Semiannual Report to Congress, October 1, 2021


Semiannual
Report to Congress

October 1, 2021-March 31, 2022

OFFICE OF
INSPECTOR
GENERAL

U.S. ENVIRONMENTAL
PROTECTION AGENCY

I

E PA-350-R-22-001
May 2022

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Index of Reporting Requirements

Inspector General Act of 1978, as amended

Requirement

Subject

Addressed in

Section 4(a)(2)

Recommendations concerning impact of existing and proposed legislation and regulations

Section 1.7

Section 5(a)(1)

Significant problems, abuses, and deficiencies relating to programs and operations

Section 2.1

Section 5(a)(2)

Significant recommendations for corrective action relating to programs and operations

Section 2.1

Section 5(a)(3)

Reports with corrective action not completed

Appendix 3

Section 5(a)(4)

Matters referred to prosecutive authorities and resulting prosecutions and convictions

Sections 2.1, 2.2, and 3.2;
Appendix 4

Section 5(a)(5)

Instances where information or assistance was refused or not provided

Section 2.3

Section 5(a)(6)

List of audit, inspection, and evaluation reports issued

Appendix 1

Section 5(a)(7)

Summaries of significant reports

Section 2.1

Section 5(a)(8)

Audit, inspection, and evaluation reports—questioned costs

Section 3.1

Section 5(a)(9)

Audit, inspection, and evaluation reports—funds to be put to better use

Section 3.1

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

Appendixes 2 and 3

Section 5(a) (11)

Significant revised management decisions

n/a

Section 5(a) (12)

Significant management decisions with which OIG disagreed

Appendix 2

Section 5(a) (14-16)

Peer reviews conducted

Appendix 5

Section 5(a)(17—18)

Statistics on investigative reports, referrals, prosecutions, and indictments

Section 3.2

Section 5(a) (19)

Substantiated investigations involving senior government employees

Appendix 4

Section 5(a) (20)

Instances of whistleblower retaliation

Section 2.3

Section 5(a) (21)

Any establishment attempts to interfere with independence

Section 2.3

Section 5(a) (22)

Closed audits, inspections, evaluations, and investigations not disclosed to public

Appendix 4

Abbreviations

CSB
EPA
FY
OIG
PFAS
SES

u.s.c

U.S. Chemical Safety and Hazard Investigation Board
U.S. Environmental Protection Agency
Fiscal Year

Office of Inspector General
Perfluoroalkyl and Polyfluoroalkyl Substances
Senior Executive Service
United States Code

Are you aware of fraud, waste, or abuse in an
EPA or CSB program?

EPA Inspector General Hotline

1200 Pennsylvania Avenue, NW(2431T)
Washington, D.C. 20460
(888) 546-8740
(202) 566-2599 (fax)

OIG Hotline@epa.gov

Learn more about our OIG Hotline.

EPA Office of Inspector General

1200 Pennsylvania Avenue, NW (2410T)
Washington, D.C. 20460
(202) 566-2391
www.epa.gov/oiq

Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions

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Message to Congress

As we are halfway through fiscal year 2022, this semiannual report is an opportunity to
review what we have achieved so far; focus on our goals for the second part of the year;
and ensure 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 both the EPA and the CSB, I am pleased that we have
had many successes so far in FY 2022, which are highlighted throughout this report.

Tangible results. The OIG s recommendations help the EPA and the CSB improve their
operations, not only through the lens of regional and programmatic offices but also in
terms of their overarching strategies and agencywide missions. For example, in OIG Report No. 22-E-0011. EPA
Has Not Performed Agencywide Risk Assessments, Increasing Risk of Fraud, Waste, Abuse and Mismanagement,
issued December 15, 2021, we found that the EPA did not fully implement federal guidance regarding
comprehensive agencywide risk assessment strategies and instead relied upon assurances from division-level
offices that internal controls were effective. In response to our recommendations, the Agency updated and
established policies and procedures to facilitate enterprise risk assessments with senior-leader engagement to
identify agencywide and crosscutting issues.

Responsiveness to environmental emergencies. Our ultimate customers are the American taxpayers, and we
strive to conduct projects on issues that impact their health and the environment. For example, in November 2021,
the U.S. Navy reported that the drinking water at Joint Base Pearl Harbor-Hickam, located near Honolulu, was
contaminated by leaking fuel. The fuel came from Red Hill, the Navy's bulk fuel storage facility, which the
U.S. Department of Defense has since agreed to defuel and close. We initiated an evaluation to determine whether
the EPA's oversight of authorized state programs in Hawaii has been effective in addressing the potential for
contamination.

k y

mim

Sean W. O'Donnell

The OIG is also working on two other projects concerning drinking water systems. We are examining the EPA's
response to drinking water systems contaminated with lead in both Flint and Benton Harbor. Michigan. Exposure
to lead carries significant risks for children, such as behavior and learning problems, lower IQs, hyperactivity,
slowed growth, hearing problems, and anemia. In Flint, where residents were exposed after the city switched its
water supply in 2014, we are examining whether the EPA fully addressed recommendations from our July 2018
audit, which included improving oversight of Safe Drinking Water Act compliance, training of EPA senior
leaders, and the EPA's operation of its citizen tip hotline. And in Benton Harbor, we are currently examining how
the EPA followed its 2016 policy memorandum, Policy on Elevation of Critical Public Health Issues, when
addressing a water crisis in that city. Water samples collected by the Benton Harbor public water system indicate
that residents were exposed to elevated levels of lead beginning in 2018.

Safer Chemicals. This semiannual period, we issued top management challenges reports for both the EPA and the
CSB. According to the Reports Consolidation Act of 2000, these reports should address the "most serious
management and performance challenges facing the agency." One new challenge we identified for the EPA is the
safe use of chemicals. I discussed this imperative with Congress in a December 2021 hearing addressing
perfluoroalkyl and polyfluoroalkyl substances, better known as PFAS. These "forever chemicals" are found in
consumer and personal care products. Continued exposure can result in an increase in adverse health effects such

During the semiannual reporting
period, OIG work resulted in:

. 4.-4.- l. .4 . ¦ Based on OIG work,

OIG investigative work resulted in: £pA and CSB irnplemenled;

22 reports

66 recommendations
for improvement

33 findings identified in external
audit reports impacting EPA

[©

1,335 hotline contacts handled

3 indictments, informations, and
complaints

7 criminal convictions

34 administrative actions, including
suspension and debarment actions

The term "convictions" comprises finalized convictions (those for
which sentencing is completed) filed during the reporting period.

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as an increased risk of some cancers, decreased fertility in women, and developmental effects or delays in
children. We plan to continue examining PFAS issues in our annual planning and future projects. For example,
we are analyzing whether the EPA followed applicable policies and procedures when developing the
perfluorobutane sulfonic acid toxicity assessment and making changes to the Long-Chain Perfluoroalkyl
Carboxylate and Perfluoroalkyl Sulfonate Chemical Substances Significant New Use Rule.

Whistleblowers and scientific integrity. Supporting whistleblowers and protecting whistleblower activities
continues to be a priority. Whistleblowers play a vital role in the OIG's efforts to eliminate and prevent waste,
fraud, and abuse in Agency programs and operations. They also help us make sure that the Agency fully adheres
to its Scientific Integrity Policy, which has guided the EPA's work for more than a decade. Our hotline regularly
receives allegations of misconduct related to scientific integrity. For example, we received a complaint that the
EPA was not following the best-available science regarding low-dose radiation and consequently initiated an
evaluation. In OIG Report No. 22-E-0016. EPA Is Taking Steps to Update Its Federal Radiation Guidance, issued
January 6, 2022, we found that the Agency does not have a formal process for updating its federal radiation
guidance but that it has taken steps to ensure that its guidance, including for low-dose radiation exposure, is
updated and informed by the best-available and peer-reviewed science. Additionally, the OIG continues to
examine allegations made by whistleblower complainants concerning scientific integrity within the EPA's Office
of Chemical Safety and Pollution Prevention.

Another priority is investigating misconduct involving scientific data. During this semiannual period, we had
11 open investigations into conduct that potentially jeopardizes the EPA's scientific integrity. We are discussing
with the Agency's scientific integrity official revisions to coordination procedures between our offices. Our
common goal is to ensure that scientific integrity concerns, including allegations of research misconduct, are
routed to the proper office and addressed in the most efficient and effective manner. We also believe that these
revisions will clarify the OIG's access rights, about which there has been confusion in the past, and help to
improve information sharing in the future.

Continuing the Mission. Over the last decade, however, we have been operating at flat or declining budgets,
which have severely impacted our ability to perform effective oversight. Although the OIG will receive
approximately $269.3 million from FYs 2022 to 2026 under the Infrastructure Investment and Jobs Act, these
funds can only be used to oversee IIJA-related programming, which is only a portion of the EPA's work.
Administrative and technological support for IIJA oversight is being supported, in part, by our core budget,
leaving less for the OIG to conduct meaningful oversight of the EPA's and the CSB's core functions. Without
staffing levels for oversight commensurate with the EPA's and CSB's full repertoire of programs and operations,
the OIG may be unable to meet the expectations of the public and Congress that we perform comprehensive
oversight to keep the Agency efficient, effective, and accountable to the American taxpayer.

Sean W. O'Donnell
Inspector General

During this semiannual reporting period, OIG:

In this fiscal year, EPA and CSB:

Identified $54,722,992 in potential
monetary benefits

Conducted joint investigations that resulted in
$2,742,191 in fines, penalties, and restitutions

Avoided $174,550 in costs after
implementing recommendations
based on investigative results

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Table of C

Section 1: Overview

1.1	About EPA. CSB. and PIG		1

1.2	OIG Strategic Planning		2

1.3	Analysis of Unimplemented Recommendations		3

1.4	OIG Hotline		5

1.5	Scientific Integrity and Misconduct		7

1.6	Inspector General Congressional Testimony		11

1.7	Congressional and Legislative Activity		12

Section 2: Work Accomplished During Semiannual Period

2.1	Oversight Work		14

Congressional Reguests		14

Coronavirus Pandemic		14

Human Health and Environmental Issues		18

Business Practices and Accountability		21

Hotline Contacts	

U.S. Chemical Safety and Hazard Investigation Board		32

2.2	Investigative Work		34

2.3	Instances of Whistleblower Retaliation and Interference with Independence		37

2.4	Single Audit Work		38

Section 3: Statistical Data

3.1	Audit Report Resolution	 40

3.2	Summary of Investigative Results	 41

Appendixes

1—Reports	Issued		44

2—Delayed	EPA Management Decisions and Comments: Management Decisions

with Which OIG Disagrees		46

3—Reports	with Corrective Action Not Completed		52

4—Closed	Investigations Involving Senior Employees		69

5—Peer	Reviews Conducted		70

6—OIG	Mailing Addresses and Telephone Numbers		71

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SECTION 1:
OVERVIEW

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

1.1 About EPA, CSB, and PIG

The 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.

The U.S. Chemical Safety and Hazard Investigation Board

The U.S. Chemical Safety and Hazard Investigation Board 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.

The 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. Since fiscal
year 2004, Congress has designated the EPA inspector general to also serve as the inspector general for
the CSB. As a result, the EPA OIG has the responsibility to audit, evaluate, inspect, and investigate EPA
and CSB programs and operations, as well as to review proposed laws and regulations to determine their
potential impact on these programs and operations. 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.

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, 2021-March 31, 2022

1.2 OIG Strategic Planning

When determining which audits and evaluations to undertake, the OIG independently considers the top
management and performance challenges facing the EPA and the CSB. In this semiannual report, we
identify which top management challenges our audits and evaluations address, as applicable, next to the
following symbol: . We also consider how our oversight work supports the EPA's mission-related
efforts to protect human health and the environment. We show which mission-related efforts our reports
support next to this symbol: . Some of the work we conduct is required by law or executive order;
those reports are labeled with the following symbol: 1^1. We also, as part of our oversight function, may
verify proper implementation of EPA and CSB corrective actions via follow-up audits and evaluations.
We identify such follow-up projects with the following symbol: ft

Agency Management Challenges

EPA FY 2022 management challenges report issued November 12, 2021
CSB FY 2022 management challenges report issued November 10, 2021

In accordance with the Reports Consolidation Act of 2000, each
OIG is required to prepare an annual report summarizing what
the inspector general considers to be the "most serious
management and performance challenges facing the agency." To
identify the EPA's top management challenges, we considered
the OIG's body of work, surveyed EPA program offices,
solicited senior EPA leadership input, and held outreach
meetings with the Agency's program offices. We also considered
the work of the U.S. Government Accountability Office and
public statements by EPA leaders to the press and Congress.
Based on this feedback, we identified seven management
challenges facing the EPA. We used audit, evaluation, and other
analyses of CSB operations to formulate one management
challenge facing the CSB in FY 2022.

We began work in this semiannual reporting period to identify
the top management challenges that the EPA and the CSB will
face in FY 2023. We expect to publish this report during the next
semiannual reporting period.

Oversight Plan

FY 2022 plan issued December 16, 2021

Our Fiscal Year 2022 Oversight Plan reflects the priority work that the OIG believes is necessary to keep
the EPA, the CSB, Congress, and the American people fully informed about problems and deficiencies
relating to the administration of Agency programs and operations. This document lists, by management
challenge, our planned and ongoing oversight projects and guides us in fulfilling our critically important
mission to detect and deter waste, fraud, and abuse in EPA and CSB programs and operations; to improve
the efficiency and effectiveness of the EPA and the CSB; and to help ensure ethical conduct throughout
the EPA and the CSB. It is also important to note that our plan is not static; the projects included may be
modified throughout the year as new challenges and risks emerge for the EPA and the CSB.

EPA FY 2022 Management Challenges

1. Mitigating the causes and adapting to
impacts of climate change.

2. Integrating and leading environmental
justice, including communicating risks.

3. Ensuring safe use of chemicals.

4. Safeguarding scientific integrity.

5. Protecting information technology and
systems against cyberthreats.

6. Managing infrastructure funding and
business operations.

7. Enforcing environmental laws and
regulations.

CSB FY 2022 Management Challenge

1. Accomplishment of CSB mission is
impaired until new board members are
selected.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

1.3 Analysis of 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, which
address a range of human health, environmental, and business issues. Twice a year, we will issue a
compendium that provides an in-depth analysis of the open and unresolved recommendations issued by
the OIG to the EPA and the CSB.

Before issuing a final report, the OIG distributes a draft report to the EPA or the CSB, identifying a lead
official for each recommendation included in the report. The lead officials then have the opportunity to
respond to the draft report findings and recommendations. For the final report, which is posted on the
OIG's website, the OIG analyzes the responses received and indicates whether each recommendation is:

• Unresolved. The EPA or the CSB disagrees with the recommendation or did not provide a
formal, complete, written response to the recommendation, or the OIG disagrees that the
Agency's proposed corrective actions are responsive to the recommendation. Recommendations
that remain unresolved six months after the final report is issued are listed in Appendix 2.

• Resolved. The EPA or the CSB and the OIG agree upon the recommendation and proposed
corrective actions, but the corrective actions have not yet been completed. These
recommendations are also called open recommendations and are considered unimplemented,
regardless of whether their expected due dates are in the past or the future. Unimplemented
recommendations issued prior to this semiannual reporting period are listed in Appendix 3.

• Completed. The EPA or the CSB and the OIG agree upon the recommendation and proposed
corrective actions, and the EPA or the CSB has fully completed them.

Section 5(a)(3) of the Inspector General Act requires that we identify each significant recommendation
described in previous semiannual reports for which corrective action has not been completed. For this
semiannual report, we analyzed actions taken by the EPA and the CSB regarding recommendations
described in past semiannual

reports and identified those that Number of unimP'emented recommendations

remained unimplemented as of
March 31, 2022: 156 for the EPA
and three for the CSB. The chart to
the right shows when these
159 unimplemented
recommendations were originally
issued to the EPA or the CSB. The
potential monetary benefits of the
156 recommendations issued to the
EPA are approximately
$29.7 million. There are no
potential monetary benefits FY2008-2017 FY2018 FY2019 FY2020 FY2021

associated with the unimplemented

CSB recommendations. Note that the recommendations issued during this semiannual period are included
as part of the report summaries in Section 2.1.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

The table below breaks down the 159 unimplemented recommendations issued to the EPA and the CSB
according to their potential health, environmental, and business benefits and identifies the potential
monetary benefits to be gained if these recommendations are implemented. Appendix 3 provides the full
text of the unimplemented recommendations.

Category

Number remaining
unimplemented

Potential monetary benefits
associated with unimplemented
recommendations



EPA unimplemented recommendations

1. Administrative and Business
Operations

53

$1,877,000

2. Human Health and Environmental
Issues

103

$27,800,000

EPA subtotal

156

$29,677,000



CSB unimplemented recommendations

1. Management and Operations

3

$0

CSB subtotal

3

$0



TOTAL

159

$29,677,000

4

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

1.4 OIG Hotline

Section 8M of the Inspector General Act 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, 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 laws, 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 suggestions 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. In Section 2.1. we summarize the work based on hotline contacts
concluded during this semiannual reporting period.

Hotline Statistics

The figures below detail the number and types 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 semiannual period ending March 31, 2022. In this semiannual period, of the
1,335 contacts received, the OIG made 252 referrals. A contact can be referred to more
than one entity. We refer complaints related to the OIG's oversight goals and mission to
internal offices to consider for action. We refer contacts unrelated to potential fraud, waste,
abuse, misconduct, or mismanagement but related to an Agency program or operation to
the appropriate EPA or CSB office. As applicable, we attempt to refer contacts unrelated to the EPA or
the CSB to another government agency. More information about our hotline operations, including a
podcast that discusses how the EPA OIG hotline works, who uses it, and how to file a hotline complaint,
can be found on our website.

