Semiannual Report to Congress, October 1, 2022


U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

SEMIANNUAL

r REPORT i

TO
CONGRESS

OCT 1, 2022 - MAR 31, 2023

-------
Index of Reporting Requirements

Inspector General Act of 1978, as amended

Requirement	Subject	Addressed in

Section 5(a)(1)	Description of significant problems, abuses, and deficiencies relating to programs and operations and	Section 2.1

associated reports and recommendations for corrective action

Section 5(a)(2)

Identification of each recommendation made before the reporting period for which corrective action has
not been completed and potential cost savings associated with the recommendation

Section 1.3; Appendix 3

Section 5(a)(3)

Summary of significant investigations closed during the reporting period

Section 2.2

Section 5(a)(4)

Identification of the total number of convictions during the reporting period resulting from investigations

Sections 2.2 and 3

Section 5(a)(5)	A list identifying each audit, inspection, or evaluation report issuing during the reporting period; along	Appendix 1

with the total value of questioned costs (to include unsupported costs); total value of recommendations
that funds to put to better use; and whether a management decision had been made by the end of the
reporting period

Section 5(a)(6)	Information regarding any management decision made during the reporting period with respect to an	Appendix 2

audit, inspection or evaluation report issued during a previous reporting period

Section 5(a)(7)

Information described under section 804(b) of the Federal Financial Management Improvement Act of
1996

Section 1.3

Section 5(a)(8-10)

Information with respect to peer reviews conducted

Appendix 5

Section 5(a)(11-12)

Statistics on investigative reports, referrals, prosecutions, and indictments

Section 3

Section 5(a)(13)

Information with respect to substantiated investigations involving senior government employees

Appendix 4

Section 5(a)(14)

Information with respect to instances of whistleblower retaliation

Section 2.3

Section 5(a)(15)

Detailed description of any establishment attempts to interfere with OIG independence; summary of
each report made to the agency head under IG Act section 6(c)(2)

Section 2.3

Section 5(a)(16)	Detailed description of closed audits, inspections, and evaluations; and closed investigations involving	Appendix 4

senior employees not disclosed to public

Abbreviations



C.F.R.

Code of Federal Regulations

CSB

U.S. Chemical Safety and Hazard Investigation Board

EPA

U.S. Environmental Protection Agency

FY

Fiscal Year

GS

General Schedule

IIJA

Infrastructure Investment and Jobs Act

OIG

Office of Inspector General

Pub. L.

Public Law

U.S.C.

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 HotlinePepa.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/oig

Subscribe to our Email Updates.
Follow us on Twitter (SiEPAoig.
Send us your Project Suggestions.

-------
Message to Congress

It is my pleasure to present this Semiannual Report to Congress, which summarizes the
U.S. Environmental Protection Agency Office of Inspector General's work during the first half
of fiscal year 2023. Throughout this period, we provided important oversight of EPA and
U.S. Chemical Safety and Hazard Investigation Board programs and operations. We also
undertook robust strategic efforts to help us tackle evolving needs and challenges, especially
in regard to the historic funding that the EPA is receiving under the Infrastructure Investment
and Jobs Act and the Inflation Reduction Act.

Strategically Preparing for Evolving Oversight Needs and Challenges. Between the IIJA
and the IRA, the EPA will receive over $100 billion in supplemental appropriations. The
Agency's obligation to invest this unprecedented level of EPA funding brings with it a
corresponding level of risk for fraud, waste, and abuse. In the IIJA Congress dedicated funds for EPA OIG
oversight; unfortunately, the IRA did not provide funds for the same sort of independent oversight.

Furthermore, our oversight responsibilities are greater than ever, but after a decade of declining and stagnant
annual budgets, plus a lack of funds to oversee IRA work, we must do much more with less.

Still, we remain staunchly committed to our mission and stretching every oversight dollar to capacity. As of
March 31, we had around a dozen ongoing and planned IIJA oversight projects. During this semiannual reporting
period, we also developed strategic planning products to help both the EPA and the OIG optimize the use of their
respective IIJA funds. We published several IIJA-related oversight products: the Infrastructure Investment and Jobs
Act—Overview of the EPA's Progress Since November 2021, the Compendium of Open and Unresolved
Recommendations Related to Infrastructure Investment and Jobs Act-Funded Programs, four "lessons learned"
reports to help the Agency avoid past pitfalls as it completes its IIJA work, and an IIJA oversight webpage with an
interactive dashboard that allows users to see where and how the EPA is disbursing IIJA funds.

Communicating with Congress and the Public. As the OIG's communications with Congress and the public are
paramount, we worked to keep both informed of our oversight activities and progress. For example, on March 29,
I testified before the Energy and Commerce Subcommittee on Oversight and Investigations about our IIJA
groundwork and early oversight results, our outreach to stakeholders and shared best practices, lessons learned,
and overall good governance practices for the EPA to apply as it manages IIJA funds. To bolster our external
communications, I completed the successful split of a single office that led our legal and external affairs functions
into two distinct units. Now we have two offices, the Office of Counsel and the Office of Congressional and Public
Affairs, each led by a member of the Senior Executive Service. This reorganization enables each office to focus on
its specialties, expand and enhance its products and services, and cultivate an environment where its employees
thrive.

Providing Oversight Related to Environmental Emergencies. To ensure that the EPA has effective internal controls
in place to protect human health and the environment, and that federal dollars flowing to and through state
agencies are used appropriately, it is critical that we provide oversight related to environmental emergencies.
During this period, we rapidly initiated inquiries into the EPA's response to two such emergencies: the train
derailment in East Palestine, Ohio, and the potential contamination of the Elm Point Wellfield drinking water
source in St. Charles, Missouri. Regarding the train derailment, we had staff on-site and communicating with other
OIGs before we even initiated our official inquiry. We are currently conducting interviews; gathering data; and
analyzing a variety of issues, after which we will determine whether to initiate formal oversight work related to
these environmental emergencies.

Sean W. O'Donnell

-------
During the semiannual
reporting period, OIG
work resulted in:

OIG investigative work
resulted in:

6 indictments, informations,
and complaints

In fiscal year 2023 thus far, the OIG:

recommendations
for improvement*

j 2,874 hotline
(fcy contacts handled

$82 million in grant
funds identified as
potentially used
ineffectively**

(f)

1 criminal conviction

Agency avoided $12.42 million

in costs after implementing
recommendations or based on
investigative results

.A 14 administrative actions,
yC J including suspensions and
< J disbarment actions

Identified $46.81 million
in potential
monetary benefits

Conducted investigations
that resulted in $397,768
in fines, penalties, and
restitutions

Measure includes both EPA OIG-only
investigations and joint investigations.

* This includes reports that were conducted in compliance with Quality Standards for Inspection and Evaluation or generally accepted government
auditing standards as well as reports that did not follow eitherstandard. This excludes peer review reports.

** The $82 million in grants that the EPA has provided for wood heater changeout programs could be wasted if the replacement wood heaters

During this semiannual reporting period, we also initiated an audit and an evaluation related to the Jackson,
Mississippi drinking water crisis; continued an audit related to the drinking water lead contamination in Benton
Harbor, Michigan; and continued an evaluation related to the Red Hill fuel leak that contaminated drinking water
at Joint Base Pearl Harbor-Hickam in Hawaii. We expect to issue our reports on the drinking water lead
contamination and fuel leak in the second half of fiscal year 2023 and will continue to issue findings and
recommendations to help the EPA safeguard America's water.

Identifying Funds That Could Be Put to Better Use. As we conduct oversight, we aim to promote economy and
efficiency. In the first half of fiscal year 2023, we identified $135 million that could be put to better use. For
example, as we relayed both in our report and in our podcast on the EPA's residential wood heater program, we
found that $82 million for residential wood heater changeout programs may have been wasted because the EPA
cannot ensure that the new wood heaters are actually cleaner than the ones they replace. Findings like this truly
demonstrate the financial benefit of our work—an investment in oversight may identify millions of dollars that
would otherwise be wasted.

In addition, we proactively worked to prevent the mismanagement of funds. For example, in our management
implication report on the mitigation of fraud vulnerabilities, we informed the Agency that grantees and
subrecipients may not be fully aware of key fraud prevention and enforcement measures. We also provided
considerations for the Agency to strengthen its grant-funding mechanisms. Further, we closed five significant
investigations, including one in which a water utility services company and its owner pleaded guilty to submitting
false water samples to a laboratory for lead and copper testing. Overall, we recouped more than $176,000 through
our investigations. Additionally, during ongoing investigative matters, we identified $12,115,000 as potential cost
savings due to possible violations of law, regulation, contract, grant, cooperative agreement, or other agreement
or document governing the expenditure of funds.

Supporting and Protecting Whistleblowers. Whistleblowers play a vital role in our efforts to ensure that Agency
programs and operations are efficient and effective. As such, supporting and protecting whistleblowers remains a
top OIG priority. In March 2023, we issued a management implication report concerning vulnerabilities to our
information security and oversight independence. Specifically, because there was little or no network

-------
segmentation between the EPA and the OIG, certain EPA staff could modify OIG account settings and access
sensitive data, such as emails from whistleblowers. To protect whistleblowers, we promptly addressed these
vulnerabilities and implemented processes to prevent unauthorized access to sensitive information.

Investigating Scientific Integrity Concerns. Throughout this period, we engaged in oversight activities related to
safeguarding scientific integrity. For example, as we detailed in Report No. 23-E-0013, The EPA's January 2021
PFBS Toxicity Assessment Did Not Uphold the Agency's Commitments to Scientific Integrity and Information Quality,
we found that the EPA did not follow its typical process to develop the January 2021 perfluorobutane sulfonic acid
toxicity assessment, and this deviation left public health vulnerable to potential negative impacts. We issued
recommendations to make process-oriented changes that advance the culture of scientific integrity, safeguard
against the alteration of scientific data, and improve employee and public confidence in the Agency's ability to
sufficiently and effectively protect human health and the environment.

Continuing our Mission. As we move into the second half of fiscal year 2023, we will continue to use our resources
efficiently and effectively to help the EPA and the CSB fulfill their respective missions on behalf of the American
taxpayer. With a tremendous need for oversight and limited discretionary dollars, we continue to identify and
conduct projects on issues that are important to the American people and affect their health and the environment.
Ultimately, we serve the American taxpayer.

Sean W. O'Donnell
Inspector General

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Table of C

Section 1: Overview		1

1.1	About the EPA, the CSB, and the OIG		2

1.2	OIG Strategic Planning		3

1.3	Analysis of Unimplemented Recommendations		5

1.4	OIG Hotline		7

1.5	Scientific Integrity and Misconduct		10

1.6	Inspector General Testimony		12

Section 2: Work Accomplished During the Semiannual Period		13

2.1	Oversight Work		14

Infrastructure Investment and Jobs Act		14

Human Health and Environmental Issues		15

Business Practices and Accountability		19

U.S. Chemical Safety and Hazard Investigation Board		21

2.2	Investigative Work		22

2.3	Instances of Whistleblower Retaliation and Interference with Independence		28

Section 3: Statistical Data		29

Summary of Investigative Results		30

Appendixes		33

1—Reports	Issued		34

2—	Management Decisions Relating to Reports Issued During Previous

Reporting Periods 		35

3—Reports	with Corrective Action Not Completed		37

4—Closed	Investigations Involving Senior Employees		48

5—Peer	Reviews Conducted		49

6—OIG	Mailing Addresses and Telephone Numbers		50

-------
SECTION 1:
OVERVIEW

1

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

1.1 About the EPA, the CSB, and the OIG

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, the EPA works to ensure that the public has clean air, land,
and water.

