Compendium of Open
and Unresolved
Recommendations:
Data as of May 31, 2023

July 27, 2023 | Report No. 23-N-0025


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Report Contributors: Kelly Chavarria

Chad Garland
Eric Lewis
Claire McWilliams
Adam Seefeldt
KellyJune Stout

Abbreviations:

C.F.R.

Code of Federal Regulations

CWA

Clean Water Act

EDSP

Endocrine Disruptor Screening Program

EPA

U.S. Environmental Protection Agency

FIFRA

Federal Insecticide, Fungicide, and Rodenticide Act

MDEQ

Michigan Department of Environmental Quality

NEIC

National Enforcement Investigations Center

NPDES

National Pollutant Discharge Elimination System

OIG

Office of Inspector General

PRIA

Pesticide Registration Improvement Act

RCRA

Resource Conservation and Recovery Act

RFS

Renewable Fuel Standard

RTR

Residual Risk and Technology Review

TSDF

Treatment, Storage and Disposal Facility

U.S.C.

United States Code

WPS

Worker Protection Standard

Cover Images:

A truck passing the Longview Power Plant near Morgantown,
West Virginia. (EPA image)

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OIG Hotline@epa.gov

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Washington, D.C. 20460
(202) 566-2391
www.epa.gov/oiq

Subscribe to our Email Updates.
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Send us your Project Suggestions.


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At a Gla

23-N-0025
July 27, 2023

Compendium of Open and Unresolved Recommendations:
Data as of May 31, 2023

Why We Published This
Compendium

The Inspector General Act of 1978, as
amended, requires each inspector
general to prepare semiannual reports
for Congress. As part of that reporting,
the inspector general must identify all
recommendations from the prior
reporting period for which corrective
actions have not been completed by the
agency, as well as any management
decisions with respect to audit,
inspection, or evaluation reports issued
during that prior reporting period.

The U.S. Environmental Protection
Agency Office of Inspector General is
publishing this Compendium to analyze
the open recommendations listed in the
semiannual report covering our work
from October 1, 2022, through March 31,
2023, and the recommendations that
remained unresolved through May 31,
2023. We produce the Compendium
annually.

Open recommendations, also called
resolved recommendations, are those on
which the EPA and the OIG agree, but
the agreed-upon corrective actions have
not yet been completed, regardless of
whether their expected due dates are in
the past or the future.

Unresolved recommendations are

those that the EPA disagrees with; has
not provided a formal, complete, written
response to; or has proposed corrective
actions for that the Agency and the OIG
have not agreed upon.

What We Found

This Compendium focuses on 91 recommendations
identified as open in Report No. EPA-350-R-23-001.
Semiannual Report to Congress: October 1, 2022-
March 31, 2023, issued May 2023, and
22 recommendations that remained unresolved through
May 31, 2023. Our analysis recognizes changes in the
statuses of recommendations that occurred after the
issuance of the semiannual report but not later than
May 31, including the implementation of corrective
actions for seven of the 98 open recommendations in that

Implementing corrective
actions on the open and
unresolved
recommendations
contained in this
Compendium could
have potential monetary
benefits of $74.6 million.

report.

The 113 recommendations we address in this Compendium represent $74.6 million in
potential monetary benefits. In this Compendium, we also discuss the following:

•	A breakdown of the 22 unresolved recommendations.

•	The relationship of the open and unresolved recommendations to the EPA's
fiscal year 2023 top management challenges, which we identify in the our
EPA's Fiscal Year 2023 Top Management Challenges report, issued
October 28, 2022.

•	Fifteen open or unresolved recommendations that the OIG deemed high
priority.

•	A breakdown of the 91 open recommendations by program office and region.
Seven of these open recommendations previously were reported by the
Agency as closed, but upon further review, we disagreed with the Agency's
assessment and reopened them.

•	Sixty-seven open recommendations that are designed to improve human
health and the environment, and 24 open recommendations that are designed
to improve administrative and business operations.

•	Fifty-two open recommendations that are at least three years old or that have
corrective actions scheduled to be completed more than three years after the
associated report's issuance.

Address inquiries to our public affairs
office at (202) 566-2391 or
OIG.PublicAffairs@epa.gov.

List of OIG reports.


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U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

July 27, 2023

MEMORANDUM

SUBJECT: Compendium of Open and Unresolved Recommendations: Data as of May 31, 2023
Report No. 23-N-0025

The U. S. Environmental Protection Agency Office of Inspector General presents the Compendium of Open
and Unresolved Recommendations: Data as of May 31, 2023, which details 91 open recommendations
issued in reports published as of September 30, 2022, and 22 recommendations that remained unresolved
through May 31, 2023.

The Inspector General Act of 1978, as amended, requires each inspector general to prepare semiannual
reports for Congress, which must include "an identification of each significant recommendation described
in previous semi-annual reports on which corrective action has not been completed." This Compendium
provides further analysis of open recommendations identified in Report No. EPA-350-R-23-001.

Semiannual Report to Congress: October 1, 2022-March 31, 2023, issued May 2023.

Section 1 outlines how open and unresolved recommendations relate to the Agency's key management
challenges, which we detail in The EPA's Fiscal Year 2023 Toy Management Challenges, issued
October 28, 2022. Section 2 identifies the high-priority open or unresolved recommendations. Section 3
focuses on unresolved recommendations. Section 4 details open recommendations by program and
regional office, as well as the (1) human health and environmental benefits and (2) administrative and
business operation benefits of the open recommendations, including those recommendations that the
Agency previously closed but the OIG reopened. Section 5 lists the open recommendations that are at
least three years old, as well as the open recommendations with proposed corrective actions not scheduled
to be completed within three years of the associated report's issuance.