Hotline contacts received 10/1/21-3/31/22 Hotline contacts referred 10/1/21-3/31/22

f \

Podcast

\ s

1,106

229

Hotline emails Hotline calls

159

To OIG offices To EPA program To other federal,
offices state, and local

agencies

Source: EPA OIG hotline data. (EPA OIG images)

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Semiannual Report to Congress	October 1, 2021-March 31, 2022

Categories of the 159 hotline contacts referred to OIG offices

Criminal activity





| 68

Employee issues



1 21



Environmental issues



27









Program and operations related issues



28









Scientific integrity issues



12



Whistleblower

¦





Source: EPA OIG hotline data. (EPA OIG image)

Hotline Confidentiality

Individuals who contact the hotline are not required to identify themselves and may request
confidentiality when submitting allegations. However, the OIG encourages those who report allegations
to identify themselves so that they can be contacted if the OIG has additional questions. Pursuant to
section 7 of the Inspector General Act, the OIG will not disclose the identity of an EPA 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 make a complaint or
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—regardless of whether the individual is an EPA or CSB employee—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(3).epa.qov

Mail:

EPA OIG Hotline

Phone: (888) 546-8740 or (202) 566-2476



1200 Pennsylvania Avenue, NW

Online: EPA OIG Hotline



Mail Code 2410T





Washington, D.C. 20460

EPA Whistleblower Protection Coordinator





The EPA whistleblower protection coordinator can be reached at:



Phone: (202)566-1513

Email:

whistleblower protection(3).epa.qov

6

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

1.5 Scientific Integrity and Misconduct

Scientific integrity at the EPA helps ensure that the science conducted, communicated, and used across the
Agency is of the highest quality. Scientific integrity is crucial because it safeguards science to ensure that
it is objective and rigorous. In November 2021, the OIG identified "Safeguarding Scientific Integrity
Principles" as a top management challenge for the EPA. The EPA issued its Scientific Integrity Policy in
February 2012. The policy sets the expectation for all EPA employees to represent the Agency's scientific
activities clearly, accurately, honestly, objectively, thoroughly, without political or other interference, and
in a timely manner, consistent with their official
responsibilities. It also sets the expectation that all EPA
employees will report policy breaches. The EPA's
Scientific Integrity Program consists of the EPA's
scientific integrity official, deputy scientific integrity
officials from each of the EPA's program and regional
offices, and program staff who support implementing the
Scientific Integrity Policy.

As part of its mission to detect and deter waste, fraud,
abuse, and mismanagement, the OIG conducts investigations related to "research misconduct" or
"scientific misconduct," including fabrication, falsification, or plagiarism. After receiving consent from the
complainant, the OIG may refer scientific integrity allegations that it receives to the scientific integrity
official. The scientific integrity official and OIG staff meet once every two weeks to discuss the status of
cases, as appropriate, as well as other scientific integrity-related issues.

The OIG has a critical role in protecting the Agency's scientific integrity. As an independent office, the
OIG can receive complaints of mismanagement, misconduct, abuse of authority, or censorship, including
those related to scientific or research misconduct, without fear of improper influence. Through its statutory
mandate, the OIG can investigate these allegations. To facilitate transparency, we continue our practice,
started in our fall 2020 Semiannual Report to Congress, of providing a summary of scientific integrity
oversight at the Agency. The following section reports the status of scientific integrity allegations received
by the scientific integrity official and any scientific misconduct allegations received by the OIG.

Scientific Integrity Allegations and Advice Queries Received by the Scientific
Integrity Official

The EPA's Scientific Integrity Program engages with Agency staff who raise potential scientific integrity
concerns through two mechanisms: (1) advice and assistance and (2) a procedure for reporting and
adjudicating allegations. The purpose of advice and assistance is to provide early intervention to prevent
lapses in scientific integrity. 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 allegation. If an allegation is reported, the Scientific Integrity
Program conducts an initial screening to determine whether the allegation is covered under the Scientific
Integrity Policy. This initial screening may 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.

The table and figure below enumerate the scientific integrity allegations and advice queries received by the
scientific integrity official in the current fiscal year and since the program's inception in 2012. Allegations
are categorized by topic area; one complaint may contain multiple allegations. For advice queries, only the

"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."

—Scientific Integrity Policy. Section II

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Semiannual Report to Congress	October 1, 2021-March 31, 2022

number of contacts and primary topic area are captured as summary statistics by the scientific integrity
official.

Scientific integrity allegations and advice queries by topic



Authorship

Data
quality

Delay/
suppression

Interference

Plagiarism

Other

Not
scientific
integrity

Allegations

Oct-Mar 2022







1 (100%)







Total: FY 2022

0

0

0

1

0

0

0

Total: program
inception through
March 31, 2022

16 (15%)

8 (7%)

16 (15%)

42 (38%)

2 (2%)

16 (15%)

10 (9%)

Advice Queries

Oct-Mar 2022

2 (6%)





15 (46%)



13 (39%)

3 (9%)

Total: FY 2022

2

—

—

15

—

13

3

Total: program
inception through
March 31, 2022

32 (9%)

19 (5%)

51 (14%)

156 (43%)

7 (2%)

68 (19%)

28 (8%)

Source: EPA Scientific Integrity Program. (EPA OIG table)

Note: Percentages in this table were rounded. These are preliminary data provided by the EPA's Scientific
Integrity Program and are subject to change.

Number of scientific integrity inquiries by fiscal year since policy inception

120
100
80
60
40
20

0 	

2012

¦ Advice ¦ Allegation

Source: EPA Scientific Integrity Program. (EPA image)

Note: For FY 2022, these are preliminary data provided by the EPA's Scientific Integrity Program and are subject
to change.

As shown in the table and figure above, for the semiannual reporting period ending March 31, 2022, the
scientific integrity official received one new allegation and 33 new advice queries. Also during this
semiannual reporting period, one allegation was closed or resolved. The table below summarizes the status
of the allegations as of March 31, 2022. There are currently 25 open allegations: 24 from prior reporting
periods and one from the current reporting period. Requests for advice or allegations received by the
scientific integrity official are not necessarily referred to the OIG. The scientific integrity official is
responsible for informing complainants that certain types of issues, such as those involving waste, fraud,
abuse, reprisal, and misconduct, should be reported to the OIG. The scientific integrity official is also

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Semiannual Report to Congress

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responsible for directly referring these types of allegations to the OIG. See the next section for information
about the OIG's actions on scientific misconduct allegations during this semiannual reporting period.

Status of allegations

Allegations

Number as of

Status

March 31, 2022

Open/Active*

Closed—substantiated

Closed—not substantiated

Closed—other

Withdrawn

Referred to the OIG

Not scientific integrity

Source: OIG summary of EPA Scientific Integrity Program data. (EPA OIG table)

• This number includes the total open/active allegations remaining from the
current and previous reporting periods.

Note: These are preliminary data provided by the EPA's Scientific Integrity
Program and are subject to change.

Scientific Misconduct Allegations Received and Investigated by the OIG

EPA Order 3120.5 contains the Agency's policy and procedures for addressing research misconduct,
including the requirement for EPA employees to immediately report to the OIG any allegation of research
misconduct that involves:

• Public health or safety being at risk.

• Agency resources or interests being threatened.

• Circumstances where research activities should be suspended.

• Reasonable indication of possible violations of civil or criminal law.

• Federal action being required to protect the interests of those involved in the investigation.

• A research entity's belief that an inquiry or investigation may be made public prematurely, so that
appropriate steps can be taken to safeguard evidence and protect the rights of those involved.

• Circumstances where the research community or public should be informed.

Additionally, EPA Manual 6500, Functions and Activities of the Office of Inspector General: 1994 Edition,
states, "Each employee is responsible for promptly reporting indications of wrongdoing or irregularity to the
OIG and for cooperating and providing assistance during any audit or investigation." Coordination
procedures between the scientific integrity official and the OIG state that upon receiving a research
misconduct allegation, the scientific integrity official will refer the allegation to the OIG Hotline. Likewise,
if the OIG receives an allegation of research misconduct through means other than the OIG Hotline, the
allegation will be forwarded to the OIG Hotline, and OIG staff will contact the scientific integrity official to
discuss the allegation, as appropriate. As noted above, the scientific integrity official and OIG staff also meet

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

every two weeks to discuss the status of cases, as appropriate, as well as other scientific integrity-related
issues.

For the semiannual reporting period ending March 31, 2022, the OIG received seven complaints with
allegations involving potential scientific misconduct from Agency employees, the scientific integrity official,
and other sources. The OIG had 11 open investigations involving potential scientific misconduct during the
reporting period. Two cases were opened during the reporting period, one of which was subsequently closed.

The OIG had no relevant results of investigations that it conducted or oversaw to report to the Agency for a
determination of appropriate action.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

1.6 Inspector General Congressional Testimony

On December 9, 2021, EPA Inspector General Sean W. O'Donnell testified before the U.S. Senate
Committee on Homeland Security and Governmental Affairs at a hearing examining federal efforts to
address perfluoroalkyl and polyfluoroalkyl substances, known as PFAS, contamination that centered on a
July 2021 U.S. Department of Defense OIG Report No. DQDIG-2021-105. Evaluation of the Department
of Defense 's Actions to Control Contaminant Effects from Perfluoroalkyl and Polyfluoroalkyl Substances
at Department of Defense Installations. Inspector General O'Donnell appeared before the committee in his
capacity as both EPA inspector general and Department of Defense acting inspector general.

Given his dual roles, Inspector General O'Donnell was uniquely suited to provide insight related to the
Department of Defense OIG report, as well as the EPA's role in leading federal efforts to address PFAS
contamination and chemical safety. He testified that the EPA OIG had identified "Ensuring the Safe Use of
Chemicals" as one of the top management challenges facing the EPA in FY 2022. The EPA OIG's recent
body of work included projects specifically focusing on PFAS, other chemicals of concern, and
overarching processes related to chemical safety.

The inspector general noted that the recent EPA OIG work identified deficiencies related to chemical
safety, including the EPA's overall lack of capacity to conduct chemical risk evaluations in compliance
with the Toxic Substances Control Act, drinking water health advisories that have not kept pace with
emerging chemicals of concern, allegations regarding a loss of scientific integrity, challenges to the EPA's
ability to properly address the safety of chemicals within established rulemaking procedures, and issues
with the EPA's capability to provide timely and accurate communication about contaminants.

Inspector General O'Donnell also provided testimony related to whistleblower complaints on chemical
safety and scientific integrity issues, including recent allegations that senior leadership inappropriately
changed or removed the human health hazards for several chemicals—including one PFAS—from
chemical assessments. The EPA OIG is examining some of these allegations in an ongoing project to
determine the extent to which the EPA is using and complying with applicable standards during review
and approval of new chemicals under the Toxic Substances Control Act.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

1.7 Congressional and Legislative Activity

Briefings, Requests, and Inquiries

During this reporting period, the OIG provided 17 briefings to congressional members and staff on the
OIG's oversight work. These briefings allowed the inspector general and OIG staff to better understand
congressional perspectives, provide information about the OIG, and establish the foundation for an open
dialogue. They also served as an opportunity for the OIG to highlight the need for increased oversight of
the EPA and the CSB. Briefings included discussions regarding recent, ongoing, and future OIG work,
including oversight of the EPA's strategic plans to address harmful algal blooms; the EPA's response to
the drinking water lead contamination in Benton Harbor, Michigan; and the EPA's oversight of drinking
water contamination at the Red Hill Underground Fuel Storage Facility in Honolulu. During this reporting
period, the OIG received three congressional requests.

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 programs and operations of the EPA and the CSB, as well as to
make recommendations concerning their potential 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 any recommendations and comments we make 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 semiannual reporting period
ending March 31, 2022, we reviewed two proposed changes to legislation, regulations, policy,
procedures, or other documents that could affect the EPA, the CSB, or the OIG. We provided
recommendations or comments on proposed legislation related to whistleblower protections and
investigations.

12

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SECTION 2:

Work Accomp
During	the Semiann

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

2.1 Oversight Work
Congressional Requests

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, 2022, we did
not publish any reports based on congressionally requested work.

Coronavirus Pandemic

Reports Related to the EPA's Pandemic Responses

Total National Reported Clean Air Act Compliance-Monitoring Activities Decreased
Slightly During Coronavirus Pandemic, but State Activities Varied Widely

Report No. 22-E-0008, issued November 17, 2021
Improving air quality

[> Overseeing states implementing EPA programs; Maintaining operations during pandemic responses (from
FY 2020-2021 EPA Management Challenges report)

The coronavirus pandemic marginally impacted the total number of nationwide compliance-monitoring
activities at facilities that emit air pollution, but states and territories reported changes in
compliance-monitoring activities at high-emitting sources, ranging from an 88-percent decrease to a
234-percent increase in FY 2020. Substantially lower levels of compliance monitoring increase the risk
that noncompliance will go undetected at facilities. State and local agencies also shifted some types of
activities from on-site to off-site, in accordance with EPA guidance issued in July 2020. However, the
EPA has not assessed the impact of off-site activities to ensure that they comply with the Clean Air Act
Monitoring Strategy.

Recommendations for corrective action issued to the assistant administrator for Enforcement and Compliance Assurance

In coordination with the EPA regional offices, evaluate the needs of the state and local agencies in states and territories
that had significant declines, as determined by the EPA, in their total compliance-monitoring activities for fiscal year 2020
to determine whether technical assistance is needed and provide it as appropriate.

Assess a portion of off-site full-compliance evaluations reported by state and local agencies during the coronavirus
pandemic to determine whether they meet the requirements of a full-compliance evaluation.

After assessing a portion of the off-site full-compliance evaluations reported by state and local agencies during the
coronavirus pandemic, determine whether additional guidance on what constitutes an off-site full-compliance evaluation,
the types of facilities where an off-site full-compliance evaluation is appropriate, and when a remote visual component is
necessary. If such a determination is made, issue updated guidance on off-site full-compliance evaluations.

Determine and document the conditions or parameters under which the use of remote video to conduct off-site partial
compliance evaluations is feasible from a legal, technical, and programmatic perspective.

Finalize the Remote Video Partial Compliance Evaluation workgroup's standard operating procedures.

Determine whether and how remote video can be used in conjunction with a document review to qualify as a
full-compliance evaluation for purposes of the Clean Air Act Stationary Source Compliance Monitoring Strategy and
provide instruction to state and local agencies.

Report Addresses: EPA mission-related effort, {o} Top management challenge for EPA. Mandatory reporting requirements. Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Authorized State Hazardous Waste Program Inspections and Operations Were
Impacted During Coronavirus Pandemic

Report No. 22-E-0009. issued December 1, 2021

Partnering with states and other stakeholders
{§} Maintaining operations during pandemic responses (from FY 2020-2021 EPA Management Challenges report)

The number of inspections from March 2020 through
February 2021 for Resource Conservation and Recovery Act
treatment, storage, and disposal facilities decreased by
34 percent and for large-quantity generators decreased by
47 percent when compared to the prior year. The number of
violations found per inspection also decreased. Decreases in
inspections during the coronavirus pandemic may have been
due to remote work and travel restrictions. These inspections
provide a deterrent effect that protects human health and the
environment.

Recommendations for corrective action issued to assistant administrator for Land and Emergency Management

Assist authorized states in developing and implementing plans that ensure that states are able to maintain operations in
the event of a pandemic or other disaster.

Work with EPA regions to identify limitations, such as issues with the Cross-Media Electronic Reporting Rule, on virtual
work by authorized state programs and address the issues through modification of EPA processes, information systems, or
updated guidance.

Recommendations for corrective action issued to assistant administrator for Enforcement and Compliance Assurance

Review Resource Conservation and Recovery Act information system inspection data entered during the coronavirus
pandemic to determine the extent off-site compliance-monitoring activities were incorrectly counted as inspections and
correct the inspection data in the system as needed.

Work with ail EPA regions to determine why the rate of violations per inspection was reduced during the coronavirus
pandemic and the inspection rate for large-quantity generators was below historical levels from October 2020 through
February 2021.

Develop policies that define inspection requirements and flexibilities to optimize the capabilities of authorized state
programs in future large-scale pandemic or disaster events. These should include mechanisms, consistent with EPA
guidance documents, that allow maintenance of normal Resource Conservation and Recovery Act inspection rates while
ensuring the safety of enforcement staff.

EPA facility inspection. (EPA photo)

Report Addresses: £ EPA mission-related effort, fo~ Top management challenge for EPA. Mandatory reporting requirements. Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

EPA Should Consistently Track Coronavirus Pandemic-Related Grant Flexibilities and
Implement Plan for Electronic Grant File Storage

Report No. 22-P-0018, issued February 22, 2022

Operating efficiently and effectively
; Managing infrastructure funding and business operations

Because of inconsistent tracking by EPA program offices and regions, the Agency does not know the full
extent to which program offices and regions have implemented
grant flexibilities and exceptions permitted by the Office of
Management and Budget due to the coronavirus pandemic. This
lack of agency wide tracking hindered the Agency's ability to
assess how the pandemic impacted the grant recipients" ability to
accomplish its program mission. Additionally, the EPA does not
have an official agencywide electronic grant file storage system,
which increases the risk of files being lost or inaccessible.

Recommendations for corrective action issued to assistant administrator for Mission Support

1 Develop a standard operating procedure that instructs program offices and regions on tracking and documenting grant
flexibilities and exceptions, and their impacts, due to unanticipated events in order to assure consistency in the information
needed to manage grants.