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 investigates chemical incidents and determines the cause or probable cause.

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. §§ 401-424, 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.; at the EPA's ten regional offices; in Research Triangle Park, North
Carolina; and in Cincinnati, Ohio.

OIG Vision

Be a premier oversight organization trusted to speak the truth, promote good governance, and
contribute to improved human health and the environment.

OIG 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.

OIG 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.

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

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: 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 2023 report issued October 28, 2022
CSB FY 2023 report issued October 21, 2022

As required by 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." The EPA OIG identifies top management challenges
facing the EPA by surveying staff at EPA program offices,
soliciting input from senior EPA leadership, conducting
outreach meetings with the Agency's program offices, and
utilizing findings from the OIG's previous reports and
investigations. We also consider the work of the U.S.

Government Accountability Office and public statements by
EPA leaders to the press and Congress.

Similarly, top management challenges facing the CSB are
identified by surveying CSB board members, considering
statements made by CSB leaders to the press and Congress,
and utilizing findings from the OIG's previous audits,
evaluations, and investigations. Based on this feedback, we
identified eight top management challenges facing the EPA
and three for the CSB in FY 2023.

Fiscal Year 2023 Oversight Plan

Oversight Plan, issued January 9, 2023
The Oversight Plan is our guide for the audits, evaluations, and other oversight engagements we intend
to conduct during the fiscal year to fulfill our mission. In developing the Oversight Plan, we focused on
projects related to the OIG-identified top management challenges. We also considered the findings,
recommendations, and observations from previous OIG and U.S. Government Accountability Office
reports; key strategic documents, such as the EPA strategic plan; congressional hearings, legislation, and
feedback from members of Congress; and projects related to the Infrastructure Investment and Jobs Act.
These considerations help ensure that we undertake projects that address the EPA's and the CSB's most
pressing challenges. Since our planning efforts are not static, the projects included in the plan may be
modified as challenges and risks for the EPA and the CSB evolve and emerge.

EPA FY 2023 Management Challenges

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

2. Integrating and leading environmental justice
across the Agency and government.

3. Providing for the safe use of chemicals.

4. Safeguarding scientific integrity principles.

5. Ensuring Agency systems and other critical
infrastructure are protected against
cyberthreats.

6. Managing business operations and resources.

7. Enforcing compliance with environmental
laws and regulations.

8. Managing increased investment in
infrastructure.

CSB FY 2023 Management Challenges

1. Accomplishment of the CSB's mission remains
impaired until the full board is confirmed.

2. Minimize mission critical staff vacancies and
attrition rates.

3. Improve cybersecurity weaknesses.

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Infrastructure Investment and Jobs Act Progress Report—Year One

Issued March 29, 2023

The Infrastructure Investment and Jobs Act, or IIJA, Pub. L. 117-58, provides the EPA with approximately
$60 billion for infrastructure-related purposes, including geographic programs, state and tribal assistance
grants targeting clean-water initiatives, brownfields, Superfund, pollution prevention, and recycling. As of
February 28, 2023, the EPA had obligated approximately 12 percent of its IIJA funds; however, less than
1 percent of the $60 billion in IIJA funds had been expended. The IIJA Progress Report—Year One
summarized the EPA OIG's efforts to provide oversight of the EPA's execution of IIJA funding in year one.

The EPA OIG has received funds that will allow us to oversee the EPA's execution of IIJA programming for
over ten years. As of February 28, 2023, we obligated less than 2 percent of our total appropriated IIJA
funds. Our focus in year one was strategic hiring for mission critical positions. We also issued several
lessons learned reports that summarized previous OIG report findings that are applicable to IIJA-funded
programs.

The OIG's FY 2023-2027 Strategic Plan

Under development

In this semiannual report period, we began developing our next strategic plan, since our current strategic
plan will expire at the end FY 2023. The new strategic plan will document our inspector general's five-year
vision and the OIG's mission.

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

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. This semiannual period, we
issued a compendium that provided an in-depth analysis of all open and unresolved recommendations
issued by the OIG to the EPA and the CSB. We also issued a second compendium that focused on open
and unresolved recommendations specifically concerning programs that received funding under the IIJA.

Before issuing a final report that contains recommendations, 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 can then 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.

• 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)(2) of the Inspector General Act, 5 U.S.C. § 405, as amended by the James M. Inhofe National
Defense Authorization

Act for Fiscal Year 2023, Number of unimplemented recommendations 41

requires that we identify
each recommendation
described in previous
semiannual reports for
which corrective action
has not been completed,
including the potential
cost savings associated
with the

recommendation.1 We FY 2008- FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

interpret potential costs 2017

1 Effective December 27, 2022, the Inspector General Act of 1978 was reorganized and codified as 5 U.S.C. §§ 401-
424; the requirements for the semiannual report to Congress appear in 5 U.S.C. § 405. Section 5273 of the National
Defense Authorization Act for Fiscal Year 2023, however, amended the semiannual reporting requirements as they
had appeared in Section 5 of the Inspector General Act prior to the codification. These revisions are operative law
but are not yet codified in 5 U.S.C. § 405 and instead appear in the statutory notes as amendments not shown in
the text. Accordingly, all citations to particular semiannual reporting requirements will reflect the specific
subsection of section 5 of the IG Act and a general parallel citation to 5 U.S.C. § 405.

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

savings to be the total of questioned costs plus funds put to better use. 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 remained unimplemented as of March 31, 2023: 98 for the
EPA and one for the CSB. The chart below shows when these 99 unimplemented recommendations
were originally issued to the EPA or the CSB. The potential costs savings of the 98 recommendations
issued to the EPA are approximately $74.6 million. There are no potential cost savings associated with
the unimplemented CSB recommendation. Note that the recommendations issued during this
semiannual period are included as part of the report summaries in Section 2.1.

Section 5(a)(7) of the Inspector General Act, 5 U.S.C. § 405, requires that we provide information
described under section 804(b) of the Federal Financial Management Improvement Act of 1996. In our
annual audit of the Agency's FY 2022 and 2021 Consolidated Financial Statements, we determined that
the "results of our tests did not disclose any instances of noncompliance with [Federal Financial
Management Improvement Act of 1996] requirements, including where the Agency's financial
management systems did not substantially comply with the applicable federal accounting standard."
Accordingly, there is no information or outstanding corrective actions to report with respect to the
Federal Financial Management Improvement Act of 1996.

The table below breaks down the 99 unimplemented recommendations issued to the EPA and the CSB
according to their potential health, environmental, and business benefits and identifies the potential
cost savings if these recommendations are implemented. Appendix 3 provides the full text of the
unimplemented recommendations, to include the potential cost savings for each recommendation.

Category

Number remaining
unimplemented

Potential cost savings
associated with unimplemented
recommendations

EPA unimplemented recommendations

1. Administrative and Business
Operations

$46,761,000

2. Human Health and Environmental
Issues

$27,800,000

EPA subtotal

$74,561,000

CSB unimplemented recommendations

1. Management and Operations

CSB subtotal

TOTAL

$74,561,000

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

1.4 OIG Hotline

Section 8M of the Inspector General Act, 5 U.S.C. § 420, 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, 2023. In this period, of 2,874 contacts
received, the OIG made 258 referrals. A contact can be referred to more than one entity.

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, 10/1/2022-3/31/2023

Podcast

Hotline calls
231

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Hotline contacts referred, 10/1/2022-3/31/2023

Categories of the 258 hotline contacts referred to OIG offices

Whistleblower issues

Scientific integrity issues

Program- and operations-related issues

Employee issues

Environmental issues

Potential or alleged criminal activity



Hotline Confidentiality

Individuals who contact the hotline are not required to identify themselves and may request anonymity
or 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, 5 U.S.C. § 407, 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 unless that individual consents or the
inspector general determines that such disclosure is unavoidable during the course of an investigation.
This applies regardless of whether the individual is an EPA or CSB employee. Individuals concerned

8

-------
Semiannual Report to Congress	October 1, 2022-March 31, 2023

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

9

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

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 October 2022, 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 fraud, waste, abuse, and mismanagement, the OIG conducts
investigations related to "research misconduct" and "scientific misconduct," including fabrication,
falsification, or plagiarism in proposing, performing, or reviewing research or reporting research results.
The OIG may refer scientific integrity allegations that it receives to the scientific integrity official. The
scientific integrity official and OIG staff meet 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. 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 subsections report the status of scientific integrity allegations received by the
scientific integrity official and 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 to provide early intervention for the
purpose of preventing lapses in scientific integrity and (2) a procedure for reporting and adjudicating
allegations.

For the semiannual reporting period ending March 31, 2023, the scientific integrity official reported that
the Scientific Integrity Program received two new allegations and 15 new advice queries. Also, during
this semiannual reporting period, two allegations were closed or resolved. As of March 31, 2023, there
were 24 open allegations, all from prior reporting periods.

Scientific Misconduct Allegations Received and Investigated by the OIG

At the beginning of the semiannual reporting period, the OIG had nine open cases involving potential
scientific misconduct. The OIG received four complaints with allegations involving potential scientific
misconduct from Agency employees and other sources during this semiannual reporting period. Two of
these complaints resulted in new investigations. As of March 31, 2023, one investigation was closed. 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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

OIG did not have any relevant results of investigations that it conducted or oversaw to report to the
Agency for a determination of appropriate action.

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 in which 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 an 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 in which the research community or public should be informed.

Additionally, EPA Manual 6500, Functions and Activities of the Office of Inspector General, states, "[e]ach
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, which sets out the mechanism for compliance with
Agency policy, 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 every two weeks to discuss the
status of cases, as appropriate, as well as other scientific integrity-related issues.

Requests for advice or allegations received by the scientific integrity official are not always referred to
the OIG. There also have been several instances where we have learned of scientific integrity policy
violations not directly from EPA personnel, including the scientific integrity official, but coincidentally
through audits and evaluations. In FY 2022, the OIG initiated discussions with the Agency to revise the
coordination procedures between the OIG and the Agency's Scientific Integrity Program related to
information sharing on scientific integrity. In June 2022, the OIG presented revised coordination
procedures to the Agency that would ensure that complaints involving scientific integrity, as well as
other misconduct, were promptly disclosed to the OIG. As of this reporting period, the revised
coordination procedures remain with the Agency for its review. Since the beginning of FY 2023, the OIG
has had to issue monthly information requests to the Agency's Scientific Integrity Program to ensure
that the OIG is receiving all relevant information on potential scientific integrity concerns while the
Agency reviews the OIG's revised coordination procedures. These monthly requests will continue to be
renewed until new coordination procedures are finalized. Revised coordination procedures are essential
to clarify the OIG's access rights and ensure that scientific integrity concerns, as well as allegations of
other wrongdoing, are routed to the proper office and addressed in the most efficient and effective
manner.