We will post this report to our website at www.epa.gov/oig.

cc: Assistant Administrators
General Counsel
Chief Financial Officer
Associate Administrators
Regional Administrators
Agency Follow-Up Coordinators

FROM: Sean W. O'Donnell, Inspector General

TO:

Michael S. Regan, Administrator

Janet McCabe, Deputy Administrator


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Table ofCon

Introduction	1

1	Implementing Open and Unresolved Recommendations

Would Help Mitigate the EPA's Top Management Challenges	3

2	Overview of High-Priority Open and Unresolved Recommendations	5

3	Overview of Unresolved Recommendations	6

4	Overview of Open Recommendations	7

5	Corrective Actions Taking Three Years or More to Implement	8

A Open and Unresolved Recommendations Listed by Fiscal Year 2023

Top EPA Management Challenge and Benefit Type	9

B Fifteen High-Priority Open or Unresolved Recommendations	19

C Twenty-Two Unresolved Recommendations	26

D Open Recommendations by Program Office and Region	32

E Fifty-Two Corrective Actions Scheduled to Take Three Years

or More to Implement	36

23-N-0025	5


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INTRODUCTION

Purpose

The purpose of this Compendium is to keep Agency management and
Congress informed about the U.S. Environmental Protection Agency's
outstanding commitments to act on Office of Inspector General
recommendations, as well as about the Agency's progress in
completing corrective actions that will help improve its programs and
operations. This Compendium provides a summary and analysis of the
EPA's open and unresolved recommendations.

As of May 31, 2023, the EPA had not implemented corrective actions
for 91 open OIG recommendations issued as of September 30, 2022,
while 22 more recommendations remained unresolved.1 The full text
of the open recommendations and any associated monetary benefits
can be viewed in Appendix 3 of Report No. EPA-35Q-R-23-Q01.
Semiannual Report to Congress: October 1, 2022-March 31, 2023,
issued May 2023. While that appendix lists a total of 98 open
recommendations, the EPA closed seven of them between April 1 and
May 31, 2023. We have omitted these seven from this Compendium.

Open recommendations, or

resolved recommendations, are
those that the EPA and the OIG
agree on but for which the
agreed-to corrective actions have
not been completed. This includes
those with corrective actions past
due or due in the future. An open
recommendation can have one or
more corrective actions that the
Agency has agreed to complete.

Unresolved recommendations are
those that the EPA disagrees with;
has not provided a formal,
complete, written response to; or
has proposed corrective actions for
which it and the OIG have not
agreed upon.

Implementing corrective actions to ensure that the Agency adopts robust internal controls to protect
government assets has become particularly important given the EPA's supplemental appropriations
under the Infrastructure Investment and Jobs Act and the Inflation Reduction Act. These two Acts, when
combined, provide the EPA with more than $100 billion in additional funding over a period of five years.
As with previous supplemental spending legislation, there is a risk that the influx of funds may be
mismanaged, that funding requirements will not be complied with, or that programmatic goals will not
be met. If the Agency does not timely address its outstanding recommendations, its IDA- and IRA-funded
programs could be more susceptible to fraud, waste, abuse, or mismanagement.

1 The OIG also provides oversight to the U.S. Chemical Safety and Hazard Investigation Board, which had only one
open recommendation as of March 31, 2023, that can be viewed in Appendix 3 of Report No. EPA-350-R-23 001,
Semiannual Report to Congress: October 1, 2022-March 31, 2023 (May 2023).

23-N-0025

1


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Background

The OIG provides independent oversight of the EPA and the U.S. Chemical Safety and Hazard Investigation
Board in accordance with the Inspector General Act of 1978, as amended, 5 U.S.C. §§ 401-424. Our
mission is to detect and prevent fraud, waste, and abuse, and to promote economy, efficiency, and
effectiveness, in the EPA's programs and operations. To that end, we conduct audits, evaluations, and
investigations that result in written reports with evidence-based recommendations for improving EPA
programs and operations and for addressing wrongdoing and mismanagement.

For each report, we work with the EPA and the CSB to reach agreement on corrective actions
responding to our recommendations. Timely resolution and completion of corrective actions are critical
for reducing costs, managing risks, improving processes, and realizing other monetary benefits of
improved efficiency and effectiveness. This also ensures integrity and accountability in the use of public
funds.

We track the status of recommendations to ensure that management takes the corrective actions that
were agreed-upon during the reporting process. We encourage the responsible offices to complete
corrective actions in one year or less, but the Agency may determine that a corrective action will take
longer. We highly discourage corrective actions taking what we view as an unreasonable amount of time
to implement, and we will address and report such instances, as appropriate.

The IG Act requires each inspector general to prepare semiannual reports to Congress that identify all
recommendations from prior reporting periods for which an agency has not completed corrective
actions and any management decisions with respect to audit, inspection, or evaluation reports issued
during a prior reporting period. The IG Act also requires that, for audit, inspection, and evaluation
reports issued during the reporting period, the semiannual report identify the dollar value of
recommendations where funds could be put to better use. This Compendium supplements the OIG's
semiannual report to provide additional information regarding open and unresolved recommendations.

Methodology

For this Compendium, we compiled recommendations that were reported as open in Appendix 3 of
Report No. EPA-350-R-23-001. Semiannual Report to Congress: October 1, 2022-March 31, 2023, issued
May 2023. We originally issued those recommendations to the EPA in audit reports from 2008 through
September 30, 2022. As of May 31, 2023, 91 of those recommendations remained open. Additionally,
we compiled 22 recommendations that remained unresolved as of May 31, 2023, and 15 high-priority
open or unresolved recommendations that had been issued as of that date. Figure 1 illustrates the
time-based criteria for the data used in this Compendium.