2 Develop a plan to implement, by December 2022, a uniform electronic record-keeping system for grants to meet the Office
of Management and Budget direction in M-19-21, Transition to Electronic Records, that all federal records must be created,
retained, and managed in electronic formats with appropriate metadata.

3 Direct program offices and regions to use a uniform official electronic file system that would allow consistency in
agencywide access and storage of electronic grant files.

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 the
misuse of the EPA logo or seal and products that failed to perform as advertised. One pandemic-related
investigation was closed during the semiannual reporting period, and the allegation was supported.

OIG Transparency Efforts Related to Pandemic
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 webpage of our work
related to the pandemic. This page 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 November 2021

Updated November 2021

Our final EPA OIG's Response to the COVID-19 Pandemic summary report was issued in November
2021. However, relevant oversight work continues. The OIG will complete and continue to initiate audits,
evaluations, and investigations related to the impact of the coronavirus pandemic on the EPA and the
CSB. We will examine and identify how the pandemic has impacted Agency programs and operations, as

Report Addresses: EPA mission-related effort, {o} Top management challenge for EPA. Mandatory reporting requirements. Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

well as potential misconduct and criminal activity. Subjects we have reviewed or may examine include
the EPA's responses to emergency incidents, such as hurricanes and wildfires; releases of hazardous
substances; air quality enforcement; and misconduct and criminal activity. We continue to coordinate
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.

Report Addresses: EPA mission-related effort, {o} Top management challenge for EPA. Mandatory reporting requirements. Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Human Health and Environmental Issues

EPA's Title V Program Needs to Address Ongoing Fee Issues and Improve Oversight

Report No. 22-E-0017, issued January 12, 2022

Improving air quality
{o} Mitigating the causes and adapting to the impacts of climate change

EPA regions generally met their goal of conducting one Title V program evaluation per year. However,
the EPA noted concerns about the decline of Title V program revenue and the use of non-Title V revenue
to fund Title V programs. The guidance the
EPA issued to the regions in 2018 regarding
conducting fee evaluations was discretionary
and did not clarify when to conduct fee
evaluations or establish a minimum standard of
review. Insufficient and misused Title V fees
may lead to unsustainable Title V programs and
hinder the EPA's ability to comply with Clean
Air Act regulations.

Source: EPA OIG image.

Recommendations for corrective action issued to the assistant administrator for Air and Radiation

Coordinate with EPA regions to provide recurring training on Clean Air Act Title V fee laws and regulations to permitting
agencies.

In collaboration with EPA regions, develop and implement a plan to address declining Clean Air Act Title V revenues.

Update the EPA's guidance documents to require regions to establish time frames for permitting authorities to complete
corrective actions in program and fee evaluation reports and clear, escalating consequences if timely corrective actions are
not completed.

Update the Clean Air Act Title V guidance documents to establish criteria for when regions must conduct Title V fee
evaluations and require a minimum standard of review for fee evaluations.

Provide training to EPA regional staff on the updated Clean Air Act Title V fee guidance and how to conduct fee evaluations.

Collaborate with regional staff to identify and make available the regional resources and expertise necessary to conduct fee
evaluations.

Report Addresses: £ EPA mission-related effort, fo) Top management challenge for EPA. fib Mandatory reporting requirements. Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

The EPA Needs to Develop a Strategy to Complete Overdue Residual Risk and
Technology Reviews and to Meet the Statutory Deadlines for Upcoming Reviews

Report No. 22-E-0026, issued March 30, 2022

Improving air quality
; ) Integrating and leading environmental justice, including communicating risks

The EPA has not conducted all the residual risk and technology reviews mandated by the Clean Air Act.
These reviews are used, as needed, to revise standards that limit air toxics emissions. As of November 1,
2021, 93 of the 169 industrial sources subject to the statutory requirement had overdue reviews. The EPA
has not conducted a workforce analysis to determine the level of staff and resources needed to conduct the
required reviews. Air toxics emitted from industrial sources with overdue reviews can cause cancer and
other serious health conditions. Overdue reviews may also disproportionately impact communities with
environmental justice concerns, as these communities are more likely to be sited near industrial facilities
or other pollution sources.

Recommendations for corrective action issued to the assistant administrator for Air and Radiation

1 Perform a workforce analysis to determine the staff and resources needed to meet the statutory deadlines for residual risk
and technology reviews, initial technology reviews, and recurring eight-year technology reviews, as well as to complete any
such reviews that are overdue.

2 Develop and implement a strategy to conduct (a) residual risk and technology reviews and recurring technology reviews by
the applicable statutory deadlines and (b) any overdue residual risk and technology reviews and recurring technology
reviews in as timely a manner as practicable. The strategy should take into account the Agency's environmental justice
responsibilities under Executive Order 12898 and other applicable EPA and executive branch policies, procedures, and
directives.

Report Addresses: £* EPA mission-related effort, f :> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

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Semiannual Report to Congress October 1, 2021-March 31, 2022

Brownfields Program-Income Monitoring Deficiencies Persist Because the EPA Did Not
Complete All Certified Corrective Actions

Report No. 22-P-0033. issued March 31, 2022 ^

£* Operating effectively and efficiently; Cleaning up and revitalizing land
[ '? Managing infrastructure funding and business operations

The Office of Land and Emergency Management did not fully complete the agreed-to corrective actions
for five recommendations from OIG Report No. 17-P-0368. Improved Management of the Brownfields
Revolving Loan Program Is Required to Maximize Cleanups. As a result, the Agency is unable to
determine whether an estimated $46.6 million of program income under closed cooperative agreements
was used timely and for the purposes authorized under the closeout agreements established to govern the
use of that program income. In addition, the Agency is unable to determine whether actions are needed to
address noncompliance with closeout agreement terms and conditions.

Recommendations for corrective action issued to the assistant administrator for Land and Emergency Management

Develop a policy and implement procedures to reduce the balances of available program income and establish a time frame
for recipients to use or return the funds to the EPA.

Implement a method for tracking program income and compliance with post-closeout reporting requirements.

Expand existing guidance to include the requirements and method for the post-closeout tracking of program income and
annual reports.

Provide training to regional Brownfields Revolving Loan Fund staff and management on the post-closeout tracking and
monitoring requirements.

Expand existing guidance to include a deadline for post-closeout annual report submission.

Assess whether any of the $46.6 million of program income under closeout agreements should be returned to the
government.

Report Addresses: £* EPA mission-related effort, f :> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Business Practices and Accountabilit

EPA Has Not Performed Agencywide Risk Assessments, Increasing the Risk of Fraud,
Waste, Abuse, and Mismanagement

Report No. 22-E-0011, issued December 15, 2021

£** Compliance with the law; Operating efficiently and effectively

i 7 Managing infrastructure funding and business operations

The Office of the Chief Financial Officer is responsible for implementing Office of Management and
Budget Circular A-123, Management's Responsibility for Enterprise Risk Management and Internal
Control, which requires federal agencies to integrate internal control activities under the umbrella of an
enterprise risk-management program through a risk-assessment process. However, the Office of the Chief
Financial Officer has not developed or implemented such a process, which would identify high-priority
risks that cut across individual Agency programs and fully engage executive officials in entity-level
risk-assessment activities. A risk-assessment process would also ensure that resources received through
annual and supplemental appropriations are strategically targeted. In addition, the Office of the Chief
Financial Officer has not updated its financial-management processes, policies, and procedures to identify
and address risks at the agencywide entity level.

Recommendations for corrective action issued to the chief financial officer

1	Improve the Agency's strategy for implementing enterprise risk management by incorporating and communicating the
executive-official engagement needed in risk activities to achieve full compliance with Office of Management and Budget
Circular A-123, Management's Responsibility for Enterprise Risk Management and Internal Control.

2	Establish Agency policies and procedures—including updates to Resource Management Directives System 2520,
Administrative Control of Appropriated and Other Funds; EPA Order 1000.24, Management's Responsibility for Internal
Controls; and EPA Delegation 1-16, Agency CFO-Accounting, Budgeting, and Other Financial Management Activities—to
comply with Office of Management and Budget Circular A-123, Management's Responsibility for Enterprise Risk
Management and Internal Control.

Report Addresses: £* EPA mission-related effort, f :> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

The EPA Did Not Follow Agency Policies in Managing the Northbridge Contract and
Potentially Violated Appropriations Law

Report No. 22-E-0027, issued March 31, 2022

Operating efficiently and effectively
; ) Managing infrastructure funding and business operations

In December 2015, the EPA awarded a contract to The Northbridge Group Inc.
to provide support services to states for their municipal drinking water and
wastewater programs. While the EPA paid for work conducted in Region 9
under the Northbridge contract, EPA staff did not obtain proper approvals
when paying the invoices. In addition, the EPA used over $1.1 million to
interchangeably pay invoices for other states, which made it difficult to
determine whether funds were properly spent. The Agency also did not follow
multiple appropriation funding policies when allocating $6.8 million for the entire
contract. While we confirmed that Northbridge provided acceptable deliverables
for its work in Region 9, the EPA did not follow established acquisition guidance
to review and track the completion of these deliverables.

Recommendations for corrective action issued to the assistant administrators for Water and Mission Support

1 In conjunction with the chief financial officer and general counsel, assess whether and to what extent EPA personnel failed
to comply with 31 U.S.C. §§ 1301(a) and 1341(a)(1)(A) in funding Northbridge activities performed pursuant to EPA Contract
EP-C-16-001; provide the results of this assessment, including the relevant invoice numbers and dollar amounts for any
violations identified, to the OIG; and take all appropriate corrective actions regarding violations, if any.

2 Annually train contracting officers, contracting officer representatives, and work assignment contracting officer
representatives and maintain documentation of their completion of training on requirements applicable to funding contract
activity using multiple appropriations, including requirements found in appropriations law; the Federal Acquisition
Regulation; the EPA Administrative Control of Appropriated Funds, Release 3.2, known as the 2008 Funds Control Manual;
and the EPA Acquisition Guide.

3 Establish internal controls to ensure the enforcement of segregation of duties between the contracting officer, the
contracting officer representative, and the work assignment contracting officer representative and the proper review and
tracking of the completion of contractor deliverables.

Northbridge
Contract

Potential violation
Purpose Statute

$-*M\

Source: EPA OIG image.

Report Addresses: £* EPA mission-related effort. (:> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

EPA Needs to Complete Implementation of Religious Compensatory Time Training for
Supervisors and Employees

Report No. 22-P-0019, issued March 7, 2022

Operating efficiently and effectively
( '? Managing infrastructure funding and business operations

We found that the EPA's certified
corrective action for a
recommendation in OIG Report
No. 16-P-0333, Enhanced Controls
Needed to Prevent Further Abuse
of Religions Compensatory Time,
issued September 27, 2016, did not,
in fact, fully implement the
recommendation to which the
Agency had agreed. Specifically,
training on Religious
Compensatory Time was provided
to the EPA's Human Resources
community, but not to all
employees who use it or all supervisors
who approve such time. Without proper
training, employees and supervisors

may not understand the policy, requirements, and responsibilities regarding the use and approval of
Religious Compensatory Time, which could result in misuse or abuse and create a monetary liability for
the Agency.

Improves
understanding

of policy,
requirements,
and

responsibilities

Training the Agency's supervisors and employees on Religious
Compensatory Time regulations and policy would prevent misuse
and decrease monetary liability. (EPA OIG image)

Recommendations for corrective action issued to the assistant administrator for Mission Support

1 Require the EPA's Office of Human Resources to train all employees and supervisors who earn, use, or approve Religious
Compensatory Time on the U.S. Office of Personnel Management's current regulatory requirements for, and the EPA's
current policy and procedures related to, Religious Compensatory Time.

Report Addresses: £* EPA mission-related effort, f :> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

EPA Generally Adheres to Information Technology Audit Follow-Up Processes, but
Management Oversight Should Be Improved

Report No. 22-P-0010, issued December 8, 2021

£* Operating efficiently and effectively

} Enhancing information technology security; Complying with key internal control requirements (data quality;
policies and procedures) (from FY 2020-2021 EPA Management Challenges report)

While the EPA completed
13 corrective actions for
cybersecurity audit
recommendations in the OIG
reports we reviewed, the
Agency inaccurately reported
its timely completion for one
corrective action and lacked
management oversight to
effectively resolve identified
weaknesses in two other
corrective actions. Specifically,
one unresolved weakness
related to the EPA being

unable to verify the certification and preservation of documentation to support information technology
contractors" compliance with Agency training requirements. For the other unresolved weakness, the
Agency failed to install security patches for its Pesticide Registration Information System production
database in accordance with federal and Agency information security directives.

Recommendations for corrective action issued to the assistant administrator for Chemical Safety and Pollution Prevention

1	Update the Agency's audit tracking system with the correct completion dates and reasons for the delays for corrective
actions related to Recommendation 4 of EPA OIG Report Number 19-P-0195, Pesticide Registration Fee, Vulnerability
Mitigation and Database Security Controls for EPA's FIFRA and PRIA Systems Need Improvement, issued June 21, 2019, as
required by EPA Manual 2750, Audit Management Procedures.

2	Instruct program managers that they must validate that corrective actions are completed before closing them in the Agency's
audit tracking system.

Recommendation for corrective action issued to the assistant administrator for Mission Support

3	Develop and implement a process to store certifications collected for annual role-based training requirements in a
centralized, properly restricted location.

Recommendation for corrective action issued to the assistant administrator for Chemical Safety and Pollution Prevention

4	Implement controls to comply with federally and Agency-required time frames to install patches to correct identified
vulnerabilities in the Pesticide Registration Information System application.

Timely Completion

The EPA completed the 13 corrective actions we reviewed as part of this audit;
however, discrepancies related to a lack of management oversight were found
in three of the 13 corrective actions. (EPA OIG image)

Report Addresses: £* EPA mission-related effort. (:> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

24

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

EPA Established a Web Management Program, but Improvements Are Needed in
Deploying Web Analytics

Report No. 22-P-0013, issued December 20, 2021

Operating efficiently and effectively
; ) Integrating and leading environmental justice, including communicating risks

The EPA has not deployed the required web analytics
tracking code, which is used to capture web traffic and
develop metrics, for 14 of its 308 public websites that
provide essential environmental information to
communities, which is required by Office of
Management and Budget and Agency procedures. The
Agency also has not identified a responsible office for
maintaining a list of all EPA public websites or
established a process to validate that the required
tracking code is deployed on all public websites. The
lack of web analytics on the EPA's public websites
could result in the loss of valuable web traffic metrics
necessary to improve the communication of vital EPA
environmental data to the public.

Recommendations for corrective action issued to the assistant administrator for Mission Support

1	Identify a single responsible office to create and maintain a list of all of the EPA's public websites.

2	Develop and implement a process, including identifying a responsible office, to periodically validate that the required
General Services Administration Data Analytics Program tracking code is deployed on all public websites.

Percentage of the EPA's public websites without the
required web analytics tracking code. (EPA OIG
image)

Report Addresses: £* EPA mission-related effort. (:> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

25

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

EPA's Fiscal Years 2021 and 2020 (Restated) Consolidated Financial Statements

Report No. 22-F-0007, issued November 15, 2021 ]f^

£** Operating efficiently and effectively
{o} Fulfilling mandated reporting requirements

We rendered an unmodified opinion on the EPA's consolidated financial statements for fiscal years 2021
and 2020 (restated), meaning they were fairly presented and free of material misstatement. We noted the
following instance of noncompliance with laws and regulations: the EPA did not comply with Office of
Management and Budget Circular A-136 form and content requirements for the balance sheet. We also
noted the following significant deficiencies:

• The EPA did not reconcile cash differences with the U.S. Department of the Treasury.

• The EPA did not recognize revenue for the Water Infrastructure Finance and Innovation Act of
2014 fee fund expenses.

• The accounts receivable source documentation was not provided in a timely manner by EPA
regions.

• The Office of the Chief Financial Officer needs to conduct periodic reviews of users" accounts
within the EPA's Contract Payment System.

Recommendations for corrective action issued to the chief financial officer

Timely reconcile EPA cash differences with the U.S. Department of the Treasury.

Update the Water Infrastructure Finance and Innovation Act accounting model to properly recognize earned revenue and
unearned revenue as fee fund expenses are incurred.

Reclassify unearned revenue to earned revenue for Water Infrastructure Finance and Innovation Act fee fund expenses
incurred during fiscal years 2021 and 2020.

Recommendations for corrective action issued to the assistant administrator for Enforcement and Compliance Assurance

Enforce the existing policies and procedures, which includes forwarding accounts receivable source documents to the
Cincinnati Finance Center, in accordance with the time frame provided in the applicable resource management directives.

Implement a system that tracks the dates when accounts receivable source documents need to be submitted and are
submitted by the Office of Enforcement and Compliance Assurance to the Cincinnati Finance Center.

Recommendations for corrective action issued to the chief financial officer

Record the three receivables totaling approximately $8.1 million in the fiscal year 2021 financial statements.

Complete the review of user accounts within the Contract Payment System as outlined in the Office of the Chief Financial
Officer User Access Control Management Plan by the planned milestone. If all the activities are not completed by that date,
the Office of the Chief Financial Officer should create a Plan of Action and Milestones within the Agency Information Security
Repository in accordance with the requirements described in CIO 2150-P-04.2, Information Security - Security Assessment
and Authorization Procedures.

Update the fiscal year 2021 financial statements to comply with Office of Management and Budget's Circular A-136,
specifically, the balance sheet line items.