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

1.6 Inspector General Testimony

On March 29, 2023, EPA Inspector General Sean
W. O'Donnell testified before the U.S. House of
Representatives Committee on Energy and
Commerce's Subcommittee on Oversight and
Investigations. He, along with U.S. Department
of Commerce inspector General Peggy
Gustafson, U.S. Department of Energy inspector
General Teri Donaldson, and U.S. Government
Accountability Office Natural Resources and
Environment Managing Director Mark Gaffigan,
discussed how their respective agencies are
approaching oversight of the appropriations
from the IIJA, CHIPS and Science Act, and
Inflation Reduction Act.

Regarding the IIJA, Inspector General O'Donnell
testified that the EPA OIG laid the groundwork
for oversight after the Act was enacted by developing a specific IIJA oversight plan and examining
previous EPA OIG, Government Accountability Office, and single audit reports to identify good
governance practices that the EPA could incorporate into its IIJA efforts. He said that EPA OIG oversight
efforts will focus on state revolving funds and best practices in contract and grant awards. The EPA OIG
already has six projects underway examining a range of issues, such as Superfund sites slated for IIJA
cleanup funds, supply chains for funding projects, and the capacity of state revolving funds to manage
an influx of IIJA funds. Five other projects are in the planning stage.

The IRA did not provide any funds for EPA OIG oversight, Inspector General O'Donnell testified, meaning
that the EPA OIG will have to rely on annual appropriations to conduct oversight of both normal Agency
operations and programs as well as IRA-specific operations and programs. He added that although the
lessons learned reports issued for the IIJA could apply to the IRA, both Acts encompass different goals,
offices, and programs.

Inspector General O'Donnell testified that he appreciated the support Congress has given to the EPA
OIG, but more is needed to guarantee proper oversight of EPA's work funded by annual and IRA
appropriations. Without the proper budget, the EPA OIG will have to continue making hard choices
about its work and workforce.

Inspector General Sean W. O'Donnell testifying before the U.S. House of
Representatives Committee on Energy and Commerce, Subcommittee on
Oversight and Investigations. (House Committee on Energy and
Commerce Subcommittee on Oversight and Investigations photo)

-------
SECTION 2:

Work Accomplished
During the Semiannual Period

13

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

2.1 Oversight Work

Summaries of the reports that we issued during the semiannual period, along with the associated
recommendations, are detailed below. Section 5(a)(1) of the Inspector General Act, 5 U.S.C. §405,
requires "a description of significant problems, abuses, and deficiencies relating to the administration of
programs and operations of the establishment" as well as the related reports and recommendations for
corrective action. Section 5(a)(16)(A) of the Act, 5 U.S.C. § 405, requires that we provide a detailed
description of closed audits, inspections, and evaluations not previously disclosed to the public; the OIG
does not have any such instances to report.

Infrastructure Investment and Jobs Act

On November 15, 2021, President Joseph R. Biden Jr. signed the IIJA, Pub. L. 117-58, into law. This Act
appropriated approximately $60 billion to the EPA for FYs 2022 through 2026, a significant increase from
the EPA's annual appropriation, which has ranged from approximately $8.1 billion to $10.1 billion over
the past ten years. The OIG will receive nearly $270 million under the Act to conduct audits, evaluations,
and investigations of EPA programs and entities receiving or affected by IIJA funds.

In accordance with our IIJA Oversight Plan, we focused on helping the EPA plan for this significant increase
in funding by issuing lessons learned reports. We issued one such report during this semiannual period.

American Recovery and Reinvestment Act Findings for Consideration in the
Implementation of the Infrastructure Investment and Jobs Act

Report No. 23-N-0004, issued December 7, 2022

Compliance with the law; Partnering with states and other stakeholders; Operating efficiently and effectively.

0 Managing business operations and resources; Managing increased investment in infrastructure.

Through our analysis of 28 reports related to the EPA's management of its American Recovery and
Reinvestment Act funds, we developed three lessons that the EPA should consider to mitigate risks and
reduce the likelihood of fraud, waste, and abuse of IIJA funds. These lessons are to ensure that federal
requirements are met; provide clear and comprehensive guidance; and improve project management,
monitoring, and data verification. We did not issue any recommendations in this report.

OIG Webpage: "EPA OIG Infrastructure Investment and Jobs Act Oversight"

Launched March 2023, continually updated

We maintain a webpage of our work related to the IIJA to keep the public apprised of our efforts. The
webpage contains our IIJA oversight plan, as well as planned, ongoing, and completed oversight work
related to the IIJA.

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Human Health and Environmental Issues

The EPA Is Not on Track to Reach Its National Compliance Initiative Goals to Stop
Aftermarket Defeat Devices and Tampered Vehicles

Report No. 23-E-0006, issued January 25, 2023

Improving air quality; Partnering with states and other stakeholders.

0 Mitigating causes and adapting to impacts of climate change; Enforcing environmental laws and regulations.

The Office of Enforcement and Compliance Assurance is not on track to achieve 25 percent
of the metrics in the strategic plan for its National Compliance Initiative, Stopping
Aftermarket Defeat Devices for Vehicles and Engines. The strategic plan includes vague,
unquantifiable metrics; EPA offices inconsistently interpret the strategic plan's requirements; the EPA

has not updated the strategic plan to clarify
requirements; and regional staff are not given
adequate technical training. Moreover, the EPA does
not share helpful enforcement data with the states or
incentivize complementary state efforts to implement
the National Compliance Initiative. If the National
Compliance Initiative's goals are not achieved, excess
emissions from aftermarket defeat devices and
tampered vehicles will continue to threaten public and
environmental health.

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

Develop guidance for the regions that outlines how to interpret, track, and report metrics and that defines vague terms
used in the EPA's Stopping Aftermarket Defeat Devices for Vehicles and Engines National Compliance Initiative strategic
plan.

Update the EPA's Stopping Aftermarket Defeat Devices for Vehicles and Engines National Compliance Initiative strategic
plan so that the National Compliance Initiative goals can be achieved in the event of a pandemic or other challenge.

In collaboration with EPA regions, revise and reissue the strategic plan for the Stopping Aftermarket Defeat Devices for
Vehicles and Engines National Compliance Initiative. In addition, ensure the strategic plan includes quantifiable deliverables
that are linked to known compliance-rate baselines that promote the success of the initiative, as well as a mechanism to
acquire and implement post-training feedback from regions and states.

Work with the Office of General Counsel to provide training for headquarters and regional enforcement staff and to release
enforcement data, as appropriate and consistent with applicable legal requirements, that states can use to target and deter
the installation and use of aftermarket defeat devices within their jurisdictions.

Use the OIG's state questionnaire results, as well as feedback from regions and states, to identify and implement a strategy
to overcome barriers and incentivize voluntary complementary work by the states to stop aftermarket defeat devices and
tampering.

Podcast

What Is a National Compliance Initiative?

The EPA focuses its enforcement and compliance
assurance resources on the most serious
environmental violations by developing and
implementing national program priorities, called
National Compliance Initiatives. For more
information on the Stopping Aftermarket Defeat
Devices for Vehicles and Engines NCI, readers can
access the National Compliance Initiatives webpage.

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

The EPA's Residential Wood Heater Program Does Not Provide Reasonable
Assurance that Heaters Are Properly Tested and Certified Before Reaching
Consumers

Report No. 23-E-Q012. issued February 28, 2023

£*• Improving air quality; Compliance with the law; Operating efficiently and effectively.

Enforcing environmental laws arid regulations; Integrating and leading environmental justice, including communicating risks.

The EPA's residential wood heater program does not ensure that wood heaters are
properly tested and certified before reaching consumers. The EPA's 2015 New Source
Performance Standards for wood heaters is flawed, and the EPA's approved test methods

are unclear and too flexible. As a result, certification tests may
not be accurate, do not reflect real-world conditions, and may
result in some wood heaters being certified for sale that emit
too much particulate-matter pollution. The EPA also lacks
internal controls to ensure that certification test reports are
valid and that certification tests are conducted appropriately.
State regulators indicated that they cannot rely on the EPA's
certifications of wood heaters and, therefore, developed their
own standards and lists of approved wood heaters. The
$82 million in grants that the EPA has provided for wood
heater changeout programs could be wasted if the
replacement wood heaters are not cleaner than the old wood
heaters.

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

1 Develop internal controls for the residential wood heater program to improve the certification process and oversight,
including but not limited to:

a. Issuing a standardized certification test report template.

b. Developing policies and procedures that detail how to conduct in-depth reviews of certification test reports.

c. Periodically observing certification testing.

d. Developing and implementing guidance for conducting systematic compliance audit tests.

2 In consultation with the Office of Air and Radiation, define roles and responsibilities within and between the Office of
Enforcement and Compliance Assurance and the Office of Air and Radiation for the residential wood heater program, so that
sufficient subject-matter expertise and resources are leveraged to ensure that certification test reports are substantively
reviewed.

3 Develop and implement a plan to demonstrate whether residential wood heaters certified using the test methods based on
ASTM E3053 comply with the New Source Performance Standards for residential wood heaters.

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

4 Incorporate the EPA's certification test report expectations set forth in the April 2022 corrective action list into the 2023
revisions to the New Source Performance Standards for residential wood heaters.

Podcast

Residential wood heater in home. (EPA OIG photo)

Report Addresses: £*• EPA mission-related effort. Top management challenge for EPA, Mandatory reporting requirement. Follow-up report.

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

The EPA Met 2018 Water Security Requirements but Needs to Improve Oversight
to Support Water System Compliance

Report No. 23-P-0003, issued November 21, 2022

Ensuring clean and safe water; Compliance with the law.

0 Protecting information technology and systems against cyberthreats; Managing infrastructure funding and business operations.

The EPA met the requirements of section 2013 of the America's Water Infrastructure Act of 2018, but
19 percent of water systems did not certify that they had completed their risk and resilience
assessments by the statutory deadline, making them vulnerable to cyberattacks and other malevolent
acts. These noncompliant systems serve 40 million people. About 95 percent of the noncompliant water
systems were small water systems, which are more likely to serve disadvantaged communities. The EPA
did not adequately oversee these water systems to ensure that they complied with the Act's
requirements, specifically maintaining contact information, publishing guidance regarding enforcement
actions against noncompliant water systems, providing assistance to support small water compliance, or
reviewing the quality of their risk and resilience assessments and emergency action plans.

i





Risk and resilience
assessment
deadlines



Community water
system size

Population served

Emergency response
plan
deadlines

Large

>100,000

March 31, 2020

September 30, 2020

Medium

50,000 - 99,999

December 31, 2020

June 30, 2021

Small

3,301 -49,999

June 30, 2021

December 31, 2021

Source: OIG summary of certification deadlines set by section 2013 of America's Water Infrastructure Act of 2018.
(EPA OIG image)

Recommendations for corrective action issued to the assistant administrator for Water:

1	In consultation with the assistant administrator for Enforcement and Compliance Assurance, as appropriate, update and
implement a plan for supporting community water systems so that all water systems comply with all certification
requirements included in section 2013 of the America's Water Infrastructure Act, for past and future deadlines related to
risk and resilience assessments and emergency response plans.