Figure 1: Time-based criteria for open and unresolved recommendations in this Compendium

September 30, 2022

Appendix 3 of the OIG semiannual
report to Congress published in
May 2023 covers open
recommendations through this date.

May 31, 2023

This Compendium reflects the

statuses of open and
unresolved recommendations
as of this date.

March 31, 2023

Cutoff date for status updates to
open recommendations listed in
the May 2023 semiannual report.

Source: Methodology used by the OIG in compiling this compendium. (EPA OIG image)
23-N-0025


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SECTION 1: implementing Open and Unresolved Recommendations
Would Help Mitigate the EPA's Top Management Challenges

Implementing corrective actions for many of the EPA's open and unresolved recommendations would
help the EPA mitigate what the OIG has identified as the Agency's eight most significant management
challenges. We detail these management challenges in our EPA's Fiscal Year 2023 Top Management
Challenges report issued October 28, 2022.

Identifying these key challenges each year is an essential component of the OIG's mission. These
challenges are the most likely areas in which the EPA will face difficulties fulfilling its mission of
protecting human health and the environment. We plan our oversight work to help the Agency mitigate
these specific challenges. We have aligned the open and unresolved recommendations in this
Compendium to challenges identified for fiscal year 2023, regardless of whether we previously aligned
them to an earlier fiscal year's top management challenge or to none at the time they were originally
issued or resolved.

U.S. ENVIRONMENTAL
PROTECTION AGENCY

FISCAL YEAR 2023



n



IBI

¦¦H



¦

U.S. Environmental Protection Agency



Fiscal Year 2022

Top Management Challenges



¦Aft. i



.¦!=;! o»;S ,§|[

i$o

Itsij







OFFICE OF INSPECTOR GENERAL

FYs 2020-2021

U.S. Environmental
Protection Agency

Top Management Challenges

n *•> rsssi

A #



Source: Report covers of our top management challenge reports for fiscal years 2023, 2022, and 2020-2021. (EPA
OIG images)

As detailed in Figure 2, implementing corrective actions for the 91 recommendations that were reported
in our last semiannual report to Congress and that remained open as of May 31, 2023, would help the
EPA mitigate seven of the its eight top management challenges for fiscal year 2023. If addressed, the
22 unresolved recommendations detailed in this Compendium would alleviate five of the eight top
management challenges. We have not yet made recommendations concerning the eighth challenge,
management of increased investment in infrastructure, but we have issued four lessons-learned reports
of prior findings to aid the EPA in implementing IIJA-funded programs.

Appendix A details the OIG reports with open and unresolved recommendations, including the relevant
management challenge, responsible EPA office, number of recommendations, and type of benefit to the
Agency from implementing corrective actions.

23-N-0025

3


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Figure 2: The EPA's top management challenges and related open and unresolved recommendations

91 Open Recommendations # 22 Unresolved Recommendations

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' © ^

~l

.0

Mitigating the causes
and adapting to the
impacts of climate
change

The Agency will need
to effectively allocate
resources for
coordination with
local, state, federal,
and international
partners in developing
comprehensive
strategies to mitigate
the effects of climate
change.

Ensuring Agency
systems and other
critical infrastructure
are protected against
cyberthreats

Information
technology is an
essential resource.
Without a robust and
mature cybersecurity
posture, acts from
malicious cyber actors
could hinder the EPA's
ability to perform its
mission.

Integrating and leading
environmental justice
across the Agency and
government

As environmental
justice continues to be
woven into EPA
decisions, Agency
decision-makers must
have the proper tools
and training to assess
and mitigate the
disparate effects of
their decisions.

|L_

_J\

_A

Managing business
operations and
resources

The EPA must create
and maintain effective
business operations
for distributing billions
of dollars in grants and
contracts while
safeguarding taxpayer
dollars.

Providing for the safe
use of chemicals

To effectively protect
public health and the
environment, the EPA
must be able to
conduct credible and
timely assessments of
the risks from
pesticides, toxic
chemicals, and other
environmental
chemical risks.

_jl

Enforcing compliance
with environmental
laws and regulations

The Agency faces
challenges in assessing
its resource
requirements for
enforcement
programs and
identifying innovative
and cost-effective
means of detecting
and deterring
noncompliance.

		J

Safeguarding scientific
integrity principles

The Agency must
ground science-based
decisions in principles
of scientific integrity
to ensure the best
available science.
These scientific
integrity concepts
must be deployed
throughout the EPA's
culture.

•I
•I

~l

3

cm

Managing increased
investment in
infrastructure*

The recent
Infrastructure
Investment and Jobs
Act appropriation
represents a
significant increase in
the EPA's funding, and
the Agency must
effectively manage
these funds to achieve
intended results.

Source: OIG analysis of open recommendations issued before September 30, 2022, and unresolved
recommendations issued as of May 31, 2023. (EPA OIG table)

*The OIG has not yet issued a report with recommendations concerning IIJA funding, but we are currently
conducting and planning audits, evaluations, and investigations of related programs.

23-N-0025

4


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SECTION 2: Overview of High-Priority Open and Unresolved
Recommendations

High-priority recommendations assist the Agency in focusing on those areas that are most critical to
achieving its mission. Implementing corrective actions for high-priority recommendations ensures that
the necessary internal controls are in place to prevent fraud, waste, abuse, and mismanagement.

We have identified 15 open or unresolved recommendations that we have deemed a high priority
because they offer significant contributions to either the EPA's mission of improving human health and
the environment or its administrative or business processes, or because they identify significant
potential funds to be put to better use.