Report Addresses: £* EPA mission-related effort, f :> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

EPA's Fiscal Year 2020 Fourth-Quarter Compliance with the Digital Accountability and
Transparency Act of 2014

Report No. 22-P-0001, issued November 8, 2021

Compliance with the law; Operating efficiently and effectively
{o} Complying with key internal control requirements (data quality•); Fulfilling mandated reporting requirements
(from FY 2020-2021 EPA Management Challenges report)

The EPA substantially complied with the requirements of the Digital Accountability and Transparency
Act of 2014 and submitted financial and award data to the Department of the Treasury" s Digital
Accountability and Transparency Act Broker on time. While the EPA's fiscal year 2020 fourth-quarter
financial and award data submissions were of "higher" quality, the EPA had not fully implemented the
data standards established by the Office of Management and Budget and the Department of the Treasury.

Recommendations for corrective action issued to the assistant administrator for Mission Support

1

Update policies and procedures to require that Awardee/Recipient Legal Entity Name and Legal Entity Address data
elements match SAM.gov at the time of the award and any award modifications for all contracts and grants. At the time of
any award modification, update the Agency's contracts or grants management system and the Federal Procurement Data
System with any changes to these data elements.

2

Update policies and procedures to require that Award Descriptions be written in plain English and that A ward Descriptions
for modifications explain the purpose of the contract, not merely the purpose of the modification.

3

Update the EPA's grants management system to align with the data standards of the Digital Accountability and
Transparency Act of 2014, including all parts of data elements reported therein, and to allow input only of the acceptable
values outlined for each data element in DATA Act Information Model Schema, Reporting Submission Specification.

4

Update the Catalog of Federal Domestic Assistance Titles on an annual basis, as required in DATA Act Information Model
Schema, Practices and Procedures, Appendix F, "Update Cadence for Data Sources."

5

Provide training to improve consistency of data entry for all data elements, particularly Primary Place of Performance
Address and Award Description.

6

Include all categories for the Non-Federal Funding Amount data element—including the Recipient, State, Local, and Other
Contributions categories—in the EPA's grants management system.

Report Addresses: £* EPA mission-related effort, f :> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

27

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

EPA's Fiscal Years 2020 and 2019 (Restated) Financial Statements for the Pesticides
Reregistration and Expedited Processing Fund

Report No. 22-F-0012, issued December 21, 2021

£» Operating efficiently and effectively

{o} Managing infrastructure funding and business operations

We rendered an unmodified opinion on the EPA's
FYs 2020 and 2019 (restated) Federal Insecticide,
Fungicide, and Rodenticide Act Fund financial
statements, meaning that the statements were fairly
presented and free of material misstatement. During our
analysis of the draft financial statements, we noted the
following material weakness: the EPA materially
misstated the fund's income and expenses from other
appropriations. The EPA corrected the calculation in its
final financial statements. We noted the following
significant deficiency; the EPA needs to improve its
financial statement preparation process.

Pesticide sprayers are used to control weeds and
insects in field crops. (EPA photo)

Recommendations for corrective action issued to the chief financial officer

1 Correct the calculation in the Federal Insecticide, Fungicide, and Rodenticide Act 20-03 on-top adjustment to accurately
capture the amounts for footnote 10, "Income and Expenses from Other Appropriations."

2 Document the control activities and procedures for calculating the income and expense amounts for footnote 10,
"Income and Expenses from Other Appropriations."

3 Develop a plan to strengthen and improve the preparation and management review of the Federal insecticide, Fungicide,
and Rodenticide Act Fund financial statements and adjustments entered into the accounting system so that errors and
misstatements are detected and corrected in a timely manner.

Report Addresses: £ EPA mission-related effort, fo) Top management challenge for EPA. fib Mandatory reporting requirements. Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

EPA's Fiscal Years 2020 and 2019 Financial Statements for the Pesticide
Registration Fund

Report No. 22-F-0014, issued December 21, 2021 |FP*:

Operating efficiently and effectively
> Managing infrastructure funding and business operations

We rendered an unmodified opinion on the EPA's fiscal years 2020 and 2019 Pesticide Registration Fund
financial statements, meaning that the statements were fairly presented and free of material misstatement.
During our analysis of the draft financial statements, we noted the following material weakness: the EPA
materially misstated the PRIA income and expenses from other appropriations. The EPA corrected the
calculation in its final financial statements. We noted the following significant deficiency: the EPA needs
to improve its financial statement preparation process.

Recommendations for corrective action issued to the chief financial officer

1 Correct the calculation in the Pesticide Registration Improvement Act 20-04 on-top adjustment to accurately capture the
amounts for footnote 10, "Income and Expenses from Other Appropriations."

2 Document the control activities and procedures for calculating the income and expense amounts for footnote 10, "Income
and Expenses from Other Appropriations."

3 Develop a plan to strengthen and improve the preparation and management review of the Pesticide Registration
Improvement Act Fund financial statements and adjustments entered into the accounting system so that errors and
misstatements are detected and corrected in a timely manner.

Report Addresses: £* EPA mission-related effort, f :> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

EPA's Fiscal Years 2020 and 2019 Hazardous Waste Electronic Manifest System Fund
Financial Statements

Report No. 22-F-0015, issued December 29, 2021

£* Operating efficiently and effectively

Managing infrastructure funding and business operations

We rendered a qualified
opinion on the EPA's
FYs 2020 and 2019
Hazardous Waste
Electronic Manifest
System Fund financial
statements, meaning
that, except for material
differences in accounts
receivable and earned
revenue, the FY 2020
financial statements
were fairly presented.

We noted the

following material weaknesses: the EPA continued to make errors in its financial statement preparation
process and does not have adequate internal control over accounts receivable and earned revenue. We also
noted the following significant deficiency: the EPA misstated its appropriated balances.

Recommendations for corrective action issued to the chief financial officer

1 In coordination with the assistant administrator for Land and Emergency Management, enhance internal controls over
accounting for expenses recorded under fund codes so that appropriation balances are accurate. Specifically, the EPA
needs to implement preventative controls, so fund expenses are properly coded when processed, and implement
detective controls at the fund level to ensure fee-based expenses and appropriations-based expenses are properly
segregated, reconciled, and recorded in the general ledger.

2 Correct the expenses recorded in excess of appropriated balances.

Hazardous Waste Hazardous Waste Hazardous Waste

Generation Transportation Disposal

The EPA collects user fees to cover the costs of operating the Hazardous Waste
Electronic Manifest System, which tracks off-site shipments of hazardous waste
from their points of generation to their ultimate destinations. (EPA photos)

Report Addresses: £ EPA mission-related effort, fo) Top management challenge for EPA. fib Mandatory reporting requirements. Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

The EPA Lacks Documented Procedures for Detecting and Removing Unapproved
Software on the Agency's Network

Report No. 22-E-0028, issued March 30, 2021

Compliance with the law; Operating effectively and efficiently
( '? Protecting information technology and systems against cyberthreats

We found that the EPA achieved a maturity level of Level 3 (Consistently Implemented) for the five
security functions and nine domains outlined in the FY 2021 Inspector General Federal Information
Security Modernization Act of 2014 (FISMA) Reporting Metrics. This means that the EPA consistently
implemented its information security policies and procedures, but quantitative and qualitative
effectiveness measures are lacking. We also identified that the EPA has deficiencies in documenting
software management procedures for detecting and removing nonbase software, which is software that is
not part of the standard Agency package. The Agency has developed a software triage team that meets
regularly to discuss unapproved software found on the EPA's network.

Recommendations for corrective action issued to the assistant administrator of Mission Support

1 Develop and document procedures for detecting and removing unapproved software on the Agency's network, to include
time frames for removal, risk classifications, and identification of software collecting privacy data.

2 Develop and provide training on the Agency's processes for detecting and removing unapproved software to users with
privileges to install software on the EPA's network.

Hotline Contacts

Report Initiated via the OIG Hotline

Hotline: EPA Is Taking Steps to Update Its Federal Radiation Guidance

Report No. 22-E-0016, issued January 6, 2022

Operating efficiently and effectively
[ '? Safeguarding scientific integrity

The OIG Hotline received a complaint alleging that the EPA is not following the best-available science
regarding low-dose radiation because it uses the linear no-
threshold model to inform its radiation guidance. Our review,
however, found that the EPA updates its radiation guidance to
incorporate new scientific data in accordance with its strategic
plans and annual priority goals. In addition, the EPA's use of
the linear no-threshold model for radiation guidance is based on

findings and recommendations by national and international authoritative bodies. We issued no
recommendations.

The EPA bases its radiation guidance on the
linear no-threshold model, which assumes
that ionizing radiation is always harmful
and that there is no threshold amount
below which radiation exposure is safe.

Report Addresses: £* EPA mission-related effort, f :> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

U.S. Chemical Safety and Hazard Investigation Board

Contractor-Produced Report: U.S. Chemical Safety and Hazard Investigation Board
Independent Auditor's Report on Compliance with the Digital Accountability and
Transparency Act of 2014 Submission Requirements for Fiscal Year 2021

Report No. 22-P-0002, issued November 8, 2021

An OIG contractor, Allmond & Company, found that the CSB's fiscal year 2020 third-quarter financial
and award data submitted under the Digital Accountability and Transparency Act of 2014 were of
"excellent" quality. In addition, Allmond & Company found that the CSB complied with the Act's
reporting requirements of completeness and timeliness, and its internal control over the Act's submission
were effective. No recommendations were issued to the CSB.

Contractor-Produced Report: U.S. Chemical Safety and Hazard Investigation Board
Fiscal Years 2021 and 2020 Financial Statement Audit

Report No. 22-F-0005, issued November 15, 2021

An OIG contractor, Allmond & Company, rendered an unmodified opinion on the CSB's financial
statements for FYs 2021 and 2020, meaning that the statements were fairly presented and free of material
misstatements. Allmond & Company did not identify any instances of noncompliance with applicable
laws, regulations, contracts, and grant agreements or deficiencies in internal control over financial
reporting that would be considered a material weakness. There were no recommendations issued to the
CSB.

U.S. Chemical Safety and Hazard Investigation Board's Compliance in Fiscal Year 2021
with Improper Payments Legislation and Guidance

Report No. 22-E-0020, issued March 15, 2022

We evaluated and found the CSB FY 2021 fully compliant with improper payment legislation and
guidance. In addition, the CSB had not noted any programs that were susceptible to significant improper
payments. The CSB made approximately $7.2 million in payments during the fiscal year that were subject
to improper payment requirements and reported improper payments totaling approximately $345. We did
not issue any recommendations to the CSB.

Report Addresses: £* EPA mission-related effort, f :> Top management challenge for EPA. Mandatory reporting requirements. S Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Contractor-Produced Report: CSB Is at Increased Risk of Losing Significant Data and Is
Vulnerable to Exploitation

Report No. 22-E-0025, issued March 29, 2022

Needs Improvement

Configuration
Management

Needs Improvement

Contingency
Planning

Level 1: Ad hoc
Level 2: Defined

Level 3: Consistently Implemented

Level 4. Managed and Measurable
Level 5: Optimized

SB & Company assessed the effectiveness
of the CSB's information security program
at "Level 2, Defined," which means its
policies, procedures, and strategies for its
information security program are
fomialized and that its strategies are
documented but not consistently
implemented. SB & Company also found
that the CSB does not have a Vulnerability
Disclosure Policy to protect its public
website, which increases the risk that
vulnerabilities identified by external
stakeholders are not being reported in a
timely manner. SB & Company also
reported a finding previously
communicated by the OIG in Report No. 21-
E-0071, CSB's Information Security Program
Is Not Consistently Implemented;

Improvements Are Needed to Address Four Weaknesses, that related to the CSB's discontinuation of off-
site storage of tape backups during the coronavirus pandemic, which could lead to data being permanently
lost after an incident.

The CSB's information security program is not consistently
implemented. Improvements are needed in configuration
management and contingency planning. (EPA OIG image)

Recommendations for corrective action issued to the CSB chairperson

1 Develop and deploy a Vulnerability Disclosure Policy to formalize security feedback and to comply with Office and
Management and Budget M-20-32 and U.S. Department of Homeland Security Binding Operational Directive 20-01.

2 Immediately restore off-site storage of backup tapes and implement a strategy that will ensure that the Agency consistently
stores backups of its systems at an off-site location. Additionally, explore alternative methods of off-site backup that can be
performed automatically and do not require physical intervention by CSB personnel, such as storing backups in the cloud.

Report Addresses: £ EPA mission-related effort, fo) Top management challenge for EPA. fib Mandatory reporting requirements. Follow-up report.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

2.2 Investigative Work

Significant Investigations

EPA Employee Arrested for Child Pornography

On March 29, 2022, an EPA GS-13 employee was arrested and charged with one count of possession of
child pornography in the U.S. District Court, District of New Jersey.1 The EPA employee allegedly
accessed child pornography on an EPA computer using a web browser that was not authorized to be
installed on EPA computers. If convicted, the employee faces a maximum term of 20 years in prison and
a $250,000 fine.

This investigation was conducted jointly with the Department of Homeland Security's Homeland Security
Investigations.

Individuals Sentenced for Conspiracy to Defraud Companies

On December 2, 2021, three individuals were sentenced in the U.S. District Court, Southern District of
Florida, for their roles in a conspiracy to defraud companies by issuing worthless bonds to insure
large-scale construction projects. One individual of Boca Raton, Florida, was sentenced to 72 months in
prison; one individual of Saratoga Springs, New York, was sentenced to 46 months in prison; and one
individual of Las Vegas was sentenced to 24 months in prison. On November 16, 2021, one additional
individual of Rancho Mirage, California, was sentenced to 54 months in prison. Each defendant was also
sentenced to three years of supervised release, ordered to pay over $2.6 million in restitution to victims of
the fraud, and ordered to forfeit $1,242,417. From approximately March through December 2015, the
defendants unlawfully enriched themselves by issuing various performance and payment bonds, a type of
insurance required on major construction contracts, from companies that were the beneficiaries of both
private and federal government contractors. During the course of the fraud, one of the defendants, acting
as a so-called "individual surety," pledged over $30 million in assets to companies working on large-scale
infrastructure and other construction projects, including EPA projects. There were no such assets—only
worthless securities that the defendants referred to as "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.

Kentucky Businessman Sentenced for Wire Fraud

On December 13, 2021, a Lexington, Kentucky, businessman was sentenced to six months in federal
prison, six months of home detention, and three years of supervised release by the U.S. District Court,
Eastern District of Kentucky, for wire fraud and conspiracy to commit wire fraud. According to the
individual's plea agreement, from December 2017 through May 2019, the individual submitted false
reports to the EPA to justify payments totaling $ 100,000 from an EPA research grant. Also, according to
the individual's plea agreement, 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 Department of Defense
OIG Defense Criminal Investigative Service.

1 GS stands for General Schedule.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Former Tribal Employee Sentenced for Bank Fraud

On October 12, 2021, a former employee of the Table Bluff Wiyot Tribe was sentenced to 21 months in
prison, followed by three years of supervised release, and ordered to pay approximately $95,000 in
restitution to the tribe after pleading guilty in federal court to six counts of bank fraud. From 2013
through 2015, the former employee embezzled more than $100,000 of tribe funds to pay off personal
credit cards, pay utilities, and purchase rodeo equipment. The former employee was the tribe's finance
officer and had full access to the accounts and federal grant money provided to the tribe. During the
relevant period, the tribe received federal grant monies from the EPA, the U.S. Department of the Interior,
and the U.S. Department of Housing and Urban Development.

This investigation was conducted jointly with the Department of the Interior OIG and Department of
Housing and Urban Development OIG.

Other Investigation of Note

Alleged Inappropriate Communication with Defendant in Enforcement Action

An EPA Schedule C employee allegedly violated a Department of Justice confidentiality agreement by
providing sensitive information to a municipal defendant in an EPA enforcement case. EPA staff
interviewed could not identify any incidents where sensitive enforcement information was disclosed to
the defendant. The employee admitted to having some direct communications with the defendant's
consultant but claimed to defer all substantive case inquiries to the assigned Department of Justice
attorney. The investigation confirmed that the employee would often notify the Department of Justice
attorney of these conversations via email. The employee's direct talks with the consultant did not violate
the applicable confidentiality agreement or Agency enforcement guidance on communications with
outside parties. The investigation did not substantiate the allegation.

Management Implication Reports

Allowing Remote Access to Threat Actors

Issued December 9, 2021

We identified a critical vulnerability concerning software installations on EPA-furnished computers
whereby third-party threat actors could access these computers and, by proxy, the EPA network. While
the OIG initiated investigations into specific incidents stemming from this vulnerability, we issued this
management implication report to the EPA's Office of Mission Support, which is responsible for
information security oversight, so it could take the necessary steps to ensure that EPA networks, systems,
and information are safeguarded.

Annual Performance Rating of Senior Executive Service Employees at the CSB

Issued December 28, 2021

For the 2020 appraisal period, the CSB violated Office of Personnel Management regulations and its
internal procedures when it failed to provide final annual performance ratings to two Senior Executive
Service employees. As a result, these employees could not be considered for pay increases or
performance awards. One of these SES employees also did not receive a signed performance plan or an
initial or final annual performance rating for the 2021 appraisal period. In addition, the CSB did not
establish a Performance Review Board for SES employees, as required, and the CSB chairperson
attempted to delegate performance review responsibilities for the affected performance periods to the
acting managing director, even though there was no authority for such delegation. When the acting
managing director subsequently conducted a performance review with one SES employee, the CSB

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

violated the statutory moratorium on SES performance appraisal actions following the beginning of a new
presidential administration.

In response to this management implication report, the CSB completed initial ratings for both affected
SES employees for performance years 2020 and 2021. The CSB also established a Performance Review
Board. As of March 31, 2022, the CSB had not yet finalized the 2020 and 2021 SES performance ratings.
According to the CSB, its new director of Human Resources is working with the Office of Personnel
Management and the CSB's Office of General Counsel to address these matters.