2	In consultation with the assistant administrator for Enforcement and Compliance Assurance, as appropriate, update
processes related to the EPA's implementation of section 2013 of the America's Water Infrastructure Act, including
processes to monitor community water system compliance with section 2013 and record noncompliance and contact
information in the EPA's Safe Drinking Water Information System database. These processes should be documented in the
EPA's Water Supply Guidance Manual.

3	In consultation with the assistant administrator for Enforcement and Compliance Assurance, as appropriate, review a
sample of risk and resilience assessments and emergency response plans completed by community water systems under
section 2013 of the America's Water Infrastructure Act to determine improvements, particularly in cybersecurity, that can
be made as the water systems complete the Act's ongoing certification

requirements.

4	In consultation with the assistant administrator for Enforcement and Compliance Assurance, as appropriate, develop
formal guidance for community water systems that clearly describes the America's Water Infrastructure Act section 2013
requirements, including certification deadlines, enforcement steps, and the improvements identified as a result of
Recommendation 3. Incorporate this guidance into the EPA's Water Supply Guidance Manual.

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

17

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

The EPA's January 2021 PFBS Toxicity Assessment Did Not Uphold the Agency's
Commitments to Scientific Integrity and Information Quality

Report No. 23-E-0013, issued March 7, 2023

Operating efficiently and effectively.

0 Safeguarding scientific integrity.

Podcast

The EPA did not follow the typical intra-agency review and clearance process for the
perfluorobutane sulfonic acid, or PFBS, toxicity assessment that was published in January
2021. A political appointee directed that a last-minute review be conducted, which

resulted in a scientific disagreement and
changes to the previously peer-reviewed product. These
changes included the unprecedented presentation of
toxicity ranges. If regulated entities cleaning up PFBS
contamination, for example, selected the less stringent
value within the toxicity ranges, the cleanups may have
been less protective of human health. While EPA staff
expressed scientific integrity concerns about the
last-minute review and risks to public health, the EPA lacked
procedures to address these concerns, despite OIG
recommendations issued in May 2020 for the EPA to
develop such procedures. Without these procedures, the
Agency cannot fulfill its commitment to scientific integrity
and information quality.

Per- and polyfluoroalkyl substances molecules
depicted on the cover of the EPA's Per- and
Polyfluoroalkyl Substances (PFAS) Action Plan,
dated February 2019. (EPA image)

Recommendations for corrective action issued to the assistant administrator for Research and Development:

1 Develop or update existing policies, procedures, or guidance to specify whether and under which applicable circumstances
comments expressing scientific disagreement can be provided for a scientific product that has undergone all peer reviews
and required developmental steps set forth in applicable actions or project plans.

2 Develop or update existing policies, procedures, or technical documents to specify whether reference dose ranges are
acceptable in toxicity assessments. If acceptable, specify circumstances under which reference dose ranges may be applied.

5 Update the EPA's Scientific Integrity Policy to require that the OIG be immediately notified of scientific integrity concerns,
including advice queries and allegations, that relate to political interference or that assert risks to human health or the
environment.

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

3 Update EPA policies and procedures on environmental information quality to require additional quality assurance reviews
for EPA products that undergo major changes to scientific results or conclusions after quality assurance reviews have been
completed.

Recommendations for corrective action issued to the deputy administrator:

4 Develop or update existing policies, procedures, or guidance to require policy-makers and decision officials to uphold

transparency through timely, formal communication of decisions and the scientific bases to change results or conclusions of
a scientific product to originating authors in the absence of peer review.

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Business Practices and Accountabilit

The EPA's Fiscal Years 2022 and 2021 Consolidated Financial Statements

Report No. 23-F-0002, issued November 15, 2022
Operating efficiently and effectively.

0 Managing infrastructure funding and business operations.

We rendered an unmodified opinion on the EPA's consolidated financial statements for fiscal years 2022
and 2021, meaning that they were fairly presented and free of material misstatement. We noted the
following significant deficiencies:

• The EPA improperly recorded Water Infrastructure Finance and Innovation Act of 2014 fee fund
revenue.

• The unearned advances account had an abnormal balance.

• Unneeded funds were not deobligated in a timely manner.

• Capitalized software-in-development costs were inaccurately recorded.

• The EPA processed standard vouchers without adequate procedures.

Recommendations for corrective action issued to the chief financial officer:

1 Analyze exchange and nonexchange revenue general ledger accounts and reclassify fiscal year 2022 Water Infrastructure
Finance and Innovation Act nonexchange revenue to exchange revenue.

2 Update the Water Infrastructure Finance and Innovation Act expense accounting models to properly impact exchange
revenue.

3 Research and correct the $9 million activity in the Unearned Advances, Non-Federal general ledger account to ensure
unearned advances are properly reflected in the financial statements.

4 Identify any abnormal balances in advance general ledger accounts and make necessary corrections to ensure debit and
credit balances are properly reflected.

5 Reiterate to headquarters program offices and regional offices the importance of deobligating unneeded funds identified
during the annual unliquidated obligations review by the end of the fiscal year.

6 In coordination with the assistant administrator for Chemical Safety and Pollution Prevention, implement a plan to ensure
that Pesticide Registration Information System software-in-development costs are recorded accurately and timely.

7 Incorporate in Resource Management Directive System 2530-02, Processing Journal Vouchers and Standard Vouchers,
responsibilities for all regional offices that post voucher transactions into Compass Financials to ensure consistent
accounting and financial management operations.

Recommendations for corrective action issued to the regional administrator for Region 4:

8 Establish standard operating procedures for the processing of standard vouchers that include applicable internal control
elements to ensure transactions are complete, accurate, and effectively monitored through reviews and approvals.

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

The EPA's Fiscal Years 2020 and 2019 Toxic Substances Control Act Service Fee
Fund Financial Statements

Report No. 23-F-0005, issued December 29, 2022

Operating efficiently and effectively.

£ Managing business operations and resources.

We rendered a qualified opinion on the EPA's fiscal years 2020 and 2019 Toxic Substances Control Act
Service Fee Fund financial statements, meaning that, except for material errors in expenses and income
from other appropriations, the fiscal years 2020 and 2019 financial statements were fairly
presented. The EPA materially misstated the expenses from other appropriations that supported the
Toxic Substances Control Act Service Fee Fund by nearly $25 million. The EPA's initial draft financial
statements incorrectly reported that all $63 million of the Office of Chemical Safety and Pollution
Prevention's expenses in the Chemical Risk Review and Reduction Program were Toxic Substances
Control Act Service Fee Fund expenses from other appropriations. The Agency acknowledged that
certain costs were improperly included in expenses from other appropriations and subsequently
modified its methodology and revised the financial statements. The Agency's revised methodology
reduced Toxic Substances Control Act expenses from other appropriations from approximately
$63 million to roughly $19 million. The EPA's revised methodology did not adequately capture all
expenses for carrying out sections 4, 5, 6, and 14 of the Toxic Substances Control Act. Costs not captured
increased Toxic Substances Control Act expenses from other appropriations to approximately
$44 million.

Recommendations for corrective action issued to the chief financial officer:

1 Correct the methodology for accounting for Toxic Substances Control Act direct and indirect expenses from other
appropriations to ensure all costs for administering sections 4 and 5, parts of section 6, and section 14 of the Act are
properly recorded and reported in the financial statements.

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

U.S. Chemical Safety and Hazard Investigation Board

Contractor-Produced Report: U.S. Chemical Safety and Hazard Investigation
Board Fiscal Years 2022 and 2021 Financial Statement Audit

Report No. 23-F-0001. issued November 15, 2022

An independent auditor rendered an unmodified opinion on the CSB's financial statements for fiscal
years 2022 and 2021, meaning that the statements were fairly presented and free of material
misstatements. The audit disclosed one instance of noncompliance or other matters that are required to
be reported. During fiscal year 2022, the CSB reported a violation of the Antideficiency Act that occurred
during fiscal year 2020 related to the purchase of office furniture.

Recommendations for corrective action issued to CSB management:

1	Update CSB policies and guidance to include the limits on expenditures for office furniture and related improvements for
political appointees.

2	Provide training to CSB staff and Board members on the limits of expenditures on office furniture and related
improvements for political appointees.

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

21

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

2.2 Investigative Work

Section 5(a)(3) of the Inspector General Act, 5 U.S.C. § 405, requires a summary of significant closed
investigations during the reporting period. We are also reporting investigations that have not yet been
officially closed, but in which there has been significant activity during the reporting period to include
convictions or guilty pleas. The OIG also conducts administrative investigations into allegations of
misconduct by senior Agency employees.

Closed Significant Investigations

Individuals Found Guilty of Stealing EPA Equipment Trailer

On March 3, 2021, an individual was found guilty in the Circuit Court of the State of Oregon for the
County of Multnomah of one count of theft in the first degree. On April 19, 2021, the individual was
sentenced to supervised probation for a period of 36 months and ordered to pay restitution to the EPA
for $856.04. Another individual was found guilty on September 24, 2021. On November 30, 2022, that
individual was sentenced to 18 months in prison and post-prison supervision for 24 months and ordered
to pay restitution to the EPA for $856.00. Both individuals were responsible for the theft of an EPA
equipment trailer containing emergency response equipment, including personal protective equipment,
in Portland, Oregon.

Utility Services Company and Owner Plead Guilty to False Sample Submissions

On May 25, 2022, a water utility services company and its owner pleaded guilty in the Superior Court of
Thurston County in Olympia, Washington, for their roles in defrauding state regulators and customers by
submitting false water samples to a laboratory for lead and copper testing. EPA regulations require
water systems to collect and analyze water samples from homes and businesses to determine whether
lead is present in the water distribution system. The company was charged with one felony count of
offering false instrument for filing or record, and the owner was charged with one count of attempted
offering false instrument for filing or record. The company was assessed a $5,000 fine, and the owner
received a suspended sentence of 364 days of imprisonment and a $5,000 fine, which was to be
suspended upon successful completion of 80 hours community service and two years of probation. The
Washington State Attorney General's Office Environmental Protection Division prosecuted this case.

Company Debarred for Not Properly Accounting for EPA Funding

On October 19, 2022, a company was debarred for 18 months from participating in federal procurement
and nonprocurement programs for not properly accounting for EPA federal funding. The company
violated the terms of a public agreement or transaction so serious as to affect the integrity of an Agency
program. In addition, the company provided false and misleading statements about a purported loan by
another company that was not actually consummated, obligated, or disbursed. Further, the company did
not have adequate internal controls in place and did not exercise effective financial management over
grant funds received and funds accrued pursuant to a cooperative agreement award with the EPA. The
investigation determined that the company was not a presently responsible contractor or participant.