Among these 15 recommendations are six that were not reported in Appendix 3 of our May 2023
semiannual report to Congress either because they were not resolved at that time or because we issued
them after the period the appendix covered. Of those, one is an unresolved recommendation issued in a
previous semiannual period, while five are open or unresolved recommendations issued in fiscal
year 2023. As detailed in Figure 3, these 15 high-priority recommendations pertain to nine EPA program
offices or regions.

Figure 3: High-priority recommendations by program office and region





¦ Open high-priority recommendations

¦ Unresolved high-priority recommendations



2























2



2



2



D

n

D

D

D ~

ORD OECA Region 9

OCSPP

OAR

OLEM

OCFO

OMS AO

Note: ORD = Office of Research and Development, OECA = Office of Enforcement and Compliance Assurance,
OCSPP = Office of Chemical Safety and Pollution Prevention, OAR = Office of Air and Radiation, OLEM = Office of
Land and Emergency Management, OCFO = Office of the Chief Financial Officer, OMS = Office of Mission Support,
AO = Office of the Administrator.

Source: OIG analysis of open and unresolved recommendations issued as of May 31, 2023. (EPA OIG table)

Thirteen of the 15 high-priority recommendations would benefit human health or the environment.
Implementing corrective actions for these 13 recommendations would help the EPA address five fiscal
year 2023 top management challenges:

•	Safeguard in g scien tific in tegrity prin ciples.

•	Enforcing compliance with environmental laws and regulations.

•	Providing for the safe use of chemicals.

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

•	Managing business operations and resources.

The remaining two recommendations would benefit the Agency's administrative and business
operations processes and would help the EPA address its top management challenge of managing
business operations and resources.

Appendix B identifies the high-priority recommendations, specifies the management challenge to which
they are aligned, and classifies them by the benefits to be gained from their implementation.

23-N-0025

5


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SECTION 3: Overview of Unresolved Recommendations

Twenty-two OIG recommendations to the EPA remained unresolved as of May 31, 2023. A
recommendation is unresolved when the EPA disagrees; does not provide a formal, complete, written
response; or has proposed corrective actions that the Agency and the OIG have not agreed upon. The
importance of resolving recommendations is reflected in Office of Management and Budget Circular
No. A-50's requirement that the EPA work with the OIG to resolve recommendations. It is the Agency's
responsibility to implement corrective actions associated with OIG recommendations.

Figure 4 provides an overview of the 22 unresolved OIG recommendations as of May 31, 2023,
delineated by the EPA office or region responsible for implementing the associated corrective actions.
Appendix C lists the unresolved recommendations by OIG report, including summaries of OIG and EPA
positions, the responsible office, and progress made toward resolution.

Figure 4: Unresolved recommendations by responsible office





Office of Enforcement and Compliance Assurance







Office of Water







Office of Air and Radiation







Office of Land and Emergency Management

3





Office of Research and Development

3





Office of the Administrator

1





Office of Chemical Safety and Pollution Prevention

1





Office of Mission Support

1





Source: OIG analysis of recommendations data as of May 31, 2023. (EPA OIG figure)

23-N-0025

6


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SECTION 4: Overview of Open Recommendations

A total of 91 recommendations that we issued to the EPA through September 2022 remained open as of
May 31, 2023. That means the Agency had not implemented the associated corrective actions. Of these
91 open recommendations, seven (8 percent) had previously been closed, with corrective actions
reported as completed by the Agency. However, upon review of the EPA's corrective actions, the OIG
reopened these seven recommendations. A recommendation is reopened when the Agency reports
completing the necessary corrective actions but the OIG does not agree that the actions taken meet the
intent of the recommendation.

We analyzed the benefits to the Agency from completing corrective actions in Appendix A. The benefits
fell into the following two main categories:

•	Human health and environmental benefits: 67 open recommendations.

These benefits provide for better health and environmental outcomes and include actions taken
to clean up or remediate sites, reduce exposure to contaminants, improve conditions for
vulnerable communities, improve indoor air quality, and reduce carbon dioxide emissions.

•	Administrative and business operation benefits: 24 open recommendations.

The EPA's administrative and business operations processes—which cover personnel,
contracting, grants, and information technology functions—facilitate the EPA's mission to
protect human health and the environment.

Figure 5 displays the EPA program offices and regions that are responsible for addressing the 91 open
recommendations, including the four offices responsible for the seven reopened recommendations.
Appendix D provides a breakdown of the associated reports by responsible region and program office.

Figure 5: Open and reopened recommendations by responsible office

Office of Chemical Safety and Pollution Prevention
Office of Air and Radiation
Office of Enforcement and Compliance Assurance
Office of Mission Support and OCFO
Office of Land and Emergency Management
Office of Mission Support
Office of Water
Office of General Counsel
Office of Research and Development
Region 9

Office of the Administrator
Office of the Chief Financial Officer
Region 2
Region 3
Region 5
Region 6

Note: OCFO = Office of the Chief Financial Officer.

Source: OIG analysis of open recommendations listed in Appendix 3 of Report No. EPA-350-R-23-001. Semiannual
Report to Congress: October 1, 2022-March 31, 2023 (May 2023). (EPA OIG image)

Open recommendations
Reopened recommendations

23-N-0025

7


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SECTION 5: Corrective Actions Taking Three Years or More to
Implement

Of the 91 recommendations still open as of May 31, 2023, 52 remained open after three years or were
not scheduled to be implemented within three years of the associated report's issuance. Prompt
implementation of corrective actions is necessary to ensure that the Agency realizes their benefits, both
monetary and environmental. Delayed implementation, by contrast, potentially leaves the Agency more
vulnerable to fraud, waste, and abuse and unable to meet its goals in the most effective and efficient
manner.