Inappropriate Manipulation of Air Filter Data by Office of Research and Development
Contractor

Issued February 18, 2022

We found that an Office of Research and Development laboratory contractor inappropriately manipulated
air filter data and failed to follow EPA and project guidance that resulted in 95 air filter samples, used to
provide oversight of the PM2.5 Air Monitoring Network, being rendered unusable. We agree with the
findings of an audit conducted by the EPA's Office of Air Quality Planning and Standards, which found
that the contractor made mistakes when originally weighing the data and manipulated the data to make the
data appear valid. The audit also found that the contractor did not use the Excel spreadsheet provided by
the EPA to report the data. If that spreadsheet had been used, the contractor could have realized the
mistakes and reweighed the air filter samples in a timely manner. As a result, the air filter data could not
be used because of data quality issues.

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. For the reporting period ending March 31, 2022, the Office
of Investigations issued two Reports of Investigation and received no responses outside the 60-day
window.

Agency and OIG Reports of Investigation

Reports of Investigation
with findings issued
10/1/21-3/31/22

Responses received or pendina after 60-day response period

To EPA

To OIG

Received
from EPA*

Pending from
EPA, as of
3/31/22

Received from
OIG*

Pending from
OIG, as of 3/31/22

2

0

0

0

0

0

* The EPA or the OIG will or will not take an action or will conduct a supplemental investigation.

36

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

2.3 Instances of Whistleblower Retaliation
and Interference with Independence

Whistleblower Retaliation

Section 5(a)(20) of the Inspector General Act requires a detailed description of any instances of
whistleblower retaliation noted by the OIG. This requirement includes reporting information about any
officials found to have engaged in retaliation and the consequences the EPA or the CSB imposed to hold
such officials accountable. There were no whistleblower retaliation cases closed within the semiannual
period ending March 31, 2022. 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 EPA or
the CSB to interfere with the independence of the OIG. This includes "budget constraints designed to
limit the capabilities of the [OIG]" and incidents in which the EPA or the CSB "has resisted or objected to
oversight activities of the [OIG] or restricted or significantly delayed access to information/' Similarly,
section 5(a)(5) requires that the OIG report any instances where the OIG informed the EPA administrator
or CSB chairperson that information or assistance was unreasonably refused or not provided to the OIG.

Generally, we will report on incidents responsive to sections 5(a)(21) and 5(a)(5) in the semiannual report
covering the period during which the relevant review was completed or the relevant investigation was
closed. There were no reviews completed or investigations closed involving attempts by the EPA or the
CSB to interfere with the OIG's independence within the semiannual period ending March 31, 2022.

37

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

2.4 Single Audit Work

In accordance with the Single Audit Act of 1984, as amended, and Office of Management and Budget
guidance, nonfederal entities that expend $750,000 or more in federal funds are required to have a
comprehensive annual audit of their financial statements and to 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 independent, nonfederal auditors. 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.
During the semiannual reporting period ending March 31, 2022, we issued 22 single audit memorandums
to the EPA. The issued memorandums contained 33 findings that pertained to various EPA programs, but
another federal agency or pass-through entity, such as a state, was responsible for resolving the findings.
None of the reported findings required EPA action.

38

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SECTION 3:
STATISTICAL DATA

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

3.1 Audit Report Resolution

For semiannual period ending March 31, 2022:

OIG-issued reports with questioned costs

Report category

Number of
reports

Questioned
costs*

(in thousands)

Unsupported
costs

(in thousands)

A. For which no management decision was made by
October 1, 2021

17

$124

$0

B. New reports issued during period

22

$0

$0

Subtotals (A + B)

39

$124

$0

C. For which a management decision was made during
the reporting period:

29



(i) Dollar value of disallowed costs

10

$107

$0

(ii) Dollar value of costs not disallowed

$17

$0

D. For which no management decision was made by
March 31, 2022

$0

$0

* Costs may be rounded. Questioned costs include unsupported costs.

OIG-issued reports with recommendations that funds be put to better use

Report category

Number of
reports

Funds to put
to better use*

(in thousands)

A. For which no management decision was made by October 21, 2021

17

$0

B. New reports issued during the reporting period

22

$54,723

Subtotals (A + B)

39

$54,723

C. For which a management decision was made during the reporting period:

29

(i) Dollar value of recommendations from reports that were
agreed to by management



$8,145

(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, 2022

$46,578

* Costs may be rounded.

40

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

3.2 Summary of Investigative Results

For semiannual period ending March 31, 2022:

Summary of investigative activity

Cases open as of October 1, 2022*

154

Cases opened during period

45

Cases closed during period

64

Cases open as of March 31, 2022

135



Complaints open as of October 1, 2021*

27

Complaints opened during period

55

Complaints closed during period

43

Complaints open as of March 31, 2022

39

* Adjusted from prior period.







Results of criminal and civil actions









EPA OIG only

Joint*

Total

Criminal indictments/informations/complaints**

0

3

3

Convictions***

0

7

7

C i vi I j u d g me nts/sett le me nts/fi ling s****

0

0

0

Criminal fines and recoveries

$0

$2,742,191

$2,742,191

Civil recoveries

$0

$0

$0

Prison time

0 months

76 months

76 months

Prison time suspended

0 months

23 months

23 months

Home detention

0 months

6 months

6 months

Probation

0 months

180 months

180 months

Community service

0 hours

0 hours

0 hours

* With one or more other federal agencies.

** Sealed indictments are not included in this category.

*** The term "convictions" comprises finalized convictions (those for which sentencing is completed) filed during the
reporting period.

**** For the fall 2021 semiannual period, Report No. EPA-350-R-21-002. Semiannual Report to Congress: April 1,
2021-September 30, 2021, the number of civil judgement/settlements/filings should have been one.

Administrative actions



EPA OIG only

Joint*

Total

Suspensions

5

12

17

Debarments

0

3

3

Other administrative actions

11

3

14

Total

16

18

34

Administrative recoveries

$0

$640,638

$640,638

Cost savings

$174,550

$0

$174,550

* With one or more other federal agencies.

41

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Semiannual Report to Congress	October 1, 2021-March 31, 2022

Summary of investigative reports issued and referrals for prosecution*

Number of investigative reports/referrals issued**

2

Number of persons referred to U.S. Department of Justice for criminal prosecution

14

Number of persons referred to state and local authorities for criminal prosecution

2

Number of criminal indictments and informations resulting from any prior referrals to
prosecutive authorities

0

* 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."

Subjects of employee integrity investigations



Political
appointee

SES

GS-15

GS-14
and
below

Misc.*

Total

Pending as of October 1, 2021

10

4

9

9

16

48

Opened

0

1

1

5

0

7

Closed

2

1

0

7

3

13

Pending as of March 31, 2022**

6

5

10

8

14

43

Note 1: GS stands for General Schedule.

Note 2: 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).

* Refers to investigations for cases related to individuals who fall outside the categories outlined in this table, such as
former employees and federal contractors.

** Pending numbers as of March 31, 2022, may not add up due to investigative developments resulting in subjects
being added or changed.

The chart below provides the number of individuals, by grade, who are the subject of employee
integrity investigations.

Subjects of employee integrity investigations: number of individuals by grade

6 subjects

14 subjects

5 subjects

Political Appointee
Senior Executive Service
GS-15

GS-14 and below
Miscellaneous*

10 subjects

8 subjects

Note: GS stands for General Schedule. (EPA OIG image)

*Miscellaneous employees include federal contractors, nongovernment employees, and former government
employees.

42

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APPENDIXES

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Appendix 1—Reports Issued

Section 5(a)(6) of the Inspector General Act 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 Act also requires a listing of the dollar value of questioned costs,
including unsupported costs, and the dollar value of recommendations that funds be put to better use.

Report
number

Report title

Date

Ineligible

Questioned costs
Unsupported

Unreasonable

Potential
monetary
benefits

EVALUATIONS IN ACCORDANCE WITH











QUALITY STANDARDS FOR INSPECTION AND EVALUATION











22-E-0008

Total National Reported Clean Air Act Compliance-Monitoring

11/17/21

$0.00

$0.00

$0.00

$0.00



Activities Decreased Slightly During Coronavirus Pandemic, but State













Activities Varied Widely











22-E-0009

Authorized State Flazardous Waste Program Inspections and

12/1/21

0.00

0.00

0.00

0.00



Operations Were Impacted During Coronavirus Pandemic











22-E-0011

EPA Has Not Performed Agencywide Risk Assessments, Increasing

12/15/21

0.00

0.00

0.00

0.00



the Risk of Fraud, Waste, Abuse, and Mismanagement











22-E-0016

Hotline: EPA Is Taking Steps to Update Its Federal Radiation

1/6/22

0.00

0.00

0.00

0.00



Guidance











22-E-0017

EPA's Title V Program Needs to Address Ongoing Fee Issues and

1/12/22

0.00

0.00

0.00

0.00



Improve Oversight











22-E-0020

U.S. Chemical Safety and Hazard Investigation Board's Compliance in

3/15/22

0.00

0.00

0.00

0.00



Fiscal Year 2021 with Improper Payments Legislation and Guidance











22-E-0025

CSB Is at Increased Risk of Losing Significant Data and Is Vulnerable

3/29/22

0.00

0.00

0.00

0.00



to Exploitation











22-E-0026

The EPA Needs to Develop a Strategy to Complete Overdue Residual

3/30/22

0.00

0.00

0.00

0.00



Risk and Technology Reviews and to Meet the Statutory Deadlines for













Upcoming Reviews











22-E-0027

The EPA Did Not Follow Agency Policies in Managing the Northbridge

3/31/22

0.00

0.00

0.00

0.00



Contract and Potentially Violated Appropriations Law











22-E-0028

The EPA Lacks Documented Procedures for Detecting and Removing

3/30/22

0.00

0.00

0.00

0.00



Unapproved Software on the Agency's Network













SUBTOTAL = 10



$0.00

$0.00

$0.00

$0.00

FINANCIAL AUDITS IN ACCORDANCE WITH











GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS











22-F-0005

Contractor-Produced Report: U.S. Chemical Safety and Hazard

11/15/21

$0.00

$0.00

$0.00

$0.00



Investigation Board Fiscal Years 2021 and 2020 Financial













Statement Audit











22-F-0007

EPA's Fiscal Years 2021 and 2020 (Restated) Consolidated

11/15/21

0.00

0.00

0.00

8,090,000.00



Financial Statements











22-F-0012

EPA's Fiscal Years 2020 and 2019 (Restated) Financial Statements

12/21/21

0.00

0.00

0.00

0.00



for the Pesticides Reregistration and Expedited Processing Fund











22-F-0014

EPA's Fiscal Years 2020 and 2019 Financial Statements for the

12/21/21

0.00

0.00

0.00

0.00



Pesticide Registration Fund











22-F-0015

EPA's Fiscal Years 2020 and 2019 Hazardous Waste Electronic

12/29/21

0.00

0.00

0.00

0.00



Manifest System Fund Financial Statements













SUBTOTAL = 5



$0.00

$0.00

$0.00

$8,090,000.0

44

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Questioned costs

Report
number

Report title

Date

Ineligible Unsupported Unreasonable

$0.00
0.00

0.00
0.00
0.00
0.00
0.00

$0.00

Potential
monetary
benefits

PERFORMANCE AUDITS IN ACCORDANCE WITH
GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS

22-P-0001 EPA's Fiscal Year 2020 Fourth-Quarter Compliance with the Digital	11/8/21	$0.00	$0.00

Accountability and Transparency Act of 2014
22-P-0002 Contractor-Produced Report: U.S. Chemical Safety and Hazard	11/8/21	0.00	0.00

Investigation Board Independent Auditor's Report on Compliance with
the Digital Accountability and Transparency Act of 2014 Submission
Requirements for Fiscal Year 2021
22-P-0010 EPA Generally Adheres to Information Technology Audit Follow-Up	12/8/21	0.00	0.00

Processes, but Management Oversight Should Be Improved
22-P-0013 EPA Established a Web Management Program, but Improvements	12/20/21	0.00	0.00

Are Needed in Deploying Web Analytics
22-P-0018 EPA Should Consistently Track Coronavirus Pandemic-Related Grant 2/22/22	0.00	0.00

Flexibilities and Implement Plan for Electronic Grant File Storage
22-P-0019 EPA Needs to Complete Implementation of Religious Compensatory	3/7/22	0.00	0.00

Time Training for Supervisors and Employees
22-P-0033 Brownfields Program-Income Monitoring Deficiencies Persist Because 3/31/22	0.00	0.00

the EPA Did Not Complete All Certified Corrective Actions

SUBTOTAL = 7	$0.00	$0.00

$0.00
0.00

0.00
0.00
0.00
54,787.00
46,578,205.00

$46,632,992.00

TOTAL REPORTS ISSUED = 22

$0.00 $54,722,992.00

45

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Appendix 2—Delayed EPA Management Decisions and Comments;
Management Decisions with Which OIG Disagrees

For Reporting Period Ending March 31, 2022

Section 5(a)(10)(A) of the Inspector General Act 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. For the purposes of the semiannual report,
the Act defines "management decision" to mean "the evaluation by the management of an establishment of the findings and
recommendations included in an audit report and the issuance of a final decision by management concerning its response to
such findings and recommendations, including actions concluded to be necessary." The Federal Acquisition Streamlining Act
of 1994, as amended, requires the head of each agency to make management decisions on all findings and recommendations
set forth in an OIG audit report within six months of the final report being issued. In the "Reports Without Management
Decision Within Six Months" section in this appendix, we report on the seven audits and evaluations containing
recommendations for which no management decision was made within six months of final report issuance and that were still
pending a management decision as of March 31, 2022.

Section 5(a)(10)(B) of the Inspector General Act 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 were five reports for which we did not receive a
response within a 60-day period that ended during this semiannual period. For two of these reports, we received a response
on the first business day after the 60-day period due to confusion stemming from the 60-day period ending on a weekend. We
did not include these reports in this appendix. We summarize the remaining three reports in the "Reports for Which No
Comment Was Received Within 60 Days" section in this appendix.

Section 5(a)(12) of the Inspector General Act of 1978 requires that the semiannual report contain information concerning any
significant management decision with which the inspector general disagrees. In this semiannual reporting period, there was
one EPA management decision regarding one recommendation with which the inspector general continued to disagree. We
originally reported this disagreement in Semiannual Report to Congress: April 1, 2021-September 30, 2021 (Report
No. EPA-350-R-21 -002). We summarize the status of this disagreement in the "Significant Management Decisions with Which
OIG Disagrees" section in this appendix.

Reports Without Management Decision Within Six Months

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 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.

46

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report No. 21-P-0129. EPA Should Conduct New Residual Risk and Technology Reviews for Chloroprene- and
Ethylene Oxide-Emitting Source Categories to Protect Human Health, May 6, 2021

Summary: Results from the EPA's modeling and monitoring efforts indicate that people in some areas of the country may be
exposed to unacceptable health risks from chloroprene and ethylene oxide emissions. Despite the EPA classifying
chloroprene as a likely human carcinogen in 2010 and ethylene oxide a carcinogen in 2016, the EPA has not conducted new
residual risk and technology reviews for most types of industrial sources that emit chloroprene or ethylene oxide. New risk and
technology reviews should be conducted because the EPA issued new risk values for chloroprene and ethylene oxide in 2010
and 2016, respectively, to reflect their potent carcinogenicity, as found in newer scientific evidence. The EPA should exercise
its discretionary authority to conduct new residual risk reviews under the Clean Air Act whenever new data or information
indicates an air pollutant is more toxic than previously determined. Use of such discretionary authority is consistent with the
Agency's position stated in its April 2006 commercial sterilizer residual risk and technology review rule.

We recommended that the assistant administrator for Air and Radiation (1) develop and implement an internal control process
with specific criteria to determine whether and when new residual risk reviews of existing National Emission Standards for
Hazardous Air Pollutants and uncontrolled emission sources are needed to incorporate new risk information; (2) conduct new
residual risk reviews for Group I polymers and resins, synthetic organic chemical manufacturing industry, polyether polyols,
commercial sterilizers, and hospital sterilizers; (3) revise the National Emission Standards for Hazardous Air Pollutants for
chemical manufacturing area sources to regulate ethylene oxide and conduct a residual risk review; and (4) conduct overdue
technology reviews for the source categories listed in Recommendations 2 and 3. At report issuance, three of the
recommendations were unresolved, and one was resolved with corrective actions pending.

Resolution Status: The Agency provided a formal written response dated July 7, 2021. Based on the information and
supporting documentation provided, the OIG did not agree with the Agency's planned corrective actions. The OIG issued a
memorandum on August 5, 2021, advising the Agency that the three recommendations remain unresolved. Resolution efforts
are underway for these unresolved recommendations.

Office of Air and Radiation; Office of Policy

Report No. 21-E-0125. Concerns About the Process Used for the SAFE Vehicles Rule Demonstrate the Need for a
Policy on EPA's Role in Joint Rulemakings, April 20, 2021

Summary: Although the EPA and the National Highway Traffic Safety Administration jointly issued the SAFE Vehicles Rule, the
agencies' technical personnel did not collaborate during final rule development, undercutting the joint character of the
rulemaking. Furthermore, the EPA did not follow its established process for developing regulatory actions, did not complete
major Action Development Process milestones, and did not document who decided to skip these milestones and why. In
addition, the National Highway Traffic Safety Administration performed all major technical assessments for the rule, while the
role of EPA technical personnel was limited to providing advisory input for some aspects of the analysis. The EPA did not
conduct a separate analysis related to executive orders on the impacts of modified standards on vulnerable populations. The
then-EPA administrator decided that the SAFE Vehicles Rule would be based solely on National Highway Traffic Safety
Administration modeling and analysis and that the National Highway Traffic Safety Administration would draft the majority of the
preamble text. One senior EPA official cited the National Highway Traffic Safety Administration's statutory deadline for
establishing its standards as the impetus for its lead role in developing the rulemaking. This approach bypassed aspects of the
EPA's normal rulemaking process. It also diverged from the more collaborative precedent set by the agencies' prior joint
rulemakings, as well as circumvented Office of Air and Radiation technical personnel feedback prior to the final rule being
circulated for interagency review. Furthermore, technical personnel were confused about the proper contents of the docket, and
congressional and tribal stakeholders raised transparency concerns after the final rule was published. While joint rulemaking is
infrequent, the process should be improved by clearly defining the EPA's responsibilities when working with a partner agency.

