement controls to assess delegated agencies'
stack testing oversight activities.
3/31/22
12/21/22

EPA Effectively Screens Air Emissions
Data from Continuous Monitoring Systems
but Could Enhance Verification of System
Performance
19-P-0207. June 27.2019
OAR
1. Develop and implement electronic checks in the EPA's
Emissions Collection and Monitoring Plan System or through an
alternative mechanism to retroactively evaluate emissions and
quality assurance data in instances where monitoring plan changes
are submitted after the emissions and quality assurance data have
already been accepted by the EPA.
3/31/25

EPA Demonstrates Effective Controls for
Its On-Road Heavy-Duty Vehicle
Compliance Program; Further
Improvements Could Be Made
19-P-0168. June 3. 2019
OAR
1. Define performance measures to assess the performance of the
EPA's on-road heavy-duty vehicle and engine compliance program.
9/30/22

2. Conduct and document a risk assessment for the on-road heavy-
duty vehicle and engine compliance program that prioritizes risk
and links specific control activities to specific risks. Update the risk
assessment on a scheduled and periodic basis.
6/30/21

3. Address the following risks as part of the on-road heavy-duty
vehicle and engine compliance program risk assessment, in
addition to other risks that the EPA identifies:
a. Non-criteria pollutants not being measured.
b. Level of heavy-duty sector testing throughout the compliance
life cycle.
c. Marketplace ambiguity over regulatory treatment of rebuilt
versus remanufactured engines.
d. Different compliance challenges for heavy-duty compression-
ignition and spark-ignition engines.
e. Lack of laboratory test cell and in-house testing capacity for
heavy-duty spark-ignition engines.
9/30/21

59
-------
Semiannual Report to Congress
October 1, 2020-March 31, 2021
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date*
Revised
completion
date
Potential
monetary
benefits
(in $000s)

4. Evaluate the following issues, which may require regulatory or
programmatic action, as part of (1) the on-road heavy-duty vehicle
and engine emission control program risk assessment and (2) the
EPA's annual regulatory agenda development process:
a. Regulatory definition of on-road heavy-duty engine useful life
may not reflect actual useful life.
b. Not-to-Exceed standard may not reflect real-world operating
conditions, especially for certain applications.
c. In-use testing requirements for heavy-duty spark-ignition
engines may be needed.
d. A particle number standard may more accurately control
particulate matter emissions that impact human health.
9/30/22

EPA Did Not Identify Volkswagen
Emissions Cheating; Enhanced Controls
Now Provide Reasonable Assurance of
Fraud Detection
18-P-0181. Mav 15. 2018
OAR
1. Define performance measures to assess the performance of the
EPA's light-duty vehicle compliance program.
3/31/21

EPA Has Not Met Certain Statutory
Requirements to Identify Environmental
Impacts of Renewable Fuel Standard
16-P-0275.Auaust18.2016
OAR
2. Complete the anti-backsliding study on the air quality impacts of
the Renewable Fuel Standard as required by the Energy
Independence and Security Act.
9/30/24

3. Determine whether additional action is needed to mitigate any
adverse air quality impacts of the Renewable Fuel Standard as
required by the Energy Independence and Security Act.
9/30/24

Category 6—Research and Lai
boratories
Further Efforts Needed to Uphold
Scientific Integrity Policy at EPA
20-P-0173. Mav 20. 2020
AO
1. Determine the extent and cause of the concerns related to
culture and "tone at the top," based on the indicators from the
OIG's scientific integrity survey. Issue the results to all EPA staff
and make available to the public, including planned actions to
address the causes
9/30/20

ORD /
Science
Advisor
2. With the assistance of the Scientific Integrity Committee, develop
and identify which performance measures will be used to define
Scientific Integrity Program success and effective Scientific
Integrity Policy implementation.
12/30/21

3. With the assistance of the Scientific Integrity Committee, develop
and execute a plan, including resource needs and milestones, to
address the remaining action items identified by the Agency to
improve the implementation of its Scientific Integrity Policy.
1/30/21

6. In coordination with the assistant administrator for Mission
Support, complete the development and implementation of the
electronic clearance system for scientific products across the
Agency.
6/30/22

7. With the assistance of the Scientific Integrity Committee, finalize
and release the procedures for addressing and resolving
allegations of a violation of the Scientific Integrity Policy, and
incorporate the procedures into scientific integrity outreach and
training materials.
9/30/20

8. With the assistance of the Scientific Integrity Committee, develop
and implement a process specifically to address and resolve
allegations of Scientific Integrity Policy violations involving high
profile issues or senior officials, and specify when this process
should be used.
6/30/21

60
-------
Semiannual Report to Congress
October 1, 2020-March 31, 2021
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date*
Revised
completion
date
Potential
monetary
benefits
(in $000s)