Office of Management and Budget Circular No. A-50 requires each executive agency to establish an
audit follow-up system. The circular states that agencies shall assign a high priority to resolving and
implementing corrective actions for audit recommendations. It also states that corrective actions should
proceed as rapidly as possible. However, it does not establish a time frame for implementation of
corrective actions. EPA Manual 2750, Audit Management Procedures, requires timely and efficient
resolutions to implement corrective actions for the greatest possible impact and potency. It states that
recommendations are considered overdue when the Agency has not completed corrective actions
agreed upon with the OIG within one year of their original estimated completion dates.

The Agency is responsible for timely implementation of agreed-to corrective actions, and the OIG
encourages responsible offices to do so within one year. However, the Agency may determine that a
corrective action will take longer than one year. We highly discourage taking what we view as an
unreasonable amount of time to implement corrective actions, and we will address and report such
circumstances as appropriate.

Figure 6 provides an overview of the 52 recommendations with planned corrective actions scheduled to
take three years or longer to implement. Appendix E provides details of the reports containing these
52 open recommendations.

Figure 6: Overview of the 52 recommendations with corrective actions taking three
years or longer to implement

Source: OIG analysis of open recommendations listed in Report No. EPA-350-R-23-001.
Semiannual Report to Congress: October 1, 2022-March 31, 2023 (May 2023). (EPA OIG image)

23-N-0025

8


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Appendix A

Open and Unresolved Recommendations Listed by
Fiscal Year 2023 EPA Top Management Challenge and Benefit Type

This appendix details the 49 reports that contain the EPA's 91 open and 22 unresolved recommendations, as of
May 31, 2023. Organized by top management challenge, the tables in this appendix identify the responsible EPA
office, the number of recommendations, the type of benefit to the Agency from implementing the corrective
actions, and the impact of the report's findings.

Table A-1: Summary of open and unresolved recommendations and associated reports by EPA top
management challenge

Top EPA management challenge

Number of
reports

Number of open and

unresolved
recommendations

Corresponding table

Mitigating the causes and adapting to the impacts of climate change

2

5 open

Table A-2

Integrating and leading environmental justice across the Agency
and government

8

11 open and 3 unresolved

Table A-3

Providing for the sale use of chemicals

5

17 open and 1 unresolved

Table A-4

Safeguarding scientific integrity principles

3

4 open and 5 unresolved

Table A-5

Ensuring Agency systems and other critical infrastructure are protected
against cyberthreats

4

3 open and 4 unresolved

Table A-6

Managing business operations and resources

20

39 open

Table A-7

Enforcing compliance with environmental laws and regulations

7

12 open and 9 unresolved

Table A-8

Managing increased investment in infrastructure

0

0

Not applicable*

"The OIG is conducting audits, evaluations, and investigations of offices and programs receiving IIJA appropriations, but had
not published related reports with any open or unresolved recommendations as of May 31, 2023. Our Infrastructure Investment
and Jobs Act Oversight Plan—Year Two report, issued April 27, 2023, details our planned and ongoing oversight work related
to the 11 JA.

Table A-2: Open and unresolved recommendations associated with the EPA top management challenge of
mitigating the causes and adapting to the impacts of climate change

Report No.

Report title

Action office

Number of open and

unresolved (U)
recommendations

Benefit type

Impact

22-E-0017

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

Office of Air
and Radiation

3

Human health and
environmental
issues

Lack of consistent oversight and persistent
Title V fee challenges may undermine Title V
program implementation.

16-P-0275

EPA Has Not Met
Certain Statutory
Requirements to Identify
Environmental Impacts
of Renewable Fuel
Standard

Office of Air
and Radiation

2

Human health and
environmental
issues

The EPA, Congress, and other stakeholders lack
key information on biofuel impacts needed to
make science-based decisions about the
Renewable Fuel Standard, or RFS.

23-N-0025

9


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Table A-3: Open and unresolved recommendations associated with the EPA top management challenge of
integrating and leading environmental justice across the Agency and government

Report No.

Report title

Action office

Number of open and

unresolved (U)
recommendations

Benefit type

Impact

22-P-0046

The EPA Needs to Fully
Address the OIG's 2018
Flint Water Crisis Report
Recommendations by
Improving Controls,
Training, and Risk
Assessments

Office of
Enforcement

and
Compliance
Assurance

1

Human health and
environmental
issues

Without complete oversight of the drinking water
program, the public's health is still at risk from
lead in drinking water.

22-E-0026

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

Office of Air
and Radiation

1

Human health and
environmental
issues

As of November 1,2021, the EPA had
93 overdue residual risk and technology reviews,
or RTRs, or technology reviews, almost half of
which were overdue by more than five years.
These reviews are used to establish limits for air
toxics emissions and to protect public health.

21-P-0129

EPA Should Conduct
New Residual Risk and
Technology Reviews for
Chloroprene- and
Ethylene Oxide-Emitting
Source Categories to
Protect Human Health

Office of Air
and Radiation

3

Human health and
environmental
issues

The EPA should conduct new RTRs for
chloroprene- and ethylene oxide-emitting source
categories to address elevated individual lifetime
cancer risks impacting over 464,000 people, as
found in a modeling tool, and to achieve
environmental justice.

20-E-0333

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

Office of
General
Counsel

3

Human health and
environmental
issues

Despite elimination of the case backlog,
additional improvements in the EPA's oversight of
Title VI funding recipients could prevent
discrimination.

20-N-0128

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

Office of the
Administrator

1

Human health and
environmental
issues

The EPA needs to inform residents who live near
facilities with significant ethylene oxide emissions
about their elevated estimated cancer risks so
they can manage their health risks.