We recommended that the Office of Air and Radiation docket its interpretation of whether the EPA docket for Clean Air Act
joint rulemaking actions reflects that the partner agency is an "other agency" for purposes of the Act's docketing requirements.
We recommended that the Office of Air and Radiation and the general counsel docket any comments generated by the EPA
and the National Highway Traffic Safety Administration during interagency review from January 14, 2020, to March 30, 2020.
We recommended that the Office of Air and Radiation and the Office of Policy document decisions regarding Action
Development Process milestones and determine the EPA's role in joint rulemakings, including addressing executive orders on
children's health, tribal consultation, and environmental justice. One recommendation is resolved with corrective actions
pending. Three recommendations issued to the Office of Air and Radiation and one recommendation issued to the Office of
Policy are unresolved.

Status: While we have corresponded with the Agency and met with Agency staff to discuss their planned corrective actions in
response to this report, the EPA had not provided an official written response to the OIG as of March 31, 2022. Resolution
efforts are underway for the unresolved recommendations.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Office of Enforcement and Compliance Assurance

Report No. 21-P-0132. Resource Constraints, Leadership Decisions, and Workforce Culture Led to a Decline in
Federal Enforcement, May 13, 2021

Summary: EPA-led compliance monitoring activities, enforcement actions, monetary enforcement results, and environmental
benefits generally declined nationwide from FY 2007 through FY 2018. While annual enforcement measures, such as penalty
dollars assessed or commitments to clean up pollution, declined, the results varied year-to-year based on the conclusion of
large cases. The decline in enforcement resources was a primary driver of the observed declining enforcement trends,
resulting in fewer compliance monitoring activities and concluded enforcement actions. EPA leadership also made strategic
decisions that affected enforcement trends, such as focusing limited resources on the most serious cases and, in 2017,
emphasizing deference to state enforcement programs and compliance assistance. From 2006 through 2018, growth in the
domestic economy and new laws increased the size and level of activity in key sectors that the EPA regulated, but the EPA's
capacity to meet that need decreased. The EPA's annual enforcement reports do not provide context for understanding the
EPA's enforcement accomplishments and the impact these enforcement activities have on human health and the environment.
For example, the EPA does not measure or report data for compliance-assistance activities, informal enforcement actions, and
noncompliance rates. The EPA could also provide additional information that would provide context about the scope of
activities captured by its enforcement measures, such as the type of inspections conducted, and the types and toxicity of
pollutants removed from the environment.

We recommended that the EPA's assistant administrator for Enforcement and Compliance Assurance complete a workforce
analysis to assess the Agency's capacity to maintain a strong enforcement field presence that protects human health and the
environment and to integrate the results of this analysis into the Office of Enforcement and Compliance Assurance's strategic
and annual planning processes. These two recommendations were unresolved at report issuance. We made six
recommendations about how the EPA can improve the way it reports enforcement achievements. The recommendation to
measure the Agency's compliance assistance and informal enforcement activities was also unresolved at report issuance.

Resolution Status: The Agency provided a response to the final report on July 12, 2021, which outlined the Agency's planned
corrective actions and estimated milestone dates for the three unresolved recommendations issued in the subject OIG report.
Based on the information and supporting documentation provided in the July 2021 memorandum, the OIG did not agree with
the Agency's planned corrective actions for the three unresolved recommendations. As a result, we continue to consider the
three recommendations unresolved. The OIG issued a memorandum on August 18, 2021, advising the Agency to follow the
dispute resolution process. As part of the dispute resolution process, the chief financial officer mediated a resolution
discussion. However, the recommendations remain unresolved.

Report No. 21-P-0114. 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, March 29, 2021

Summary: 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
Superfund program and the Resource Conservation and Recovery Act program or transferred between the two programs.

We issued recommendations to the assistant administrator for Land and Emergency Management and the assistant
administrator for Enforcement and Compliance Assurance to develop controls to improve oversight of units with waste in
place. The Agency agreed with three of our recommendations, while it did not agree with the other three, which were
considered unresolved at final report issuance.

Resolution Status: The Agency provided a memorandum dated May 27, 2021, which outlined the Agency's planned corrective
actions and estimated completion dates for the three unresolved recommendations issued in the subject OIG report. Based on
the information and supporting documentation provided, two of the recommendations are now resolved. The OIG did not agree
with the Agency's planned corrective action for one of the recommendations. As a result, we continue to consider one
recommendation issued to the Office of Enforcement and Compliance Assurance as unresolved. The OIG issued a
memorandum on November 2, 2021, advising the Agency to follow the dispute resolution process. The Office of the Chief
Financial Officer is scheduling a resolution meeting with the OIG, the Office of Land and Emergency Management, and the
Office of Enforcement and Compliance Assurance.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Office of Land and Emergency Management

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, 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. The recommendations issued to the Region 6
regional administrator and the associate administrator for Public Affairs are resolved. The three recommendations issued to
the assistant administrator for Land and Emergency Management remain unresolved.

Resolution Status: The EPA provided a formal response on February 28, 2020. On August 17, 2021, the Office of Land and
Emergency Management provided revised corrective actions. Resolution efforts continue.

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 the
course of this follow-up evaluation, we found that the EPA's July 2018 report to Congress did not fully meet the reporting
requirements of the BEACH Act and the Plain Writing Act of 2010. The report also did not adhere to federal internal control
principles. Specifically:

• The report did not evaluate federal and local efforts to implement the BEACH Act.

• Although the report listed 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 did 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 provided a second response on July 23, 2021, communicating that it planned to
work with staff in the Office of Congressional and Intergovernmental Relations to reach out to Congress for input on the EPA's

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

BEACH Act program. On August 12, 2021, the OIG issued a memorandum to the Agency explaining that the Agency did not
provide corrective actions that meet the intent of the report's recommendations and advised the Agency to follow the dispute
resolution process. Although the recommendations remain unresolved, the Agency informed the OIG that it is drafting its 2022
required report to Congress in a manner that meets the intent of the recommendations.

Total reports issued before reporting period for which no management decision had been made as of
March 31, 2022 = 7

Reports for Which No Comment Was Received Within 60 Days

Office of Air and Radiation; Office of Policy

Report No. 21-E-0125. Concerns About the Process Used for the SAFE Vehicles Rule Demonstrate the Need for a
Policy on EPA's Role in Joint Rulemakings, April 20, 2021

We recommended that the Office of Air and Radiation docket its interpretation of whether EPA docket for Clean Air Act joint
rulemaking actions reflects that the partner agency is an "other agency" for purposes of the Act's docketing requirements. We
recommended that the Office of Air and Radiation and the general counsel docket any comments generated by the EPA and
the National Highway Traffic Safety Administration during interagency review from January 14, 2020, to March 30, 2020. We
recommended that the Office of Air and Radiation and the Office of Policy document decisions regarding Action Development
Process milestones and determine the EPA's role in joint rulemakings, including addressing executive orders on children's
health, tribal consultation, and environmental justice. One recommendation is resolved with corrective actions pending. Three
recommendations issued to the Office of Air and Radiation and one recommendation issued to the Office of Policy are
unresolved.

Status: While we have corresponded with the Agency and met with Agency staff to discuss their planned corrective actions in
response to this report, the EPA had not provided an official written response to OIG as of March 31, 2022. Resolution efforts
are underway for the unresolved recommendations.

Office of the Chief Financial Officer

Report No. 21-P-0265. EPA Needs to Strengthen Oversight of Its Travel Program Authorization and Voucher Approval
Processes, September 30, 2021

Summary: EPA policy and procedures were not always effective in ensuring sufficient oversight of travel card use. We found
that EPA staff did not consistently comply with travel policy requirements. Out of the 31 travel transactions we reviewed, 29, or
about 94 percent, had deviations from policy in travel card use. EPA staff approved authorizations without sufficient
justification of travel policy deviations, processed late vouchers, and reimbursed vouchers for costs that lacked required
documentation. These issues occurred because of (1) travelers' and approvers' unfamiliarity with travel policies, (2) monitoring
weaknesses within the EPA team responsible for overseeing travel approvals, and (3) vague travel procedures in some
instances. As a result, the Agency continues to be at risk from travel payments that could result in the mismanagement or
waste of taxpayer funds.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

We recommended that the chief financial officer assess the feasibility of modifying Concur, the EPA's travel system, to restrict
individuals from bypassing authorization justifications or required voucher receipts; reemphasize, through training or other
methods, the requirement for justifications and documentation; require annual training for all approvers and travelers to certify
that they are knowledgeable about the Federal Travel Regulation and EPA policies; and identify system-monitoring reports for
oversight. We also recommend that the chief financial officer issue policy addendums to (1) require approvers to estimate and
compare the total cost of temporary change of station versus extended temporary duty travel and authorize the one that is
most advantageous for the Agency, cost and other factors considered, and (2) set a predetermined number of days for the
travel card cancellation and closeout process. The EPA agreed with our recommendation to require annual training for
approvers and travelers and initiated the corrective action on January 5, 2021, by implementing an annual training
requirement. We considered that recommendation resolved. The remaining recommendations were unresolved at the time of
report issuance.

Status: The Agency provided a response on December 13, 2021, which outlined the Agency's planned corrective actions and
estimated milestone dates for the three unresolved recommendations issued in the subject OIG report. Based on the
information provided in the memorandum, as well as in a subsequent meeting held on January 5, 2022, and in additional
correspondence sent to us on January 21, 24, and 27, 2022, we agreed with the planned corrective actions and the
recommendations are considered resolved as of February 22, 2022.

Office of Enforcement and Compliance Assurance

Report No. 22-F-0007. EPA's Fiscal Years 2021 and 2020 (Restated) Consolidated Financial Statements, November 15,
2021

Summary: We rendered an unmodified opinion on the EPA's consolidated financial statements for fiscal years 2021 and 2020
(restated), meaning they were fairly presented and free of material misstatement. We issued six recommendations to the chief
financial officer that were resolved at report issuance. Two recommendations issued to the assistant administrator
for Enforcement and Compliance Assurance are unresolved.

Status: The EPA had not provided a formal response regarding the two unresolved recommendations as of March 31, 2022, in
part because the final report's transmittal memorandum incorrectly stated that no final response to the report was required.
The OIG is working with the Agency to obtain a formal response in accordance with our audit resolution procedures.

Total reports issued during the reporting period for which the Agency did not provide a written response
within 60 days, as of March 31, 2022 = 3

Significant Management Decisions with Which OIG Disagrees

Report title,
number, date

Recommendation
(action official)

Potential

cost
savings

OIG's disagreement with
management decision
originally reported

Update

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

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.

(associate deputy administrator)

$0

Fall 2021

The EPA sent a Status Report
memorandum to the OIG on
February 24,2022, stating that
the Agency had completed
initial public outreach for 13 of
16 areas near ethylene oxide-
emitting facilities identified as
not receiving public outreach in
our final report. We continue to
work with the EPA to address
our recommendation.

51

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Appendix 3—Reports with Corrective Action Not Completed

In compliance with the reporting requirements of sections 5(a)(3) and 5(a)(10)(C) of the Inspector General Act, we
are to identify each significant recommendation described in previous semiannual reports on which corrective action
has not been completed, as well as provide 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, including funds that could be put to better use and questioned costs, of the unimplemented
recommendations.

This appendix contains separate tables of unimplemented recommendations for the EPA and the CSB, which were
issued in 59 OIG audit reports from 2008 through March 31, 2022.

There are 156 unimplemented recommendations for the EPA with potential monetary benefits of approximately
$29.7 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 are three unimplemented
recommendations for the CSB, with total potential monetary benefits of $0.

Below is a list of the 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:

DA	Deputy Administrator (within the Office of the Administrator)

ADA	Associate Deputy Administrator (within the Office of the Administrator)

OA	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

OLEM	Office of Land and Emergency Management

OMS2	Office of Mission Support

ORD	Office of Research and Development

OW	Office of Water

Region 2
Region 5
Region 6
Region 9
Region 10
Science Advisor

2 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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EPA Reports with Unimplemented Recommendations

This table provides the full text of recommendations issued to the EPA prior to this semiannual period that remain
unimplemented, along with the planned completion dates provided by the EPA when the associated final reports were
issued and any subsequent revisions made by the EPA to those planned completion dates.

This table reflects the status of recommendations as of March 31, 2022.

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

Category 1— Administrative and Business Operations

EPA Needs to Strengthen
Oversight of Its Travel Program
Authorization and Voucher
Approval Processes
21-P-0265. September 30.2021

OCFO

4. Issue addendums to the Resource Management Directive System
2550B travel policy or equivalent to:

a. Require approvers to estimate and compare the total cost of
temporary change of station versus extended temporary duty travel
and authorize the one that is most advantageous for the Agency,
cost and other factors considered.

b. Require the travel card cancellation and closeout process,
to occur within a predetermined number of days.

9/30/22

EPA Needs to Strengthen Its
Purchase Card Program Approval
Process

21-P-0242, September 22,2021

OMS

2. Provide CitiManager training and support to cardholders, approving
officials, and the purchase card team that will establish the expectation
that they use and enable them to effectively use CitiManager for the
documentation, justification, and approval of purchases.

6/30/22

3. Require cardholders and approving officials who have completed
the training in Recommendation 2 to maintain approvals and
purchase documentation in CitiManager. Update all relevant policies
and procedures to reflect this requirement.

6/30/22

EPA's Emergency Response
Systems at Risk of Having
Inadequate Security Controls
21-E-0226, September 13,2021

OLEM

1. Implement controls to follow National Institute of Standards and
Technology guidance when conducting systems categorizations by: (a)
involving the appropriate key stakeholders, including mission owners
and the chief information security officer, during the system security
categorization process as prescribed in the National Institute for
Standards and Technology Special Publication 800-60 Volume I, Table
3, Process Roadmap; (b) having responsible parties adhere to all
activity steps as outlined in the National Institute for Standards and
Technology Process Roadmap, including selecting all application
information types applicable to information systems; and (c) having
responsible parties document the security categorization
determinations and decisions within system security plans as provided
in the National Institute for Standards and Technology Process
Roadmap, including documenting all downward adjustments to
provisional security levels.

6/30/22

2. Reevaluate the system security categorizations for the EPA On-
Scene Coordinator, Scribe.NET, Web Emergency Operations Center,
VIPER, Contaminated Site Cleanup Information Contractor Local
Area Network, and Emergency Management Portal systems in
accordance with National Institute of Standards and Technology
guidelines. Adjust security categorizations as appropriate based on
those evaluations.

6/30/22

OMS

3. Follow Agency guidance and implement controls to update the
EPA's security categorization guidance to include the chief
information security officer when adjusting the provisional security
categorization and determining the final security categorization, as
prescribed in the National Institute for Standards and Technology
Process Roadmap.

4/15/22

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

*** The EPA closed out the recommendation, but the OIG determined that the corrective action was not completed, and the EPA has not provided a revised completion date.
**** The EPA has not provided an updated planned completion date.

U—Unresolved when the report was issued but resolved at a later date.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

4. Update the EPA's security categorization guidance to define and
include the role of the mission owner.

4/15/22

5. Develop and provide role-based training to individuals who have
security responsibilities for National Institute of Standards and
Technology system security categorization.

6/30/22

ORD

6. Develop and implement a process to list and describe all minor
applications in the appropriate system security plan

5/31/22

OMS

7. Implement a process to document that tools and models are
secure.

10/15/21

4/30/22

EPA Needs to Improve Processes
for Updating Guidance, Monitoring
Corrective Actions, and Managing
Remote Access for External Users
21-E-0124. April 16,2021

OMS

1. Update information security procedures to make them consistent
with current federal directives, including the National Institute of
Standards and Technology Special Publication 800-53, Revision 5,
Security and Privacy Controls for information Systems and
Organizations.

6/30/22

EPA Improperly Awarded and
Managed Information Technology
Contracts

21-P-0094, March 10, 2021

OMS

10. Create a software license inventory policy, which will include
identifying the number of licenses, license-counts authorized, overall
costs of licenses, maintenance fees, and contracts used for each
licensed software. Track and report savings produced by software
licensing inventory and report the savings as part of the Office of
Management and Budget's annual Spend Under Management data.

12/31/22

$1,180

EPA's Fiscal Years 2019 and 2018
Hazardous Waste Electronic
Manifest System Fund Financial
Statements

21-F-0045. January 5.2021

OCFO

1. Strengthen and improve the preparation and management review
of the financial statements so that errors and misstatements are
detected and corrected.

9/30/21

3/31/22
6/30/22

$293

2. Analyze adjustments and corrections to the financial statements so
that such adjustments are appropriate, accurate, and properly
supported by documentation.

9/30/21

3/31/22
6/30/22

3. Record accounts receivable and earned revenue in the appropriate
fiscal year.

9/30/21

3/31/22
6/30/22

4. In coordination with the assistant administrator for Land and
Emergency Management, analyze e-Manifest billings so that accounts
receivable and earned revenue are recorded accurately.