EPA Employee Practiced Law Without a Law License

An EPA GS-14 attorney adviser practiced law without a law license from approximately April 2021 to
July 2022 while representing the EPA. The investigation determined that the EPA employee's law license
was suspended after the employee failed to complete the required minimum continuing legal education
requirements for 2018 to 2020 and for not paying the required registration payment for 2021. The
investigation also determined that the EPA employee signed self-certifications for 2021 and 2022

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

attesting to having an active law license in one of the 50 states. The EPA employee retired from the EPA
in lieu of a proposed removal.

New York Corporation Falsely Certifies Individuals Were Employees

On September 1, 2022, the New York State Environmental Facilities Corporation, a public benefit
corporation, entered into an agreement with the U.S. Department of Justice, Northern District of New
York, to pay $500,000 to resolve allegations that it falsely certified several individuals were working at
the corporation in support of an EPA water-quality improvement grant for the state's Clean Water
State Revolving Fund program. The investigation determined, and the Environmental Facilities
Corporation acknowledged, that these individuals were instead working directly for former governors
of New York in positions unrelated to the EPA grant and the Clean Water State Revolving Fund
program. As part of a settlement agreement, the Environmental Facilities Corporation admitted that
now-former senior corporation officials caused the state to include part of these individuals' salaries
and benefits in federal funding requests without disclosing that the individuals were hired by and
worked for the Office of the Governor. During the prior reporting period, the OIG presented this matter
to the EPA Suspension and Debarment Division for administrative action; the case was closed after the
division declined to pursue action.

This was a joint investigation with the Federal Bureau of Investigation.

Open Significant Investigations

Laboratory Co-Owner Pleaded Guilty to Reporting False Test Results

On January 30, 2023, the co-owner of a water testing laboratory company in Bridgeport, West Virginia,
pleaded guilty in U.S. District Court, North District of West Virginia, to making a false representation in
violation of 18 U.S.C. §§ 1001 and 2(a) and faces up to five years in prison and a fine of no more than
$250,000. The company purportedly tested public drinking water samples submitted to it pursuant to the
Safe Drinking Water Act. In May 2021, the City of Martinsburg, West Virginia, sent water samples to the
laboratory company for testing and the co-owner reported that the samples were tested and found to be
safe. The investigation determined that the co-owner of the company did not test the water samples
because the laboratory equipment was not operational. When Martinsburg reported the test results to
the State of West Virginia pursuant to EPA regulations, the city unwittingly reported false test results.

This was a joint investigation with the EPA Criminal Investigation Division.

Individual Pleaded Guilty for Sales of Unregistered Pesticides

On December 8, 2022, a Burlington, New Jersey, individual was sentenced in U.S. District Court, District
of New Jersey, to five years in federal prison and three years of supervised release, as well as forfeiture
of $2.74 million. The court further ordered restitution to be set at a future hearing. The individual
previously had pleaded guilty to an information—which is a formal charging document that describes
the criminal charges against a person and the factual basis for those charges—charging him with one
count each of knowingly distributing or selling an unregistered pesticide in violation of the Federal
Insecticide, Fungicide, and Rodenticide Act; wire fraud; and presenting false claims to the United States.
According to the individual's plea agreement, from March 2020 through May 2021, the individual used
fraudulent representations to make more than 150 sales of unregistered pesticides for a profit of more
than $2.74 million. The purchasers of these unregistered pesticides included a Delaware police
department; a Virginia fire department; a Georgia medical clinic; a New York janitorial supply company;
a Wisconsin school district; and numerous U.S. government agencies, including the U.S. Marshals
Service, Moody Air Force Base, the U.S. Department of Veterans Affairs, and the National Forest Service.

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Pursuant to the Federal Insecticide, Fungicide, and Rodenticide Act, the EPA is responsible for regulating
the manufacture, labeling, and distribution of all pesticides shipped or received in interstate commerce.

This was a joint investigation with the EPA Criminal Investigation Division, Homeland Security
Investigations, the Department of Defense OIG Defense Criminal Investigative Service, and the Naval
Criminal Investigative Service.

Company Falsely Claimed Cleaning Product Was EPA-Approved

On December 1, 2022, two San Diego businessmen and their business pleaded guilty in U.S. District
Court, Southern District of California, to defrauding customers by falsely claiming that their company's
antimicrobial cleaning product was tested and approved by the EPA to eliminate bacteria and viruses,
including the SARS-CoV-2 virus, which causes the COVID-19 disease, on treated surfaces for one year
with a single application. The investigation determined that the products sold under the company's
name were not registered as pesticides by the EPA, as required by law. A product that is not a registered
pesticide cannot have antimicrobial claims. Pesticides that are unregistered may not be sold or
distributed in the United States. In pleading guilty, the company admitted that it sold over $800,000
worth of the unregistered pesticides.

This was a joint investigation with the EPA Criminal Investigation Division, Homeland Security
Investigations, and the U.S. Postal Inspection Service.

Defense Contractor Provided False Information About Electronic Equipment

On March 7, 2023, a Maryland defense contractor was found guilty in U.S. District Court, District of
Maryland, of wire fraud, false claims, and making and using a false document in connection with his
companies' performance on federal contracts. From February 10, 2015, through June 30, 2020, the
contractor engaged in a scheme to defraud the government by entering into contracts with federal
agencies, including the EPA, which required the contractor's two companies to provide new
telecommunications equipment that was still under manufacturers' warranty. The evidence at trial
showed that in the contractor's communications with federal agency contracting officers, the contractor
provided false information about the delivery, source, warranty, and condition of the electronic
equipment provided by the companies. This included misrepresentations that the equipment was new
and protected by the manufacturers' warranty when the contractor knew that the equipment was not
new, was new but not under warranty, or was procured through unauthorized channels. The contractor
also provided government contracting officials with false information and documents about the
companies' credentials, certifications, and qualifications to falsely certify the companies' status as
authorized partners of two telecommunications equipment manufacturers.

This was a joint investigation with the Naval Criminal Investigative Service, the U.S. Department of Labor
OIG, the Army Criminal Investigation Division, the U.S. Department of State OIG, the U.S. Department of
Commerce OIG, the U.S. Department of the Interior OIG, the Defense Criminal Investigation Service, the
U.S. Department of Homeland Security OIG, the U.S. Department of Health and Human Services OIG, and
the U.S. Department of Justice OIG.

Individuals Indicted for Conspiracy Against Not-For-Profit

On January 24, 2023, two individuals were indicted in the U.S. District Court, District of New Mexico, for
conspiracy to commit wire fraud and money laundering. One of the individuals was employed by a
501(c)(3) not-for-profit organization headquartered in Sante Fe, New Mexico. The not-for-profit
organization's goal was to protect and restore wildlife, natural resources, and ecosystems of the
American West. The not-for-profit organization received federal funding for restoration projects through
grants from federal agencies, such as the EPA and the U.S. Department of the Interior. From February
2015 through April 2019, the two individuals allegedly conspired to inflate hours billed to the

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

not-for-profit organization and allegedly diverting more than $250,000 from the entity. If convicted,
both individuals face up to 20 years in prison.

This was a joint investigation with the U.S. Department of the Interior OIG.

The EPA Found That Tribe Should Repay Disallowed Costs

Based on an OIG investigation of a tribal staff member and tribal leader allegedly embezzling EPA grant
funds, EPA Region 9 reviewed a tribal grant recipient's drawdowns and expenses stated in quarterly
performance reports for the grant. That review and investigation determined that the tribe could not
support the expenditure of $220,364 of the EPA grant funds. The EPA initiated an enforcement action
against the tribe and issued a formal Agency decision finding that the tribe must repay the EPA $220,364
in disallowed costs. In its appeal, the tribe asserted that because the EPA grant funds were embezzled
and the tribe was not involved in expenditure of the funds, it was not responsible for repaying the
disallowed costs and that the EPA should terminate the debt. In August 2021, the EPA reaffirmed its
position requiring the tribe to repay the debt based on many factors, including that there was never a
legal finding that funds were embezzled, as well as case law that determined embezzlement is not an
allowable cost. Although the tribe further disputed the debt in 2022, requesting that it be eliminated or
substantially reduced, the EPA denied the tribe's request in January 2023, noting that the tribe failed to
exercise its right to appeal the EPA's 2021 decision to the regional administrator.

Management Implication Reports

Mitigation of Grant Fraud Vulnerabilities

Issued March 30, 2023

EPA grantees and subrecipients may not be fully aware of key fraud prevention and enforcement
measures. The EPA should clearly communicate the criminal, civil, and administrative consequences of
fraudulent conduct throughout the life cycle of a grant; add OIG reporting requirements and
whistleblower protection provisions to its standard terms and conditions; and ensure that the OIG has
timely access to the records and personnel of grantees and subrecipients. We notified the Agency of the
above issues so that it may take whatever steps deemed appropriate.

Vulnerabilities to EPA OIG Information Security

Issued March 15, 2023

We identified vulnerabilities related to the EPA's network structure that allowed EPA network
administrators to modify OIG account settings and to access and view sensitive OIG information, including
email and other data of senior OIG employees and sensitive shared email inboxes. We suggested to the
EPA's Office of Mission Support that OIG information technology specialists have sole access to administer
the OIG accounts and that OIG accounts be segmented to prevent EPA employees from accessing and
modifying those accounts. We have already transferred control of our confidential and sensitive shared
email accounts to OIG email administrators and regularly review the account audit reports for these
shared accounts to ensure the integrity of authorized users and access lists for those accounts.

Senior Employee Investigations

The Administrative Investigations Directorate conducts administrative investigations of allegations of
misconduct by senior agency employees. Senior agency employees include an officer or employee in the
executive branch, including a special government employee as defined in 18 U.S.C. § 202, who occupies

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

a position classified at or above level 15 of the General Schedule or, in the case of positions not under
the General Schedule, for which the rate of basic pay is equal to or greater than 120 percent of the
minimum rate of basic pay payable for GS-15. Senior government employees include members of the
senior executive service; political appointees; and scientific and professional and senior-level positions.

There were no Reports of Investigation issued during the reporting period involving allegations of senior
employee misconduct.

Since 2021, the OIG has requested timely notification of misconduct complaints the Agency receives
against senior Agency employees; however, the OIG has encountered recurring issues with the Agency
in obtaining timely and comprehensive access to this information. For example, the Office of Mission
Support, through its Labor and Employee Relations Division, initially resisted providing this information,
questioning the OIG's business justification for seeking information about potential senior official
misconduct. In October 2021, after the OIG outlined to leadership in the Office of Mission Support and
the Office of General Counsel its need for this information as part of the OIG's oversight work, the Office
of Mission Support agreed to produce reports regarding senior employee misconduct matters to the OIG
in conjunction with biweekly coordination meetings with the OIG, the Office of General Counsel, and the
Office of Mission Support.