20-P-0062

EPA Needs to Improve
Its Emergency Planning
to Better Address Air
Quality Concerns During
Future Disasters

Office of Land

and
Emergency
Management

3 (U)

Human health and
environmental
issues

Developing EPA guidance for collecting and
communicating air quality data could improve
public confidence in the Agency during future
disaster responses.

18-P-0240

EPA Needs a
Comprehensive Vision
and Strategy for Citizen
Science that Aligns with
Its Strategic Objectives
on Public Participation

Office of the
Administrator

1

Human health and
environmental
issues

Without uniform guidance and direction, the EPA
will be unable to fully use citizen science data
that could contribute to the Agency's mission.

18-P-0221

Management
Weaknesses Delayed
Response to Flint Water
Crisis

Office of
Enforcement

and
Compliance
Assurance

1

The EPA previously

closed this
recommendation, but
the OIG reopened it.

Human health and
environmental
issues

The EPA should strengthen its oversight of state
drinking water programs to improve the efficiency
and effectiveness of the Agency's response to
drinking water contamination emergencies.

23-N-0025

10


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Table A-4: Open and unresolved recommendations associated with the EPA top management challenge of
providing for the safe use of chemicals

Report No.

Report title

Action office

Number of open and

unresolved (U)
recommendations

Benefit type

Impact

22-E-0053

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

Office of
Chemical
Safety and
Pollution
Prevention

7

1(U)

Human health and
environmental
issues

Deficiencies and a lack of transparency in the
1,3-Dichloropropene pesticide cancer
assessment process has undermined scientific
credibility and public confidence.

21-E-0264

EPA Needs an
Agencywide Strategic
Action Plan to Address
Harmful Algal Blooms

Office of Water

1

Human health and
environmental
issues

Scientists predict that harmful algal bloom
occurrences in recreational waters and drinking
water sources will increase as excess nutrients
continue to flow into water bodies, temperatures
warm, and extreme weather events occur due to
climate change.

21-E-0186

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

Office of
Chemical
Safety and
Pollution
Prevention

7

Human health and
environmental
issues

Without the required testing and an effective
system of internal controls, the EPA cannot make
measurable progress toward complying with
statutory requirements or safeguarding human
health and the environment against risks from
endocrine-disrupting chemicals.

18-P-0080

EPA Needs to Evaluate
the Impact of the
Revised Agricultural
Worker Protection
Standard on Pesticide
Exposure Incidents

Office of
Chemical
Safety and
Pollution
Prevention

1

Human health and
environmental
issues

Over 2 million agricultural workers and pesticide
handlers are protected by the Agricultural Worker
Protection Standard, or WPS. Revisions to the
standard are intended to reduce exposure to
pesticides and provide enhanced protection to
agricultural workers, pesticide handlers, and their
families.

17-P-0053

Additional Measures
Can Be Taken to
Prevent Deaths and
Serious Injuries from
Residential Fumigations

Office of
Chemical
Safety and
Pollution
Prevention

1

Human health and
environmental
issues

The EPA can better prevent deaths and serious
injuries caused during residential fumigations by
amending sulfuryl fluoride labels and monitoring
compliance.

23-N-0025

11


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Table A-5: Open and unresolved recommendations associated with the EPA top management challenge of
safeguarding scientific integrity principles

Report No.

Report title

Action office

Number of open and

unresolved (U)
recommendations

Benefit type

Impact

23-E-0013

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

Office of
Research and
Development

Office of
Mission
Support

Office of the
Administrator

3 (U)

1(U)
1(U)

Human health and
environmental
issues

Without the required testing and an effective
system of internal controls, the EPA cannot make
measurable progress toward complying with
statutory requirements or safeguarding human
health and the environment against risks from
endocrine-disrupting chemicals.

21-E-0146

EPA Deviated from
Typical Procedures in Its
2018 Dicamba Pesticide
Registration Decision

Office of
Chemical
Safety and
Pollution
Prevention

1

Human health and
environmental
issues

The EPA needs to document and follow
established procedures to ensure scientifically
sound decisions regarding pesticides. The EPA's
actions on the dicamba registrations left the
decision legally vulnerable, resulting in the Ninth
Circuit Court of Appeals vacating the 2018
registrations for violating the Federal Insecticide,
Fungicide, and Rodenticide Act, or FIFRA, by
substantially understating some risks and failing
to acknowledge others entirely.

20-P-0173

Further Efforts Needed
to Uphold Scientific
Integrity Policy at EPA

Office of
Research and
Development

3

Human health and
environmental
issues

Improving implementation of the Scientific
Integrity Policy will enable the EPA to more
effectively carry out its mission to protect human
health and the environment.

23-N-0025

12


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Table A-6: Open and unresolved recommendations associated with the EPA top management challenge of
ensuring Agency systems and other critical infrastructure are protected against cyberthreats

Report No.

Report title

Action office

Number of open and

unresolved (U)
recommendations

Benefit type

Impact

23-P-0003

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

Office of Water

4 (U)

Administrative
and business
operations

If water systems do not complete risk and
resilience assessments or emergency response
plans, they are more vulnerable to cyberattacks
and other malevolent acts. The 19 percent of
water systems that did not certify completion of
these assessments and plans serve 40 million
people.

22-P-0010

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

Office of
Chemical
Safety and
Pollution
Prevention

1

Administrative
and business
operations

The EPA's goal to provide its workforce and the
public with accurate information is undermined
when the Agency does not correct deficiencies in
a timely manner, which weakens the integrity of
its systems and data.