9/30/21

3/31/22
6/30/22

$151

EPA Needs to Substantially
Improve Oversight of Its Military
Leave Processes to Prevent
Improper Payments
21-P-0042. December 28.2020

OMS
and
OCFO

1. Adopt and implement policies and procedures on military leave and
pay requirements that comply with 5 U.S.C. §§ 5538,6323, and 5519.

4/30/22

7/29/22

2. Provide resources for supervisors, timekeepers, and reservists on
their roles and responsibilities related to military leave under the law
and Agency policies.

4/30/22

7/29/22

3. Establish and implement internal controls that will allow the Agency
to monitor compliance with applicable laws, federal guidance, and
Agency policies, including periodic internal audits of all military leave, to
verify that (a) charges by reservists are correct and supported and (b)
appropriate reservist differential and military offset payroll audit
calculations are being requested and performed.

6/30/22

7/29/22

4. Require reservists to correct and supervisors to approve military
leave time charging errors in PeoplePlus that have been identified
during the audit or as part of the Agency's actions related to
Recommendations 5 and 6.

9/30/21

3/31/22
7/29/22

5. Recover the approximately $11,000 in military pay related to
unsupported 5 U.S.C. § 6323(a) military leave charges, unless the
Agency can obtain documentation to substantiate the validity of the
reservists' military leave.

8/31/21

12/15/21
12/30/22

$11

6. Submit documentation for the reservists' military leave related to
the approximately $118,000 charged under 5 U.S.C. § 6323(b) to the

8/31/21

12/15/21
12/30/22

$118

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

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EPA's initial

EPA's I

Report title, number, and date

Office

Unimplemented recommendation

planned
completion date

(at time of report
issuance)

revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

EPA's payroll provider to perform payroll audit calculations and
recover any military offsets that may be due.

7. Identify the population of reservists who took unpaid military leave
pursuant to 5 U.S.C. § 5538 and determine whether those reservists
are entitled to receive a reservist differential. Based on the results of
this determination, take appropriate steps to request that the EPA's
payroll provider perform payroll audit calculations to identify and pay the
amounts that may be due to reservists.

2/28/22

9/30/22

8. For the time periods outside of the scope of our audit (pre-January
2017 and post-June 2019), identify the population of reservists who
charged military leave under 5 U.S.C. § 6323(b) or 6323(c) and
determine whether military offset was paid by the reservists. If not,
review reservists' military documentation to determine whether
payroll audit calculations are required. If required, request that the
EPA's payroll provider perform payroll audit calculations to identify
and recover military offsets that may be due from the reservists under
5 U.S.C. §§ 6323 and 5519.

2/28/22

12/30/22

OCFO

9. Report all amounts of improper payments resulting from paid military
leave for inclusion in the annual Agency Financial Report, as required
by the Payment Integrity Information Act of 2019.

12/1/21

12/1/22

EPA Needs to Improve Its
Planning and Management of
Laboratory Consolidation Efforts
21-E-0033, December 7,2020

OMS

1. Develop and implement procedures that include detailed
requirements for planning and managing laboratory consolidation
efforts. Requirements should address developing master plans and
programs of requirements, tracking and updating cost and schedule

12/31/20

12/31/21
12/31/22

estimates, and maintaining decisional documentation.

EPA Has Sufficiently Managed
Emergency Responses During the
Pandemic but Needs to Procure
More Supplies and Clarify
Guidance

OLEM

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.

6/30/22
11/1/22

20-E-0332. September 28.2020

EPA Needs to Strengthen Controls
Over Required Documentation and
Tracking of Intergovernmental
Personnel Act Assignments
20-P-0245.Auaust10.2020

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

10/15/21

5/31/22

Manual accordingly.

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

5/31/22

3. Strengthen controls over the tracking of EPA employees on
Intergovernmental Personnel Act assignments.

1/15/22

5/31/22

EPA Needs to Improve Its Risk
Management and Incident

OMS

1. Develop and maintain an up-to-date inventory of the software and
associated licenses used within the Agency.

10/15/21

9/20/22
9/30/22

Response Information Security
Functions

20-P-0120, March 24. 2020

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.

6/24/20***

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

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October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

EPA Needs to Improve
Management and Monitoring of
Time-Off Awards
20-P-0065, December 30, 2019

OMS

1. Revise EPA Manual 3130 A2, Recognition Policy and Procedures
Manual, to establish a methodology for determining the equivalent
value for time-off awards.

10/31/22

3. Establish internal control procedures to manage time-off awards as
part of EPA resource management.

6/30/22

EPA's Fiscal Years 2019 and 2018
(Restated) Consolidated Financial
Statements

20-F-0033, November 19,2019

OCFO

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

9/30/21

3/31/22
6/30/22

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

9/30/21

3/31/22
6/30/22

5. Establish accounting models to properly classify and record
interest, fines, penalties, and fees.

9/30/21

3/31/22
6/30/22

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

9/30/21

3/31/22
6/30/22

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

12/31/22

Actions Needed to Strengthen
Controls over the EPA
Administrator's and Associated
Staff's Travel
19-P-0155, Mav 16, 2019

OCFO

1. Evaluate and determine whether the increased airfare costs
estimated at $123,942 related to former Administrator Pruitt's use of
first/business-class travel without sufficient justification and proper
approval, for the period March 1,2017, through December 31,2017,
should be recovered and, if so, from which responsible official or
officials, and direct recovery of the funds.

11/30/21
12/16/22

$124

2. For the period January 1,2018, through his resignation in July 2018,
evaluate and determine whether any costs related to former
Administrator Pruitt's use of first/business-class travel without sufficient
justification and proper approval should be recovered and, if so, from
which responsible official or officials, and direct recovery of the funds.

6/26/19
12/16/22

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

19-N-0154, Mav 15, 2019

Region
5

1. Issue a decision regarding Ohio's request to transfer from the Ohio
Environmental Protection Agency to the Ohio Department of
Agriculture its National Pollutant Discharge Elimination System
program with respect to Concentrated Animal Feeding Operations
and other elements of the program.

3/8/21

11/23/23

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

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
6/30/22

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
6/30/22

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
6/30/22

8. Train staff on the procedures and instructions developed for
Recommendations 5 through 7.

9/30/20

9/30/21
9/30/22

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

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Semiannual Report to Congress

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Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

Improved Management of the
Brownfields Revolving Loan Fund
Program Is Required to Maximize
Cleanups

17-P-0368.Auaust23.2017

OLEM

1. Develop a policy to reduce balances of available program income
of Brownfields Revolving Loan Funds being held by recipients. The
policy should establish a time frame for recipients to use or return the
funds to the EPA.

3/19/19***

8. Develop and implement required training for all regional
Brownfields Revolving Loan Fund staff. Have the training include all
program policy and guidance relating to maintaining a Brownfields
Revolving Loan Fund after the cooperative agreement is closed if
program income exists.

3/19/19***

13. Require regional project officers, through a policy, to be assigned
and maintain information on all closed cooperative agreements with
pre- and post-program income.

3/19/19***

14. Develop and implement a method for the Office of Brownfields
and Land Revitalization to track closed cooperative agreements with
pre- and post-program income.

3/19/19***

16. Create a method for the Office of Brownfields and Land
Revitalization, and EPA regional managers, to track compliance with
reporting requirements for closed cooperative agreements.

3/19/19***

Enhanced Controls Needed to
Prevent Further Abuse of
Religious Compensatory Time
16-P-0333. September 27.2016

OMS

3. Develop training on the proper use of Religious Compensatory
Time and require all managers approving, and employees using,
Religious Compensatory Time to complete the course.

5/30/17***

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

Subtotal

53 unimplemented recommendations

$1,877

Category 2— Human Health and Environmental Issues

EPA Needs an Agencywide
Strategic Action Plan to Address
Harmful Algal Blooms
21-E-0264. September 29.2021

1. Develop an agencywide strategic action plan, including milestones,
to direct the EPA's efforts to maintain and enhance a national
program to forecast, monitor, and respond to freshwater harmful algal
blooms. This plan should incorporate strategies for: (a) identifying
knowledge gaps; (b) closing identified knowledge gaps, particularly
related to health risks from exposure to cyanotoxins in drinking water
and during recreational activities; (c) monitoring and tracking harmful
algal blooms; (d) enhancing the EPA's national leadership role in
addressing freshwater algal blooms; (e) coordinating EPA activities
internally and with states; and (f) assessing the health risks from
exposure to cyanotoxins in drinking water and during recreational
activities and establishing additional criteria, standards, and
advisories, as the scientific information allows.

1/31/23

3. Mindful that the EPA has substantial work to complete before
publishing final numeric water quality criteria recommendations for
nitrogen and phosphorus under the Clean Water Act for rivers and
streams, establish a plan, including milestones and identification of
resource needs, for developing and publishing those criteria
recommendations.

4/30/23

4. Assess and evaluate the available information on human health
risks from exposure to cyanotoxins in drinking water and recreational

12/31/22

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

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Semiannual Report to Congress

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EPA's initial

EPA's I

Report title, number, and date

Office

Unimplemented recommendation

planned
completion date

(at time of report
issuance)

revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

waters to determine whether actions under the Safe Drinking Water
Act are warranted.

Pandemic Highlights Need for
Additional Tribal Drinking Water
Assistance and Oversight in EPA
Regions 9 and 10
21-E-0254, September 27,2021

Region
9

1. Implement a strategy to provide outreach, training, guidance, and
technical and financial assistance to tribal drinking water systems to
improve their resilience using the tools developed and grants
distributed by the EPA in accordance with the America's Water
Infrastructure Act of 2018.

9/30/22

2. Develop and implement a strategy to help the direct
implementation of the tribal drinking water program, including
resumption of sanitary surveys and inspections in a manner that
considers the coronavirus restrictions of each tribe.

9/30/22

3. Develop and implement a plan to prioritize and address the
recommendations identified in the 2019 file review for Region 9.

9/30/23

5. Develop a workforce analysis to address staff workload and the
skills needed for the direct implementation of the tribal drinking water

9/30/23

program.

Region
10

6. Implement a strategy to provide outreach, training, guidance, and
technical and financial assistance to tribal drinking water systems to
improve their resilience using the tools developed and grants
distributed by the EPA in accordance with the America's Water
Infrastructure Act of 2018.

9/30/22

7. Develop and implement a strategy to help the direct
implementation of the tribal drinking water program, including
resumption of sanitary surveys and inspections in a manner that
considers the coronavirus restrictions of each tribe.

9/30/22

9. Incorporate lessons learned from the coronavirus pandemic to
improve Region 10's existing plans for continuity of operations, with
an emphasis on data management and network connectivity.

9/30/22

10. Develop a workforce analysis to address staff workload and the
skills needed for the direct implementation of the tribal drinking water

9/30/22

program.

EPA's Office of Land and
Emergency Management Lacked
a Nationally Consistent Strategy
for Communicating Health Risks at
Contaminated Sites
21-P-0223. September 9.2021

OLEM

1. Establish and implement internal controls to achieve nationally
consistent risk communication to improve the impacted public's
awareness and understanding of risks at contaminated sites.
Consistent across all Office of Land and Emergency Management
programs and regional offices, such internal controls should: (a)
define relevant timelines for communications; (b) identify who should

9/30/22

be notified of sampling results; (c) use and promote existing best risk
communication practices, such as community advisory groups,
community involvement coordinators, cumulative risk assessments,
and assessments of environmental justice concerns; (d) determine
how to communicate risks for emerging contaminants, such as per-
and polyfluoroalkyl substances; and (e) be consistent with the EPA's
Seven Cardinal Rules of Risk Communication.

2. Establish and implement internal controls for the Office of Land
and Emergency Management to conduct periodic evaluations of the
risk communication efforts and outreach at Office of Land and

9/30/22

Emergency Management-led sites. Periodically summarize Office of
Land and Emergency Management programwide risk communication
evaluation results to share across the Office of Land and Emergency
Management programs and with EPA regions. Use these risk
communication evaluation results when warranted to modify the
Office of Land and Emergency Management programwide risk
communication strategy, as appropriate.

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

-------
Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

3. Establish and implement internal controls for the Office of Land
and Emergency Management to provide community members, when
sampling results or other indicators show that they are or may be
exposed to environmental health hazards, with: (a) information that
allows them to manage their risks and (b) resources to contact to
address the health impacts of the exposure.

9/30/22

EPA Needs to Measure and Track
Performance of Programs
Eliminated in President's Budget
but Later Funded by Congress
21 -E-0219. September 2,2021

OCFO

1. Develop written guidance that explicitly states that eliminated-then-
funded programs must measure and track performance.

2/28/22

5/31/22

2. Develop an annual process to verify that eliminated-then-funded
programs have performance measures in place and to identify where
those measures are tracked.

2/28/22

5/31/22

EPA's Endocrine Disruptor
Screening Program Has Made
Limited Progress in Assessing
Pesticides

21-E-0186. July 28. 2021

OCSPP

1. Issue Tier 1 test orders for each List 2 chemical or publish an
explanation for public comment on why Tier 1 data are no longer
needed to characterize a List 2 chemical's endocrine-disruption activity.

9/30/25

2. Determine whether the EPA should incorporate the Endocrine
Disruptor Screening Program Tier 1 tests (or approved new approach
methodologies) into the pesticide registration process as mandatory
data requirements under 40 C.F.R. § 158 for all pesticide use patterns.

9/30/24

3. Issue List 1—Tier 2 test orders for the 18 pesticides in which
additional Tier 2 testing was recommended or publish an explanation
for public comment on why Tier 2 data are no longer needed to
characterize the endocrine-disruption activity for each of these
18 pesticides.

9/30/24

4. Issue for public review and comment both the Environmental Fate
and Effects Division's approach for the reevaluation of List 1—Tier 1
data and the revised List 1—Tier 2 recommendations.

12/31/23

5. Develop and implement an updated formal strategic planning
document, such as the Comprehensive Management Plan.

9/30/22

6. Develop performance measures, with reasonable time frames, to
document progress toward and achievement of milestones or targets.
Specifically, the Endocrine Disruptor Screening Program should
consider at least one performance measure that tracks progress in
testing pesticides for human endocrine disruptor activity.

10/1/24

7. Conduct annual internal program reviews of the Endocrine
Disruptor Screening Program.

9/30/22

8. Complete and publish the Endocrine Disruptor Screening
Program's response(s) to 2015 Federal Register notice comments
and its related white paper.

12/31/21

4/30/22

10. To increase external communication and transparency, update
the Endocrine Disruptor Screening Program website, including the
program timeline, and publish any relevant program documents.

12/30/21

4/30/22

EPA Should Conduct More
Oversight of Synthetic-Minor-
Source Permitting to Assure
Permits Adhere to EPA Guidance
21-P-0175. July 8. 2021

OAR

1. Update Agency guidance on practical enforceability to more clearly
describe how the technical accuracy of a permit limit should be
supported and documented. In updating such guidance, the Office of
Air and Radiation should consult and collaborate with the Office of
Enforcement and Compliance Assurance, the Office of General
Counsel, and the EPA regions.

10/31/23

2. In consultation with the EPA regions, develop and implement an
oversight plan to include (a) an initial review of a sample of synthetic-
minor-source permits in different industries that are issued by state,
local, and tribal agencies to assess whether the permits adhere to EPA
guidance on practical enforceability, including limits that are technically
accurate, have appropriate time periods, and include sufficient

10/31/24

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

-------
Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

monitoring, record-keeping, and reporting requirements; (b) a periodic
review of a sample of synthetic-minor-source permits to occur, at a
minimum, once every five years; and (c) procedures to resolve any
permitting deficiencies identified during the initial and periodic reviews.

3. Assess recent EPA studies of enclosed combustion device
performance and compliance monitoring and other relevant
information during the next statutorily required review of 40 C.F.R
Part 60 Subparts OOOO and OOOOa to determine whether revisions
are needed to monitoring, record-keeping, and reporting
requirements for enclosed combustion devices to assure continuous
compliance with associated limits, and revise the regulatory
requirements as appropriate.

12/31/24

4. Revise the Agency's guidance to communicate its key expectations
tor synthetic-minor-source permitting to state and local agencies.

10/31/24

5. Identify all state, local, and tribal agencies in which Clean Air Act
permit program implementation fails to adhere to the public
participation requirements for synthetic-minor-source permit issuance
and take appropriate steps to assure the identified states adhere to
the public participation requirements.

12/31/23

EPA Deviated from Typical
Procedures in Its 2018 Dicamba
Pesticide Registration Decision
21-E-0146, May 24, 2021

OCSPP

1. Implement a procedure requiring senior managers or policy makers
to document changes or alterations to scientific opinions, analyses, and
conclusions in interim and final pesticide registration decisions and their
basis for such changes or alterations.

3/31/22

4/30/22

2. Require an assistant administrator-level verification statement that
Scientific Integrity Policy requirements were reviewed and adhered to
for pesticide registration decisions that involve the immediate office.

9/30/22

3. Annually conduct and document training for all staff and senior
managers and policy makers to affirm the office's commitment to the
Scientific Integrity Policy and principles and to promote a culture of
scientific integrity.

3/31/22

3/31/26

Resource Constraints, Leadership
Decisions, and Workforce Culture
Led to a Decline in Federal
Enforcement
21-P-0132, May 13, 2021

OECA

3. Use the results of the Office of Inspector General's 2019
Enforcement Survey and other resources to identify and address
areas of concern for the enforcement program, including through
issuing new or revised policies, as appropriate.

9/30/21****

4. Incorporate additional enforcement information and data into future
annual enforcement results reports to provide context for

(a) compliance monitoring activities conducted by the Agency and

(b) the estimated environmental benefits achieved through Agency
enforcement actions.