In February 2023, the OIG flagged inconsistencies in the Agency's senior employee misconduct reporting.
On March 14 and March 22, 2023, the Labor and Employee Relations Division disclosed that it identified
at least ten misconduct matters from April 2022 to March 2023 that were not reported to the OIG. In
furtherance of the OIG's work in investigating senior employee misconduct and pursuant to its access
rights under the Inspector General Act, the OIG requested that information regarding these matters be
produced by March 24, 2023. The Labor and Employee Relations Division refused to timely produce the
requested information, resuscitating its requirement that the OIG provide a business justification for why
it needed information about potential senior employee misconduct and adding a requirement that it
evaluate the OIG's request under the Privacy Act. The information was ultimately produced on April 6
after the OIG elevated the matter to the Office of General Counsel and the deputy assistant administrator
for Mission Support. On April 20, 2023, the Labor and Employee Relations Division disclosed that it had
identified an additional thirteen senior official misconduct matters that were not reported to the OIG.

As another example, during the reporting period, the OIG discovered that Scientific Integrity Program
staff had significantly delayed alerting the OIG to allegations of senior employee misconduct and had not
provided timely and complete responses to OIG requests for information. Further details on the OIG's
steps to ensure the Scientific Integrity Program timely provide information of potential wrongdoing to
the OIG is discussed in Section 1.5, "Scientific Integrity and Misconduct."

Report 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 either the OIG's Office of Investigations or Administrative
Investigations Directorate issues a Report of Investigation that has at least one "supported" allegation, it
will generally request 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. When the OIG's Administrative Investigations Directorate
issues a Report of Investigation pursuant to 41 U.S.C. § 4712, the entity receiving the report is statutorily
required to take a specified action or deny relief within 30 days. 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- or 30-day period. For the reporting period ending March 31, 2023, the Administrative

26

-------
Semiannual Report to Congress	October 1, 2022-March 31, 2023

Investigations Directorate issued one Report of Investigation pursuant to 41 U.S.C. § 4712 and received
zero responses outside the 30-day window.

ADMINISTRATIVE INVESTIGATIONS
DIRECTORATE

Administrative Investigations Directorate

©-—®

1 report of investigation issued

REPORT
OF



INVESTIGATION



27

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

2.3 Instances of Whistleblower Retaliation
and Interference with Independence

Whistleblower Retaliation

Section 5(a)(14) of the Inspector General Act, 5 U.S.C. § 405, 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 was one case closed within the semiannual
period ending March 31, 2023, involving whistleblower retaliation.

On November 30, 2022, the OIG issued a Report of Investigation to the EPA identifying retaliation
against an employee of a tribal EPA grant recipient, in violation of 41 U.S.C. § 4712. Specifically, the OIG
assessed whether the tribe engaged in retaliation when it took four covered actions against an
employee who made protected disclosures. We determined that the retaliation allegations could be
sustained with respect to two of the covered actions: removal of the complainant's laptop and
restrictions on the complainant's communications with federal agencies. We determined that the
retaliation allegations could not be sustained with respect to the two other covered actions: restrictions
on the complainant's use of overtime and termination of the complainant's employment.

In response to this report, the EPA determined that sovereign immunity barred it from taking action.
The EPA noted that even if sovereign immunity did not apply it would not order corrective action.
Although the EPA agreed with the OIG's determination on all four covered actions, it noted that there is
no available corrective action regarding the tribe's removal of the complainant's laptop or restrictions
on the complainant's communications with federal agencies, as he is no longer a tribal employee. Thus,
the Agency denied the complainant relief under 41 U.S.C. § 4712(c)(1).

Interference with Independence

Section 5(a)(15) of the Inspector General Act, 5 U.S.C. § 405, requires a detailed description of any
attempt by the EPA or the CSB to interfere with the independence of the OIG, including "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.

Generally, we will report on incidents responsive to section 5(a)(15) 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, 2023.

-------
SECTION 3:
STATISTICAL DATA

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Summary of Investigative Results

Section 5(a)(4) of the Inspector General Act, 5 U.S.C. § 405, requires a listing of the total convictions for
the reporting period that resulted from investigations, and section 5(a)(ll) of the Act, 5 U.S.C. § 405,
requires statistical tables identifying the total number of investigative reports, the total number of
people referred for criminal prosecution during the reporting period, and the total number of
indictments and criminal informations during the reporting period that resulted from prior referrals to
prosecuting authorities. We also provide additional statistical information relating to the results of our
investigative work, including cases and complaints opened, and the results of criminal, civil, and
administrative actions.

For the semiannual period ending March 31, 2023:

Summary of investigative activity

Cases open as of October 1, 2022*

133

Cases opened during period

84

Cases closed during period

41

Cases open as of March 31, 2023

176



Preliminary inquiries open as of October 1, 2022**

51

Preliminary inquiries opened during period

73

Preliminary inquiries closed during period

63

Preliminary inquiries open as of March 31, 2023

61

* Adjusted from prior period; investigation had been erroneously identified as open because of a glitch in the case management system that
unpopulated the "date closed" entry.

** Adjusted from prior period; investigation had been erroneously identified as open because of a glitch in the case management system that
unpopulated the "date closed" entry. Another was removed and reopened as a proactive initiative.

Results of criminal and civil actions



EPA OIG only

Joint*

Total

Criminal indictments/informations/complaints**

0

6

6

Convictions***

0

1

1

Civil judgments/settlements/filings

0

0

0

Criminal fines and recoveries

$0

$856

$856

Civil recoveries

$0

$0

$0

Prison time

0 months

78 months

78 months

Prison time suspended

0 months

72 months

72 months

Home detention

0 months

0 months

0 months

Probation

0 months

60 months

60 months

Community service

0 hours

0 hours

0 hours

* With one or more 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.

30

-------
Semiannual Report to Congress
Administrative actions

October 1, 2022-March 31, 2023

EPA OIG only	Joint*	Total

Suspensions

0

0

0

Debarments

1

0

1

Other administrative actions

12

1

13

Total

13

1

14

Administrative recoveries**

$176,548

$220,364

$396,912

Cost savings***

$12,420,507

$0

$12,420,507

* With one or more other federal agencies.

** Administrative recoveries include restitutions, reimbursements, fines, recoveries, repayments, and the dollar values of recovered government
equipment.

*** Out of the total amount, $12,115,000 was identified as potential cost savings because of an alleged violation of a provision of a law,
regulation, contract, grant, cooperative agreement, or other agreement or document governing the expenditure of funds. Of that amount,
$305,507 were identified as costs the Agency avoided based on investigative results.

Summary of investigative reports issued and referrals for prosecution*

Number of investigative reports issued**

1

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

11

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

0

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

2

* Investigative reports comprise final, interim, and supplemental Reports of Investigation, as well as Final Summary Reports. In calculating the

number of referrals, corporate entities were counted as "persons."

** This number may differ from the numbers reported in the Reports of Investigation section.

Subjects of employee integrity investigations



Political
appointee

SES

GS-15

GS-14
and
below

Misc.*

Total

Pending as of October 1, 2022

4

5

12

17

15

53

Opened

0

4

2

7

6

19

Closed

0

2

4

12

1

19

Pending as of March 31, 2023**

2

7

11

15

17

52

Notes: SES stands for Senior Executive Service. 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, 2023, may not add up due to investigative developments resulting in subjects being added or changed.

31

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

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

Subjects of employee integrity investigations: number of individuals by grade

2 Political appointees

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

32

-------
APPENDIXES

33

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Appendix 1—Reports Issued

Section 5(a)(5) of the Inspector General Act, 5 U.S.C. § 405, requires a listing of each audit, inspection, or evaluation report issued by
the OIG during the reporting period. For each report, where applicable, the Act also requires identification of the dollar value of
questioned costs, including unsupported costs, and the dollar value of recommendations that funds be put to better use, including
whether a management decision had been made by the end of the reporting period.

Report Questioned Unsupported Funds Put to Management
number Report title	Date	Costs	Costs	Better Use	Decision*

EVALUATIONS IN ACCORDANCE WITH

QUALITY STANDARDS FOR INSPECTION AND EVALUATION

23-E-0006

The EPA is Not Track to Reach Its National Compliance Initiative
Goals to Stop Aftermarket Defeat Devices and Tampered Vehicles

1/25/23

$0.00

$0.00

$0.00

No

23-E-0012

The EPA's Residential Wood Heater Program Does Not Provide
Reasonable Assurance that Heaters are Properly Tested and Certified
Before Reaching Consumers

2/28/23

$0.00

$0.00

$0.00

No

23-E-0013

The EPA's January 2021 PFBS Toxicity Assessment Did Not Uphold
the Agency's Commitments to Scientific Integrity and Information
Quality

3/7/23

$0.00

$0.00

$0.00

No



SUBTOTAL = 3



$0.00

$0.00

$0.00



FINANCIAL AUDITS IN ACCORDANCE WITH

GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS











23-F-0001

U.S. Chemical Safety and Hazard Investigation Board Fiscal Years
2022 and 2021 Financial Statement Audit

11/15/22

$0.00

$0.00

$0.00

Yes

23-F-0002

The EPA's Fiscal Years 2022 and 2021 Consolidated Financial
Statements

11/15/22

$0.00

$0.00

$5,833,571.00

Yes

23-F-0005

The EPA's Fiscal Years 2020 and 2019 Toxic Substances Control Act
Service Fee Fund Financial Statements

12/29/222

$0.00

$0.00

$24,565,455.00

Yes



SUBTOTAL = 3



$0.00

$0.00

$30,399,026.00



PERORMANCE AUDITS IN ACCORDANCE WITH
GENERALLY ACCEPTED GOVERNMENT AUDITING STANDARDS

23-P-0003 The EPA Met 2018 Water Security Requirements but Needs to	11/21/22	$0.00	$0.00	$0.00	No

Improve Oversight to Support Water System Compliance

SUBTOTAL = 1	$0.00	$0.00	$0.00

TOTAL REPORTS ISSUED = 7	$000	$0.00 $30,399,026.00

* "Yes" indicates that there was a management decision made regarding all recommendations in the report. "No" indicates that a management decision was not made regarding the
recommendations in the report. There were no reports this reporting period for which a management decision was made regarding some recommendations but not others.

34

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Appendix 2—Management Decisions Relating to Reports Issued
During Previous Reporting Periods

Section 5(a)(6) of the Inspector General Act, 5 U.S.C. § 405, requires information regarding "any management decision made
during the reporting period with respect to any audit, inspection, or evaluation issued during a previous reporting period."

For Reporting Period Ending March 31, 2023: Management Decisions on Prior Unresolved
Recommendations Within This Six-Month Period

Report

Recommendation

Action
official

Management decision

Decision date

Report No. 22-F-0062. The
EPA's Fiscal Years 2021 and
2020 (Restated) Hazardous
Waste Electronic Manifest
System Fund Financial
Statements, issued
September 30, 2022

1. Correct the accounts receivable and
earned revenue balances.

Office of
the Chief
Financial
Officer

The Agency provided a response on
November 22, 2022, which outlined the EPA's
planned corrective actions and estimated
completion date for the unresolved
recommendation. Based on the information and
supporting documentation provided, we believe
the corrective actions meet the intent of the
recommendation. All recommendations for the
subject report are now considered resolved.
According to the Agency, all corrective actions
were completed.