21-E-0124

EPA Needs to Improve
Processes for Updating
Guidance, Monitoring
Corrective Actions, and
Managing Remote
Access for External
Users

Office of
Mission
Support

1

Administrative
and business
operations

Deficiencies in the EPA's information technology
internal controls could be used to exploit
weaknesses in Agency applications and hinder
the EPA's ability to prevent, detect, and respond
to emerging cyberthreats.

19-P-0207

EPA Effectively Screens
Air Emissions Data from
Continuous Monitoring
Systems but Could
Enhance Verification of
System Performance

Office of Air
and Radiation

1

Human health and
environmental
issues

Data from the Continuous Emissions Monitoring
System are used to determine whether sources,
such as power plants, comply with emissions
limits designed to improve air quality and achieve
environmental and public health goals.

23-N-0025

13


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Table A-7: Open and unresolved recommendations associated with the EPA top management challenge of
managing business operations and resources

Report No.

Report title

Action office

Number of open and

unresolved (U)
recommendations

Benefit type

Impact

22-P-0050

The EPA Was Not
Compliant with the
Payment Integrity
Information Act for
Fiscal Year 2021

Office of the
Chief Financial
Officer

1

Administrative
and business
operations

The EPA needs to implement appropriate control
measures to better identify and reduce the risk of
improper payments.

22-P-0033

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

Office of Land
and Emergency
Management

4

Administrative
and business
operations

The Office of Brownfields and Land Revitalization
did not complete all certified corrective actions
and still lacks current and accurate information
needed to monitor an estimated $46.6 million of
program income.

22-P-0019

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

Office of
Mission
Support

1

Administrative
and business
operations

Providing training on religious compensatory time
to all EPA supervisors and employees would
decrease the potential for employee misuse, as
well as the Agency's monetary liability.

22-P-0018

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

Office of
Mission
Support

1

Administrative
and business
operations

The EPA risks mismanaging over $20 billion in
cumulative grant funds by inconsistently tracking
grants that were modified during the coronavirus
pandemic and lacking an electronic data storage
plan.

22-F-0007

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

Office of
Enforcement

and
Compliance
Assurance

1

Administrative
and business
operations

We found the EPA's financial statements to be
fairly presented and free of material
misstatement. However, the Agency needs to
address deficiencies to strengthen its accounting
and financial statement preparation processes.

22-P-0001

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

Office of
Mission
Support

1

Administrative
and business
operations

The Digital Accountability and Transparency Act
requires the EPA to report accurate financial and
award data on USAspending.gov.

21-E-0254

Pandemic Highlights
Need for Additional
Tribal Drinking Water
Assistance and
Oversight in EPA
Regions 9 and 10

Region 9

2

Human health and
environmental
issues

The coronavirus pandemic negatively impacted
the oversight and assistance that Regions 9 and
10 provide to the tribal drinking water systems
under their purview, as well as the capacity of
these systems to provide safe drinking water.

21-P-0131

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

Office of
Enforcement

and
Compliance
Assurance

2

Human health and
environmental
issues

Safety, health, and attrition issues may
compromise the National Enforcement
Investigations Center's, or NEIC's, ability to
support the EPA's civil and criminal enforcement
efforts.

23-N-0025

14


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Report No.

Report title

Action office

Number of open and

unresolved (U)
recommendations

Benefit type

Impact

21-P-0130

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

Office of Water

2

Human health and
environmental
issues

The EPA and states can reduce the volume of
trash, including plastics, in U.S. waterways by
evaluating barriers to implementing the Clean
Water Act, or CWA, and developing strategies to
overcome those barriers.

21-P-0114

EPA Does Not
Consistently Monitor
Hazardous Waste Units
Closed with Waste in
Place or Track and
Report on Facilities That
Fall Under the Two
Responsible Programs

Office of
Enforcement

and
Compliance
Assurance

Office of Land
and Emergency
Management

1
1

Human health and
environmental
issues

The EPA's inspection frequency of treatment,
storage, and disposal facilities, or TSDFs, with
Resource Conservation and Recovery Act, or
RCRA, units closed with waste in place does not
meet the EPA's statutory requirement or policy.

21-P-0042

EPA Needs to
Substantially Improve
Oversight of Its Military
Leave Processes to
Prevent Improper
Payments

Office of
Mission
Support and
Office of the
Chief Financial
Officer

Office of the
Chief Financial
Officer

8
1

Administrative
and business
operations

The EPA paid 124 reservists about $1.4 million in
military leave pay from January 2017 through
June 2019. We identified potential improper
payments of $129,000 related to 104 of the
1,628 payroll transactions that we audited.

21-P-0032

Region 2's Hurricanes
Irma and Maria
Response Efforts in
Puerto Rico and U.S.
Virgin Islands Show the
Need for Improved
Planning,

Communications, and
Assistance for Small
Drinking Water Systems

Region 2

2

Human health and
environmental
issues

Enhancements to water system capacity and
emergency preparation for island response could
better protect the health of communities impacted
by hurricanes and other disasters.

20-P-0146

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

Office of Air
and Radiation

2

Human health and
environmental
issues

Delays in processing tribal New Source Review
permits could impact construction projects and
increase the risk that existing facilities awaiting a
permit could be emitting more pollution than
would be allowed if they were operating under an
approved permit.

23-N-0025

15


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Report No.

Report title

Action office

Number of open and

unresolved (U)
recommendations

Benefit type

Impact

19-P-0195

Pesticide Registration
Fee, Vulnerability
Mitigation and Database
Security Controls for
EPA's FIFRA andPRIA
Systems Need
Improvement

Office of
Chemical
Safety and
Pollution
Prevention

1

Administrative
and business
operations

Proper vulnerability testing, fee registration, and
database controls are essential to the security of
the EPA's FIFRA and Pesticide Registration
Improvement Act, or PRIA, systems.