3/31/22

8/29/22

6. Evaluate the annual enforcement performance measures to
assess whether additional context should be provided for other
reported measures or whether additional measures should be
included in future reports to fully capture the scope of the Agency's
enforcement program.

2/28/22

8/29/22

7. Develop and track noncompliance rates within environmental
programs or use other innovative approaches that would indicate the
success of enforcement activities at returning entities to compliance.

6/30/22

Staffing Constraints, Safety and
Health Concerns at EPA's
National Enforcement
Investigations Center May
Compromise Ability to Achieve
Mission

OECA

5. Develop and incorporate metrics that address safety and health
issues, and staff concerns into National Enforcement Investigations
Center senior management performance standards, such as
collecting anonymous feedback from all staff annually.

9/30/22

9. Develop and incorporate metrics on the National Enforcement
Investigations Center work environment and culture into Office of

6/28/24

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

-------
Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

21-P-0131.Mav 12.2021

Criminal Enforcement, Forensics, and Training senior management
performance standards, such as results from the annual Federal
Employee Viewpoint Survey, periodic culture audits, or other
methods to measure progress.

10. Develop and incorporate metrics that address work environment
and culture into National Enforcement Investigations Center senior
management performance standards.

6/28/24

EPA Helps States Reduce Trash,
Including Plastic, in U.S.
Waterways but Needs to Identify
Obstacles and Develop Strategies
for Further Progress
21-P-0130.Mav 11.2021

1. Evaluate the obstacles to implementing the Clean Water Act to
control trash in U.S. waterways and provide a public report describing
those obstacles.

12/31/21

6/30/22

2. Develop and disseminate strategies to states and municipalities for
addressing the obstacles identified in the evaluation from
Recommendation 1. These strategies may include guidance
regarding how to develop narrative water quality criteria, consistent
assessment and measurement methodologies, and total maximum
daily loads for trash pollution.

4/30/23

EPA Should Conduct New Residual
Risk and Technology Reviews for
Chloroprene- and Ethylene Oxide-
Emitting Source Categories to
Protect Human Health
21-P-0129.Mav6.2021

OAR

4. Conduct overdue technology reviews for Group I polymers and
resins that cover neoprene production, synthetic organic chemical
manufacturing industry, commercial sterilizers, hospital sterilizers,
and chemical manufacturing area sources, which are required to be
completed at least every eight years by the Clean Air Act.

9/30/24

Improved Review Processes
Could Advance EPA Regions 3
and 5 Oversight of State-Issued
National Pollutant Discharge
Elimination System Permits
21-P-0122.ADril21.2021

Region
3

1. Review the modified National Pollutant Discharge Elimination
System mining permits issued by West Virginia based on the 2019
revisions to its National Pollutant Discharge Elimination System
program to ensure that no backsliding has occurred, including for
discharges of ionic pollution, in accordance with EPA Region 3's
approval letter dated March 27,2019. If a permit does not contain
record documentation for the reasonable potential analysis or otherwise
allows backsliding, alert West Virginia of the permit inadequacies.

3/31/22'
1/31/23

2. Review the modified National Pollutant Discharge Elimination
System mining permits issued by West Virginia based on the 2019
revisions to its National Pollutant Discharge Elimination System
program to determine whether the permits contain effluent limits for
ionic pollution and other pollutants that are or may be discharged at a
level that causes, has the reasonable potential to cause, or contributes
to an excursion above any applicable water quality standard, as
required by Clean Water Act regulations. If a permit lacks required
effluent limits, take appropriate action to address such deficiencies.

12/31/22'
1/31/25

3. Develop a formal internal operating procedure to facilitate timely
permit reviews and transmission of EPA comments to states.

3/31/22'
10/31/22

f These dates were provided to the OIG by Region 3 in its June 17, 2021 response to the OIG's final report. The OIG accepted the
proposed corrective action and planned completion date for Recommendation 3, while Recommendations 1 and 2 remained unresolved.
The OIG and Region 3 corresponded several times about Recommendations 1 and 2, including a briefing held by Region 3 on
October25, 2021. In a memorandum dated December 13, 2021, the OIG accepted Region 3's proposed corrective actions to address
Recommendations 1 and 2 but did not receive revised planned completion dates. After the OIG accepted the proposed corrective actions
for Recommendations 1 and 2, Region 3 provided revised planned completion dates, which are reflected above.

Region
5

4. Review and provide written input on any National Pollutant
Discharge Elimination System permit prepared for reissuance by the
Minnesota Pollution Control Agency for the PolyMet Mining Inc.
NorthMet project, if applicable, as appropriate pursuant to the
requirements of the Clean Water Act, National Pollutant Discharge
Elimination System regulations, the Region 5 National Pollutant
Discharge Elimination System permit review standard operating

11/30/23

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

-------
Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

procedure, and the memorandum of agreement between EPA
Region 5 and the Minnesota Pollution Control Agency.

Concerns About the Process Used
for the SAFE Vehicles Rule
Demonstrate the Need for a Policy
on EPA's Role in Joint
Rulemakings
21-E-0125, April 20,2021

OAR

3. In coordination with the Office of Policy, formally document
decisions to not complete Action Development Process milestones,
including early guidance, analytic blueprint, options selection, and
final Agency review.

6/30/21

9/30/22'

t The OAR said that it will propose revised corrective actions and planned completion dates in the near future.

EPA Delayed Risk Communication
and Issued Instructions Hindering
Region 5's Ability to Address
Ethylene Oxide Emissions
21-P-0123. ADril 15. 2021

OAR

1. Develop standard operating procedures describing how the Office
of Air and Radiation will work with EPA regional offices to
communicate preliminary air toxics risk information, including
elevated risks found in the National Air Toxics Assessment, to the
public so that communities are promptly informed of potential health
concerns.

6/30/22

2. Develop standard operating procedures describing the roles and
responsibilities of the Office of Air and Radiation and regional offices
in assessing and addressing air toxics emissions contributing to
health risks, as found in the National Air Toxics Assessment, other
studies, or public complaints.

6/30/22

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. March 29,2021

OLEM

3. Develop and implement controls to verify that the Resource
Conservation and Recovery Act referrals to the Superfund program
are added to Superfund Enterprise Management System for further
Superfund program attention, as necessary.

3/31/22

6/30/22

4. Develop and implement controls to verify that the Superfund
program deferrals to the Resource Conservation and Recovery Act
are added to RCRAInfo for further Resource Conservation and
Recovery Act attention, as necessary.

9/30/23

5. Develop and maintain a crosswalk of Superfund Enterprise
Management System and corresponding RCRAInfo identification
numbers.

12/31/22

6. Develop and implement controls to identify and eliminate overlap of
environmental indicators between Resource Conservation and
Recovery Act Corrective Action and Superfund Programs and include
this information in public queries, such as Cleanups in My Community.

3/31/23

EPA Is at Risk of Not Achieving
Special Local Needs Program
Goals for Pesticides
21-E-0072, February 10,2021

OCSPP

1. Develop program objectives and measures and implement data-
collection processes to determine the risk-reduction and pollution-
prevention outcomes of the Special Local Needs program.

7/1/22

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. December 3.2020

Region
2

2. Develop and implement a supplement to Region 2's emergency
response plan to describe and address the specific geographic,
logistical, and cultural norms applicable to disaster response in Puerto
Rico and the U.S. Virgin Islands. This supplement should include local
EPA staff roles and responsibilities, as well as address the likely
limitations to transportation, communications, and power in the
aftermath of disasters.

6/30/23

3. In coordination with the Office of Water, implement America's Water
Infrastructure Act in Puerto Rico and the U.S. Virgin Islands by: (a)
developing and implementing a strategy to provide training, guidance,
and assistance to small drinking water systems as they improve their
resilience and (b) establishing a process for small drinking water
systems to apply for America's Water Infrastructure Act grants. This
process should include (1) implementing the EPA's May 2020 guidance
provided to small drinking water systems regarding resilience
assessments and (2) establishing a public information campaign to

12/31/22

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

-------
Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

inform small drinking water systems of the America's Water
Infrastructure Act grant opportunity, qualifying requirements, and
application deadlines.

Improved EPA Oversight of
Funding Recipients' Title VI
Programs Could Prevent
Discrimination

20-E-0333, September 28,2020

OGC

1. Develop and implement a plan to coordinate relevant Agency
program, regional, and administrative offices with the External Civil
Rights Compliance Office to develop guidance on permitting and
cumulative impacts related to Title VI.

9/30/22

2. Develop and implement a plan to complete systematic compliance
reviews to determine full compliance with the Title VI program.

9/30/22

4. Verify that EPA funding applicants address potential
noncompliance with Title VI with a written agreement before the
funds are awarded.

9/30/22

5. Determine how to use existing or new data to identify and target
funding recipients for proactive compliance reviews, and develop or
update policy, guidance, and standard operating procedures for
collecting and using those data.

3/31/23

6. Develop and deliver training for the deputy civil rights officials and
EPA regional staff that focuses on their respective roles and
responsibilities within the EPA's Title VI program.

3/31/22
9/30/23

EPA Needs to Improve Oversight
of How States Implement Air
Emissions Regulations for
Municipal Solid Waste Landfills
20-P-0236. Julv 30.2020

Region
6

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

OAR

4. Develop and implement a process for the periodic review of
municipal solid waste landfill design capacity information and Title V
permit lists to identify municipal solid waste landfills with design
capacities over the applicable threshold that have not applied for a
Title V permit.

9/30/21
12/31/22

Further Efforts Needed to Uphold
Scientific Integrity Policy at EPA
20-P-0173, May 20, 2020

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

12/31/21
9/30/22

ORD /
Science
Advisor

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

6/30/24

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

4/30/22
6/30/22
3/31/23

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

6/30/22
3/31/23

EPA's Processing Times for New
Source Air Permits in Indian
Country Have Improved, but Many
Still Exceed Regulatory Time
Frames

20-P-0146, April 22,2020

OAR

1. Implement a system that is accessible to both the EPA and the
applicants to track the processing of all tribal-New-Source-Review
permits and key permit dates, including application received,
application completed, draft permit issued, public comment period
(if applicable), and final permit issuance.

9/30/21

9/30/22

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

9/30/22

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

-------
Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

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

3/31/22
9/30/22

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

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.

5/31/211"

t 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. We consider the administrator's January 4, 2021 decision a significant management decision with which we disagree. We
continue to work with the EPA to address our recommendation.

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 Executive Order 12866, identify for
the public (e.g., via the public docket) substantive change of
economic significance between the draft submitted to the Office of
Information and Regulatory Affairs for review and the action
subsequently announced, and identify whether that change was
made at the suggestion or recommendation of the Office of
Information and Regulatory Affairs.

12/31/19

3/31/21
6/30/21
6/30/22T

t The OAR said that it will propose revised corrective actions and planned completion dates in the near future.

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

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

-------
Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

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 and (b) information on
modern methods for delivery of public notice.

6/30/20

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, and (f) additional resources for providing
public notice in languages other than English.

9/30/20

9/30/22





More Effective EPA Oversight Is
Needed for Particulate Matter
Emissions Compliance Testing
19-P-0251. Julv 30.2019

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
12/31/22





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 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

3/31/23



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
12/31/21
7/1/22



8. Issue updated and consistent guidance on biosolids fecal coliform
sampling practices.

12/31/20

5/31/21
12/31/21
7/1/22



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 implementations, and (c)
resources to maintain and build upon existing agency expertise.

12/31/20

9/30/22



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

3/31/23





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

12/31/21
11/1/22



Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

*** The EPA closed out the recommendation, but the OIG determined that the corrective action was not completed, and the EPA has not provided a revised completion date.
**** The EPA has not provided an updated planned completion date.

U—Unresolved when the report was issued but resolved at a later date.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

Management Weaknesses
Delayed Response to Flint Water
Crisis

18-P-0221. July 19. 2018

OECA
and
OW

6. Provide regular training for EPA drinking water staff, managers and
senior leaders on Safe Drinking Water Act tools and authorities; state
and agency roles and responsibilities; and any Safe Drinking Water
Act amendments or Lead and Copper Rule revisions.

7/7/21***

8. Create a system that tracks citizen complaints and gathers
information on emerging issues. The system should assess the risk
associated with the complaints, including efficient and effective
resolution.

7/7/21***

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.

12/31/22

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
12/31/22

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

EPA Has Not Met Statutory
Requirements for Hazardous
Waste Treatment, Storage and
Disposal Facility Inspections, but
Inspection Rates Are High
16-P-0104. March 11.2016

OECA

1 .Implement management controls to complete the required TSDF
inspections.

3/19/19***

EPA's Endocrine Disruptor
Screening Program Should
Establish Management Controls to
Ensure More Timely Results
11-P-0215. May 3. 2011

OCSPP

4. Develop short-term, intermediate, and long-term outcome
performance measures, and additional output performance
measures, with appropriate targets and timeframes, to measure the
progress and results of the program.

9/23/13***

5. Develop and publish a comprehensive management plan for
EDSP, including estimates of EDSP's budget requirements, priorities,
goals, and key activities covering at least a 5-year period.

9/23/13***

6. Annually review the EDSP program results, progress toward
milestones, and achievement of performance measures, including
explanations for any missed milestones or targets.

9/23/13***

EPA Should Revise Outdated or
Inconsistent EPA-State Clean
Water Memoranda of Agreement
10-P-0224, September 14,2010

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

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

U—Unresolved when the report was issued but resolved at a later date.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Report title, number, and date

Office

Unimplemented recommendation

EPA's initial
planned
completion date

(at time of report
issuance)

EPA's
revised
planned
completion
date(s)*

Potential
monetary
benefits**

(in thousands)

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
9/30/26

$27,800



Subtotal



103 unimplemented recommendations





$27,800

Total



156 unimplemented recommendations





$29,677

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates.

** Blank cells indicate that no potential monetary benefits were identified.

*** The EPA closed out the recommendation, but the OIG determined that the corrective action was not completed, and the EPA has not provided a revised completion date.
**** The EPA has not provided an updated planned completion date.

U—Unresolved when the report was issued but resolved at a later date.

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Semiannual Report to Congress October 1, 2021-March 31, 2022

CSB Reports with Unimplemented Recommendations

This table provides the full text of recommendations issued to the CSB prior to this semiannual period that remain
unimplemented, along with the planned completion dates provided by the CSB when the associated final reports
were issued and any subsequent revisions made by the CSB to those planned completion dates.

This table reflects the status of recommendations as of March 31, 2022.

Report title, number, and date

Office

Unimplemented recommendation

CSB's initial
planned
completion date

at time of report
issuance

CSB's
revised
planned
completion
date(s)*

Potential
monetary
benefits

(in thousands)**

Category 1— Management Operations

CSB's Information Security Program Is
Not Consistently Implemented;
Improvements Are Needed to Address
Four Weaknesses
21-E-0071. February 9.2021

CSB

1. Complete the Risk Assessment process as required by
NIST 800-37, re-evaluate the Risk Management Framework
to make in more fluent to leverage day-to-day processes in
place for completing the risk assessment, and determine
how to best implement an organization-wide governance
process for monitoring and reporting on risks.

4/30/21

9/30/22

2. Document the process in place to monitor required flaw
remediation to resolution and enhance the flaw remediation
process to require approvals if risks cannot be mitigated to
an acceptable level in a timely manner. In addition, develop
timeframes and monitoring on the timeliness of applying
patch updates.

1/31/21

9/30/22

CSB Discontinued Information
Recovery Testing and Off-Site Backup
Storage During the Coronavirus
Pandemic

21-E-0016. November 18.2020

CSB

1. Test its disaster recovery plan at least annually.

12/30/20

6/30/22

Total

3 unimplemented recommendations

Legend: * Blank cells indicate that there have been no revisions to the initial planned completion dates. ** Blank cells indicate that no potential monetary benefits were identified.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Appendix 4—Closed Investigations Involving Senior Employees

For Reporting Period Ending March 31, 2022

Section 5(a)(19) of the Inspector General Act requires a report on each investigation involving a senior government
employee where allegations of misconduct were substantiated. Section 5(a)(22) of the 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, 2022, are provided below.

CASE NUMBER: QI-HQ-2021-CCR-0075

An EPA SES employee allegedly wrongfully deleted two EPA official emails at the request of a company involved in litigation
with the Agency. The investigation did not substantiate the allegation.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

Appendix 5—Peer Reviews Conducted

For Reporting Period Ending March 31, 2022

Section 5(a)(14) of the Inspector General Act 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 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 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 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.

The following are the most recent peer reviews conducted by another OIG of EPA OIG. There are no outstanding
recommendations from these peer reviews.

Audits

The most recent peer review report on the EPA OIG was issued on April 15, 2021, by the Treasury Inspector General for
Tax Administration OIG. That review, covering the three-year period ending September 30, 2020, 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.

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 OIG identified no deficiencies and found that internal safeguards and
management procedures were compliant with quality standards.

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Semiannual Report to Congress

October 1, 2021-March 31, 2022

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

Region 1

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: (984) 309-2669

Region 4

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

Region 7

U.S. Environmental Protection Agency
Office of Inspector General
11201 Renner Boulevard
Lenexa, KS 66219
Audit/Evaluation: (913) 551 -7878
Investigations: (913) 551-7420

Region 10

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

Offices

Region 2

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

Region 5

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

Region 8

U.S. Environmental Protection Agency
Office of Inspector General
1595 Wynkoop Street, 4th Floor
Denver, CO 80202
Audit/Evaluation: (303) 312-6871
Investigations: (303) 312-6868

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

Region 3

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

Region 6

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

Region 9

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

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

71

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