1/10/23

Report No. 22-E-0052. The
EPA Was Not Transparent
About Changes Made to a
Long-Chain PFAS
Rule After Administrator
Signature, issued July 7,
2022

3. Update applicable policies, procedures,
and guidance as needed to require that—
when the EPA makes changes to a
regulatory action as a result of a suggestion
or recommendation received from the Office
of Information and Regulatory Affairs
between the time the action is submitted to
the Office of Information and Regulatory
Affairs for review and the time the action is
published in the Federal Register—the EPA
identify those changes for the public,
consistent with Executive Order 12866
section 6(a)(3)(E)(iii).

Office of
Policy

The Agency provided a response on
September 2,2022, which outlined the EPA's
planned corrective actions and estimated
completion date for the one unresolved
recommendation. After further discussion via
email, the Office of Policy provided a revised
corrective action that we accepted. All
recommendations for the subject report are now
considered resolved. According to the Agency, all
corrective actions were completed.

10/13/22

ReDort No. 22-P-0050. The
EPA Was Not Compliant with
the Payment Integrity
Information Act for Fiscal
Year 2021, issued June 27,

1. Review the OIG-identified questioned
costs for the grants payment stream,
determine the payment allowability, recover
costs as appropriate, and recalculate the
error rate.

Office of
the Chief
Financial
Officer

The Agency provided a response on
September 9,2022, which outlined the EPA's
planned corrective actions and estimated
completion dates for the three unresolved
recommendations. Based on the information and

12/21/22

2022

a. An assessment of all programs and
activities with outlays greater than $10
million.

b. An identification of which programs and
activities with annual outlays exceeding the
statutory threshold are included in each risk
assessment.

c. A mechanism for identifying, accounting
for, estimating, and reporting improper and
unknown payments and for detailing efforts
taken to prevent and reduce such payments.

supporting documentation provided all
recommendations for the subject report are now
considered resolved. According to the Agency,
corrective actions were completed for all
recommendations except Recommendation 2.

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Report

Recommendation

Action
official

Management decision

Decision date



4. Periodically train Agency personnel on
and provide completed course training
certificates for:

a.	The Standard Operating Procedure
Grants Improper Payment Review, dated
September 2021, which includes the
Payment Integrity Information Act Review
Checklist. Such training should include any
updates to these documents and emphasize
the application of the cost-allowance
principles and adherence to the terms and
conditions of federal awards.

b.	All standard operating procedures, as well
as any updates to them, implemented for
other payment streams.







36

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Appendix 3—Reports with Corrective Action Not Completed

Section 5(a)(2) of the Inspector General Act, 5 U.S.C. § 405, requires information regarding "an identification of each
recommendation made before the reporting period, for which corrective action has not been completed, including the
potential costs savings associated with the recommendation." We define potential cost savings to be the sum of
questioned costs plus funds to put to better use.

This appendix contains separate tables of unimplemented recommendations for the EPA and the CSB, which were
issued in 46 OIG audit reports from 2008 through September 30, 2022.

There are 98 unimplemented recommendations for the EPA with potential cost savings of approximately
$74.6 million. There is one unimplemented recommendation for the CSB, with no potential cost savings.

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)

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 3
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 the OMS.

37

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

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 March 31, 2023.

Report title, number, and date

Office

Unimplemented recommendation

The EPA's initial

planned
completion date

(at time of report
issuance)

The EPA's
revised
planned
completion
dates*

Potential

cost
savings**

(in thousands)

Category 1—Administrative and Business Operations

The EPA Was Not Compliant with
the Payment Integrity Information
Act for Fiscal Year 2021
22-P-0050, June 27, 2022

OCFO

2. Conduct an off-cycle risk assessment, applying the Standard Operating
Procedure Grants Improper Payment Review, dated September 2021, and
include the risk assessments in the Agency's Fiscal Year 2023 Agency
Financial Report, ensuring that the risk assessments contain: a. An
assessment of all programs and activities with outlays greater than $10
million, b. An identification of which programs and activities with annual
outlays exceeding the statutory threshold are included in each risk
assessment, c. A mechanism for identifying, accounting for, estimating,
and reporting improper and unknown payments and for detailing efforts
taken to prevent and reduce such payments.

11/15/23

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

OLEM

1. 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.

9/30/27

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

12/31/23

22-P-0033, March 31, 2022

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

9/30/27

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

9/30/24

$46,578

EPA Needs to Complete
Implementation of Religious
Compensatory Time Training for
Supervisors and Employees
22-P-0019, March 7, 2022

OMS

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.

6/30/23

$54

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

22-P-0018. February 22.2022

OMS

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.

12/31/23

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

22-P-0010. December 8.2021

OCSPP

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.

10/31/23

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

22-F-0007, November 15, 2021

OECA

5. 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.

11/30/22
4/28/23

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

** Blank cells indicate that no potential cost savings were identified. Potential cost savings are defined as questioned costs plus funds put to better use.
*** The EPA closed out the recommendation, but the OIG determined that the corrective action was not completed.

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Report title, number, and date

Office

Unimplemented recommendation

The EPA's initial

planned
completion date

(at time of report
issuance)

The EPA's
revised
planned
completion
dates*

Potential

cost
savings**

(in thousands)

EPA's Fiscal Year 2020 Fourth-
Quarter Compliance with the
Digital Accountability and
Transparency Act of 2014
22-P-0001, November 8,2021

OMS

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.

9/30/23

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

11/15/22
7/31/23

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
10/1/22
6/30/25

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
10/1/22
6/30/25

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
6/3/27

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
9/3/26

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
8/31/26

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

8/31/21

12/15/21
12/30/22
8/31/26

$118

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
12/31/26

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
2/28/27

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
12/1/24

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

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Report title, number, and date

Office

Unimplemented recommendation

The EPA's initial

planned
completion date

(at time of report
issuance)

The EPA's
revised
planned
completion
dates*

Potential

cost
savings**

(in thousands)

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
6/30/23
1/31/24

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

17-P-0368. Auaust 23. 2017

OLEM

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***

12/31/23

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***

6/23/23

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

24 unimplemented recommendations

$46,761

Category 2—Human Health and Environmental Issues

The EPA Needs to Improve the
Transparency of Its Cancer-
Assessment Process for
Pesticides

OCSPP

1. Issue guidance on when and how to conduct the kinetically derived
maximum dose approach in cancer-risk assessments for pesticides.

6/30/24

2. Issue guidance on using and applying a weight-of-evidence approach in
cancer-risk assessments for pesticides.

6/30/23

zz-t-UUoo, JUIV ^U, /[)//

3. Update the docket for 1,3-Dichloropropene to include all required
materials, including minutes and a list of participants, for meetings between
the EPA and the registrant related to the 1,3-Dichloropropene pesticide-
registration review and cancer assessment.

12/15/23

4. Issue guidance to clarify when to docket meetings related to a registration
for other related activities that occur concurrent to the pesticide-registration-
review process, such as the cancer-reassessment process.

12/15/23

6. Update the Cancer Assessment Review Committee standard operating
procedures to comply with the Office of Pesticide Programs' literature search
standard operating procedures and the broader quality principles in the Office
of Management and Budget's 2002 Information Quality Guidelines, which
includes a methodology to reconcile inconsistencies in the scientific data.

6/30/23

7. Issue procedures to document: a. The independence of Cancer
Assessment Review Committee members from the work products they
review, b. That appropriate expertise is represented on the Cancer
Assessment Review Committee for each meeting, c. When other ad hoc
voting members, such as scientists from other EPA offices, should be
added to the Cancer Assessment Review Committee, d. Regular
assessments of the Cancer Assessment Review Committee to monitor and
correct deficiencies and to determine whether applicable internal peer
review standards are being met.

6/30/23

9. Issue specific criteria requiring external peer review of Office of
Pesticide Programs' risk assessments that use scientifically or technically
novel approaches or that are likely to have precedent-setting influence on
future risk assessments, in accordance with the Office of Management and
Budget's Final Information Quality Bulletin for Peer Review.

6/30/24

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

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Report title, number, and date

Office

Unimplemented recommendation

The EPA's initial

planned
completion date

(at time of report
issuance)

The EPA's
revised
planned
completion
dates*

Potential

cost
savings**

(in thousands)

Additional Internal Controls Would
Improve the EPA's System for
Electronic Disclosure of
Environmental Violations
22-E-0051, June 30,2022

OECA

1. Develop national guidance that includes a process for screening
eDisclosure submissions for significant concerns, such as criminal conduct
and potential imminent hazards.

9/30/23

3. Develop performance measures for the eDisclosure system and a
monitoring plan to track its effectiveness.

9/30/23

4. In coordination with EPA regions, assess eDisclosure system
functionality to identify and implement improvements.

9/30/23

The EPA Continues to Fail to Meet
Inspection Requirements for
Hazardous Waste Treatment,
Storage, and Disposal Facilities
22-E-0047, June 8, 2022

OECA

1. Implement management controls to complete the required treatment,
storage, and disposal facility inspections.

3/31/24

The EPA Needs to Fully Address
the OIG's 2018 Flint Water Crisis
Report Recommendations by
Improving Controls, Training, and
Risk Assessments
22-P-0046. Mav 17. 2022

OECA

1. Document and monitor attendance at Safe Drinking Water Act training
events to ensure the appropriate staff members, managers, and senior
leaders attend the training and are aware of the EPA's oversight and
enforcement tools and authorities, including sections 1414 and 1431 of the
Safe Drinking Water Act.

12/31/22

4/28/23

2. Incorporate controls into the Report a Violation system to assess the
risks associated with tips retained by the EPA and to track when and how
the retained tips are resolved.

4/30/23

The EPA Needs to Develop a
Strategy to Complete Overdue
Residual Risk and Technology
Reviews and to Meet the Statutory
Deadlines for Upcoming Reviews
22-E-0026, March 30, 2022

OAR

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.

3/31/24

EPA's Title V Program Needs to
Address Ongoing Fee Issues and
Improve Oversight
22-E-0017, January 12,2022

OAR

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

6/30/23

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

12/31/23

3. 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.

3/31/23

5/31/23

4. 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.

3/31/23

5/31/23

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

6/30/23

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

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

12/31/22

12/31/25

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

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Report title, number, and date

Office

Unimplemented recommendation

The EPA's initial

planned
completion date

(at time of report
issuance)

The EPA's
revised
planned
completion
dates*

Potential

cost
savings**

(in thousands)

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

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 program.

9/30/23

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

21-E-0186. Julv 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 wildlife recommendations.