10. With the assistance of the Scientific Integrity Committee,
summarize allegations of scientific integrity violations in the
Scientific Integrity Program's annual reports, as applicable and
subject to the applicable privacy protections, including:
a. Adjudication outcome.
b. Description of the process used to reach the adjudication
outcome.
c. Description of corrective actions and any longer-term changes
or consequences to address the cause of substantiated
violations.
d. Whether and how the allegation was resolved through the
advice/assistance process.
12/30/20

11. With the assistance of the Scientific Integrity Committee,
finalize and post to the EPA's public website prior-year annual
reports on scientific integrity.
7/31/20

EPA Needs a Comprehensive Vision and
Strategy for Citizen Science that Aligns
with Its Strategic Objectives on Public
Participation
18-P-0240. September 5.2018
DA
1. Establish a strategic vision and objectives for managing the use
of citizen science that identifies:
a. Linkage to the agency's strategic goals.
b. Roles and responsibilities for implementation.
c. Resources to maintain and build upon existing Agency
expertise.
12/31/20

2. Through appropriate EPA offices, direct completion of an
assessment to identify the data management requirements for
using citizen science data and an action plan for addressing those
requirements, including those on sharing and using data, data
format/standards, and data testing/validation.
12/31/20

ORD
4. Build capacity for managing the use of citizen science, and
expand awareness of citizen science resources, by:
a. Finalizing the checklist on administrative and legal factors for
Agency staff to consider when developing citizen science
projects, as well as identifying and developing any procedures
needed to ensure compliance with steps in the checklist.
b. Conducting training and/or marketing on the EPA's citizen
science intranet site for program and regional staff in developing
projects.
c. Finalizing and distributing materials highlighting project
successes and how the EPA has used results of its investment in
citizen science.
12/31/20

Total
$48,759
* U—Unresolved when the report was issued and resolved at a later date.
** The EPA and the OIG were unable to reach agreement on the corrective actions for this recommendation. On January 4, 2021, as part of the audit resolution process, the EPA
administrator concurred with the OAR's position that the recommendation should be closed. However, we continue to work with the Agency to reach agreement, and we will therefore
continue to report this recommendation as unimplemented.
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
CSB Reports with Unimplemented Recommendations
Report title, number, and date
Office
Unimplemented recommendation
Planned
completion
date
Revised
completion
date
Potential
monetary
benefits
(in $000s)
Category 1—Management ana
Operations
CSB Still Needs to Improve Its
'Incident Response' and 'Identity
and Access Management'
Information Security Functions
19-P-0147.Mav9.2019
CSB
1. Implement use of Homeland Security Presidential Directive-12,
regarding Personal Identity Verification card technology for physical and
logical access, as required. If unable to implement this card technology,
obtain a waiver from the Office of Management and Budget not to operate
as required by the National Institute of Standards and Technology.
10/28/19
3/31/20
12/30/20

CSB's Information Security
Program Is Defined, but
Improvements Needed in Risk
Management, Identity and
Access Management, and
Incident Response
20-P-0077. February 12. 2020
CSB
1. Define and document risk management procedures for identifying,
assessing, and managing information technology supply chain risk.
4/30/20
6/30/21