12/31/23

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

9/30/22

12/31/22
6/30/23

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

6/30/23

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

10/31/24

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 for
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

12/31/23

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

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Report title, number, and date

Office

Unimplemented recommendation

The EPA's initial

planned
completion date

(at time of report
issuance)

The EPA's
revised
planned
completion
dates*

Potential

cost
savings**

(in thousands)

requirements for synthetic-minor-source permit issuance and take
appropriate steps to assure the identified states adhere to the public
participation requirements.

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

OCSPP

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 f

t OCSPP completed this corrective action on February 16, 2022. That was the date OCSPP held its first annual training
series on the office's commitment to the Scientific Integrity Policy and principles and to promote a culture of scientific
integrity. March 31, 2026, is OCSPP's planned final training date. OCSPP has completed annual trainings for 2022 and
2023 on time and plans to host annual trainings until 2026 to implement this recommendation.

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

21-P-0131.Mav 12.2021

OECA

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

6/28/24

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
2/28/23
9/1/23

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, Mav 6, 2021

OAR

2. Conduct new residual risk reviews for Group I polymers and resins that
cover neoprene production, synthetic organic chemical manufacturing
industry, polyether polyols production, commercial sterilizers, and hospital
sterilizers using the new risk values for chloroprene and ethylene oxide
and revise the corresponding National Emission Standards for Hazardous
Air Pollutants, as needed.

9/30/24

3. Revise National Emission Standards for Hazardous Air Pollutants for
chemical manufacturing area sources to regulate ethylene oxide and
conduct a residual risk review to ensure that the public is not exposed to
unacceptable risks.

9/30/28

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

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
1/31/25

t This date was 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

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

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Report title, number, and date

Office

Unimplemented recommendation

The EPA's initial

planned
completion date

(at time of report
issuance)

The EPA's
revised
planned
completion
dates*

Potential

cost
savings**

(in thousands)

Region 3 corresponded several times about Recommendation 2, including a briefing held by Region 3 on October 25, 2021. In a memorandum
dated December 13, 2021, the OIG accepted Region 3's proposed corrective actions to address Recommendation 2 but did not receive a
revised planned completion date. After the OIG accepted the proposed corrective actions for Recommendation 2, Region 3 provided a
revised planned completion date, which is 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 procedure, and the memorandum of agreement
between EPA Region 5 and the Minnesota Pollution Control Agency.

11/30/23

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

OECA

2. In collaboration with the Office of Land and Emergency Management,
establish mechanisms to ensure that all inspections are completed within
the required time frame of two years for operating treatment, storage, or
disposal facilities or the policy time frame of three years for nonoperating
treatment, storage, or disposal facilities.

3/29/24

OLEM

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

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

12/31/22

6/30/23

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
9/30/23

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
9/30/23

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

Further Efforts Needed to Uphold
Scientific Integrity Policy at EPA
20-P-0173, Mav20. 2020

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

9/30/20

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

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

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

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Report title, number, and date

Office

Unimplemented recommendation

The EPA's initial

planned
completion date

(at time of report
issuance)

The EPA's
revised
planned
completion
dates*

Potential

cost
savings**

(in thousands)





violation of the Scientific Integrity Policy, and incorporate the procedures
into scientific integrity outreach and training materials.



6/30/24



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
6/30/24



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

20-P-0146. Aoril 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
9/30/23



2. Establish and implement an oversight process to verity 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
9/30/23





Management Alert: Prompt Action
Needed to Inform Residents Living
Near Ethylene Oxide-Emitting
Facilities About Health Concerns
and Actions to Address Those
Concerns

20-N-0128. March 31. 2020

ADA

1. Improve and continue to implement ongoing risk communication efforts
by promptly providing residents in all communities near the 25 ethylene
oxide-emitting facilities identified as high-priority by the EPA with a forum
for an interactive exchange of information with the EPA or the states
regarding health concerns related to exposure to ethylene oxide.

U

5/31/21 f



t According to information provided by EPA in March 2023, the Agency plans to complete their outreach efforts in the next few months. We will
assess the status of this recommendation once the corrective actions are completed.

EPA Must Improve Oversight of
Notice to the Public on Drinking
Water Risks to Better Protect
Human Health

19-P-0318. September 25.2019

OW

5. Update and revise the 2010 Revised State Implementation Guidance for
the Public Notification Rule to include:

a.	Public notice delivery methods that are consistent with regulations.

b.	Information on modern methods for delivery of public notice.

6/30/20

9/30/22
3/31/23
4/30/23



6. Update and revise the 2010 Public Notification Handbooks to include:

a.	Public notice delivery methods that are consistent with regulations.

b.	Information on modern methods for delivery of public notice.

c.	Public notice requirements for the latest drinking water regulations.

d.	Procedures for public water systems to achieve compliance after
violating a public notice regulation.

e.	Up-to-date references to compliance assistance tools.

f.	Additional resources for providing public notice in languages other than
English.

9/30/20

9/30/22
3/31/23
4/30/23





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 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

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
12/31/23



Management Weaknesses
Delayed Response to Flint Water
Crisis

18-P-0221, July 19, 2018

OECAf

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***

12/30/22
4/28/23





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***

4/28/23



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

** Blank cells indicate that no potential cost savings were identified. Potential cost savings are defined as questioned costs plus funds put to better use.
*** The EPA closed out the recommendation, but the OIG determined that the corrective action was not completed.

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

45

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Report title, number, and date

Office

Unimplemented recommendation

The EPA's initial

planned
completion date

(at time of report
issuance)

The EPA's
revised
planned
completion
dates*

Potential

cost
savings**

(in thousands)

f OECA and the OW were the responsible offices for Recommendations 6 and 8. The OIG conducted a follow-up audit (Report No. 22-P-
0046) and found that the OW had completed its corrective actions but that OECA had not. Therefore, the OWhas been removed as a
responsible office for these recommendations.

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
12/31/23

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
6/30/23
9/30/23

EPA Has Not Met Certain
Statutory Requirements to Identify
Environmental Impacts of
Renewable Fuel Standard
16-P-0275, Auaust 18,2016

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***

3/29/24

EPA's Endocrine Disruptor
Screening Program Should
Establish Management Controls to
Ensure More Timely Results
11-P-0215. Mav3. 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***

10/1/24

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***

12/31/22
6/30/23

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***

6/30/23

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
9/30/23

Making Better Use of Stringfellow
Superfund Special Accounts
08-P-0196. Julv 9. 2008

Region 9

2. Reclassify or transfer to the Trust Fund, as appropriate, $27.8 million
(plus any earned interest less oversight costs) of the Stringfellow special
accounts in annual reviews, and at other milestones including the end of
fiscal year 2010, when the record of decision is signed and the final
settlement is achieved.

12/31/12

9/30/23
9/30/26

$27,800

Subtotal

74 unimplemented recommendations

$27,800

Total

98 unimplemented recommendations

$74,561

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

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

-------
Semiannual Report to Congress	October 1, 2022-March 31, 2023

CSB Report with Unimplemented Recommendation

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, 2023.

Report title, number, and date

Office

Unimplemented recommendation

The CSB's initial

planned
completion date

at time of report
issuance

The CSB's
revised
planned
completion
date(s)*

Potential cost
savings

(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
12/31/22
6/30/23





Total



1 unimplemented recommendation





$0

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

47

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Appendix 4—Closed Investigations Involving Senior Employees

For Reporting Period Ending March 31, 2023

Section 5(a)(13) of the Inspector General Act, 5 U.S.C. § 405, requires a report on each investigation involving a senior
government employee in which allegations of misconduct were substantiated. Section 5(a)(16) of the Act, 5 U.S.C. § 405,
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, 2023, are provided below.

CASE NUMBER: OI-HQ-2021-QTH-0041

An EPA GS-15 employee violated Virginia law when the employee engaged in actions inside a dwelling in an attempt to
videotape a nonconsenting individual. The employee signed a plea agreement with the Commonwealth of Virginia, in which
the employee pleaded guilty to one count of unlawful filming of another and one count of peeping or spying into a dwelling by
electronic device. The employee served one month in jail with 11 months suspended, paid $4,000 in restitution fees, and
must attend psychosexual counseling. Additionally, the EPA suspended the employee without pay for 30 calendar days.

CASE NUMBER: QI-PH-2022-ADM-0112

An EPA GS-15 employee allegedly violated several OIG procedures relative to the employee's handling of a conduct issue
involving an EPA GS-14 employee. The GS-15 employee was reassigned during the course of the investigation and later left
the EPA. The investigation determined that the allegations were inconclusive.

CASE NUMBER: AID-00014

Two EPA OIG Senior Executive Service managers and two OIG GS-15 managers allegedly failed to report allegations of
harassment and bullying made by an OIG employee against the employee's supervisor, in violation of EPA Order 4711,
Procedure for Addressing Allegations of Workplace Harassment. Pursuant to the order's procedural requirements, the fact-
finding did not render a judgment on whether the allegations were substantiated. The OIG subsequently required all
supervisory personnel to be trained on addressing allegations made under EPA Order 4711.

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Appendix 5—Peer Reviews Conducted

For Reporting Period Ending March 31, 2023

Section 5(a)(8) of the Inspector General Act, 5 U.S.C. § 405, 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)(9) of the Act, 5 U.S.C. §
405, 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)(10) of the Act, 5 U.S.C. § 405, 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 completed an external peer review of the audit organization of the U.S. Department of Agriculture OIG and
issued its report on December 28, 2022. The review was conducted in accordance with generally accepted government
auditing standards and guidelines established by the Council of the Inspectors General on Integrity and Efficiency's Guide for
Conducting Peer Reviews of the Audit Organizations of Federal Offices of Inspector General. We examined the audit
function for the fiscal year ended March 31, 2021. We found that the Department of Agriculture OIG had quality control
policies and procedures that were intended to provide reasonable assurance of compliance with generally accepted
government auditing standards. However, we believe that the Department of Agriculture OIG should take additional steps to
strengthen its system of quality control to ensure that all applicable standards are met and adequately documented. The
Department of Agriculture OIG received an external peer review rating of pass with deficiencies.

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

Audit

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.

-------
Semiannual Report to Congress

October 1, 2022-March 31, 2023

Appendix 6—OIG Mailing Addresses and Telephone Numbers

Headquarters

U.S. Environmental Protection Agency
Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, D.C. 20460
(202) 566-0847

Offices

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) 620-4719
Investigations: (857) 207-1128

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: (206) 514-0094
Evaluation: (206) 561-3729
Investigations: (206) 553-2543

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: (312) 886-3106
Evaluation: (312) 353-4353
Investigations: (646) 678-0969

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) 312-6463

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: (224) 935-6847

Region 3

U.S. Environmental Protection Agency
Office of Inspector General
Four Penn Center

1600 John F. Kennedy Boulevard, 4th Floor
Philadelphia, PA 19103-2029
Audit: (215) 814-2326
Evaluation: (215) 814-2349
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

109 T.W. Alexander Drive

P.O. Box 12055

Research Triangle Park, NC 27711
Audit: (919) 541-1030
Evaluation: (919) 541-3601
Investigations: (919) 541-3668

50

-------