Total
$0
62
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Appendix 4—Closed Investigations Involving Senior Employees
For Reporting Period Ending March 31,2021
Section 5(a)(19) of the Inspector General Act of 1978, as amended, requires a report on each investigation involving a
senior government employee where allegations of misconduct were substantiated. Section 5(a)(22) of the Inspector
General Act requires a detailed description of the particular circumstances of any investigation conducted by the OIG
involving a senior government employee that is closed and was not disclosed to the public. Details on each investigation
conducted by the OIG involving senior employees closed during the semiannual reporting period ending March 31, 2021,
are provided below.
CASE NUMBER: OI-HQ-2020-ADM-0Q26
An EPA SES employee allegedly deleted email records and directed other EPA employees to also delete email records in
violation of 18 U.S.C. § 2071. The SES employee is no longer employed at the EPA, and the investigation was inconclusive
as to whether the emails deleted by the SES employee were official records. The allegation that the SES employee directed
other employees to delete email records was not supported.
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Appendix 5—Peer Reviews Conducted
For Reporting Period Ending March 31,2021
Section 5(a)(14) of the Inspector General Act of 1978, as amended, requires an appendix containing the results of any peer
review conducted of the EPA OIG by another OIG during the reporting period or, if no such peer review was conducted, a
statement identifying the date of the last peer review conducted of the EPA OIG by another OIG. Section 5(a)(15) of the
Inspector General Act requires a list of any outstanding recommendations from any peer review conducted of the EPA OIG
by another OIG that have not been fully implemented. Section 5(a)(16) of the Inspector General Act requires a list of all peer
reviews conducted by the EPA OIG of another OIG during the reporting period, including a list of any recommendations from
any previous peer review that remain outstanding.
The EPA OIG did not conduct any peer reviews of other OIGs during the semiannual reporting period. The following are the
most recent peer reviews conducted by another OIG of the EPA OIG. There are no outstanding recommendations from
these peer reviews.
Audits
As of March 31, 2021, the Treasury Inspector General for Tax Administration OIG was conducting an external peer
review of the EPA OIG audit organization, which includes the EPA OIG's Office of Audit and Office of Evaluation,
for the fiscal year period ending September 30, 2020. The review was being conducted in accordance with
generally accepted government auditing standards and the Council of the Inspectors General on Integrity and
Efficiency's Guide for Conducting Peer Reviews of the Audit Organizations of Federal Offices of Inspector General.
The peer review team submitted the formal draft of the System Peer Review Report to the EPA OIG on March 15,
2021. The EPA OIG received an External Peer Review rating of pass. The final report issuance of the System Peer
Review Report is estimated for mid-April 2021.
The most recent peer review report on the EPA OIG was issued on June 18, 2018, by the Department of Defense
OIG. That review, covering the three-year period ending September 30, 2017, found that the EPA OIG's system of
quality control was suitably designed and complied with to provide the EPA OIG with reasonable assurance of
performing and reporting in conformity with applicable professional standards in all material respects. The EPA OIG
received an external peer review rating of pass.
The EPA OIG has initiated an external peer review of the audit organization of the Department of Agriculture OIG.
Our review covers the period from April 1, 2020, through March 31, 2021. This review is being conducted in
accordance with generally accepted government auditing standards and guidelines established by the Council of
the Inspectors General on Integrity and Efficiency.
Investigations
The General Services Administration OIG completed the most recently mandated Council of the Inspectors General
on Integrity and Efficiency quality assurance review of the EPA OIG Office of Investigations and issued its report on
June 11, 2018. The General Services Administration identified no deficiencies and found internal safeguards and
management procedures compliant with quality standards.
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Semiannual Report to Congress
October 1, 2020-March 31, 2021
Appendix 6—OIG Mailing Addresses and Telephone Numbers
Headquarters
U.S. Environmental Protection Agency
Office of Inspector General
1200 Pennsylvania Ave., NW(2410T)
Washington, D.C. 20460
(202) 566-0847
Atlanta
U.S. Environmental Protection Agency
Office of Inspector General
61 Forsyth Street, SW
Atlanta, GA 30303
Audit/Evaluation: (404) 562-9830
Investigations: (404) 562-9857
Boston
U.S. Environmental Protection Agency
Office of Inspector General
5 Post Office Square (Mail Code: 15-1)
Boston, MA 02109-3912
Audit/Evaluation: (617) 918-1475
Investigations: (617) 918-1466
Chicago
U.S. Environmental Protection Agency
Office of Inspector General
77 West Jackson Boulevard
13th Floor (IA-13J)
Chicago, IL 60604
Audit/Evaluation: (312) 353-2486
Investigations: (312) 886-7167
Cincinnati
U.S. Environmental Protection Agency
Office of Inspector General
26 West Martin Luther King Drive
Cincinnati, OH 45268-7001
Audit/Evaluation: (513) 487-2363
Investigations: (917) 717-1923
Offices
Dallas
U.S. Environmental Protection Agency
Office of Inspector General Suite 500
1201 Elm Street
Dallas, TX 75270
Audit/Evaluation: (214) 665-6735
Investigations: (214) 665-2249
Denver
U.S. Environmental Protection Agency
Office of Inspector General
1595 Wynkoop Street, 4th Floor
Denver, CO 80202
Audit/Evaluation: (303) 312-6969
Investigations: (303) 312-6868
Kansas City
U.S. Environmental Protection Agency
Office of Inspector General
11201 Renner Boulevard
Lenexa, KS 66219
Audit/Evaluation: (913) 551-7878
Investigations: (913) 551-7420
New York
U.S. Environmental Protection Agency
Office of Inspector General
290 Broadway, Suite 1520
New York, NY 10007
Audit/Evaluation: (212) 637-3049
Investigations: (212) 637-3040
Philadelphia
U.S. Environmental Protection Agency
Office of Inspector General
1650 Arch Street, 3rd Floor
Philadelphia, PA 19103-2029
Audit/Evaluation: (215) 814-2326
Investigations: (215) 814-2470
Research Triangle Park
U.S. Environmental Protection Agency
Office of Inspector General
Mail Drop N283-01
Research Triangle Park, NC 27711
Audit/Evaluation: (919) 541-1030
Investigations: (919) 541-3668
San Francisco
U.S. Environmental Protection Agency
Office of Inspector General
75 Hawthorne Street (IGA-1-2)
8th Floor
San Francisco, CA 94105
Audit/Evaluation: (415) 947-4527
Investigations: (415) 947-4506
Seattle
U.S. Environmental Protection Agency
Office of Inspector General
Mail Code 17-H13
1200 Sixth Avenue, Suite 155
Seattle, WA 98101-3140
Audit/Evaluation: (206) 553-2999
Investigations: (206) 553-6116
The EPA OIG is unable to receive regular mail or faxes because of mandatory telework during the coronavirus pandemic. We are still able to
receive and respond to phone calls.
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