17-P-0368

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

Office of Land
and Emergency
Management

1

The EPA previously

closed this
recommendation, but
the OIG reopened it.

Administrative
and business
operations

For ten of the 20 closed Brownfields revolving
loan fund cooperative agreements that we
reviewed, approximately $10.9 million available to
clean up brownfields is not being used as
intended.

16-P-0333

Enhanced Controls
Needed to Prevent
Further Abuse of
Religious Compensatory
Time

Office of
Mission
Support

1

The EPA previously

closed this
recommendation, but
the OIG reopened it.

Administrative
and business
operations

Inadequate controls for Religious Compensatory
Time resulted in payouts to employees
of $73,514 and may result in additional payouts
of up to $81,927.

14-P-0109

Internal Controls
Needed to Control Costs
of Emergency and
Rapid Response
Services Contracts, as
Exemplified in Region 6

Region 6

1

Administrative
and business
operations

Improper application of general and
administrative rates resulted in higher costs to the
government.

11-P-0215

EPA's Endocrine
Disruptor Screening
Program Should
Establish Management
Controls to Ensure More
Timely Results

Office of
Chemical
Safety and
Pollution
Prevention

3

The EPA previously

closed these
recommendations, but
the OIG reopened
them.

Human health and
environmental
issues

The Endocrine Disruptor Screening Program, or
EDSP, will not be able to establish an effective
screening and testing program without
establishing program control and accountability.
As a result, achieving the goal of protecting
human health and the environment from
endocrine disruptors will continue to be delayed.

10-P-0224

EPA Should Revise
Outdated or Inconsistent
EPA-State Clean Water
Memoranda of
Agreement

Office of Water

1

Human health and
environmental
issues

The state of the memorandums of agreement
means that the EPA cannot ensure that it has
effective management control over state
programs that assures the public that CWA
objectives are being achieved.

08-P-0196

Making Better Use of
Stringfellow Superfund
Special Accounts

Region 9

1

Human health and
environmental
issues

The EPA could reallocate some portion of its
other Trust Fund dollars to other priority sites or
needs. Alternatively, if funds are transferred to
the Trust Fund, there are numerous Superfund
requirements and priorities elsewhere in the
United States that could be addressed by putting
the approximately $27.8 million of idle funds to
better use.

23-N-0025

16


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Table A-8: Open and unresolved recommendations associated with the top EPA management challenge of
enforcing compliance with environmental laws and regulations

Report No.

Report title

Action office

Number of open and

unresolved (U)
recommendations

Benefit type

Impact

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

Office of
Enforcement

and
Compliance
Assurance

Office of Air
and Radiation

3 (U)
3 (U)

Human health and
environmental
issues

The EPA's ineffective residential wood heater
program puts human health and the environment
at risk for exposure to dangerous fine-particulate-
matter pollution by allowing sales of wood
heaters that may not meet emission standards.

22-E-0051

Additional Internal
Controls Would Improve
the EPA's System for
Electronic Disclosure of
Environmental
Violations

Office of
Enforcement

and
Compliance
Assurance

3

Human health and
environmental
issues

Without additional internal controls, the EPA
cannot ensure that it effectively screens regulated
entities' self-disclosures of environmental
violations to identify and mitigate significant
concerns, such as criminal conduct and potential
imminent hazards. If not mitigated, these
significant concerns could pose threats to human
health and the environment.

22-E-0047

The EPA Continues to
Fail to Meet Inspection
Requirements for
Hazardous Waste
Treatment, Storage, and
Disposal Facilities

Office of
Enforcement

and
Compliance
Assurance

1

Human health and
environmental
issues

This follow-up evaluation was conducted to
assess whether inspection rates of TSDFs have
changed since our earlier 2016 report on the
same topic: OIG Report No. 16-P-0104, EPA Has
Not Met Statutory Requirements for Hazardous
Waste Treatment, Storage and Disposal Facility
Inspections, but Inspection Rates Are High,
issued March 11, 2016.

21-P-0175

EPA Should Conduct
More Oversight of
Synthetic-Minor-Source
Permitting to Assure
Permits Adhere to EPA
Guidance

Office of Air
and Radiation

5

Human health and
environmental
issues

Without clear and enforceable limitations in
synthetic-minor-source permits, facilities may
emit excess pollution that would otherwise
subject them to the more stringent requirements
of the Clean Air Act major-source permitting
programs.

21-P-0132

Resource Constraints,
Leadership Decisions,
and Workforce Culture
Led to a Decline in
Federal Enforcement

Office of
Enforcement

and
Compliance
Assurance

3 (U)

Human health and
environmental
issues

A decline in the EPA's enforcement activities may
expose the public and the environment to
undetected harmful pollutants.

21-P-0122

Improved Review
Processes Could
Advance EPA Regions 3
and 5 Oversight of
State-Issued National
Pollutant Discharge
Elimination System
Permits

Region 3
Region 5

1
1

Human health and
environmental
issues

Improved EPA oversight could ensure that state
National Pollutant Discharge Elimination System,
or NPDES, programs are protecting human
health and the environment.

23-N-0025

17


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Report No.

Report title

Action office

Number of open and

unresolved (U)
recommendations

Benefit type

Impact

16-P-0104

EPA Has Not Met
Statutory Requirements
for Hazardous Waste
Treatment Storage and
Disposal Facility
Inspections, but
Inspection Rates Are
High

Office of
Enforcement

and
Compliance
Assurance

1

The EPA previously

closed this
recommendation, but
the OIG reopened it.

Human health and
environmental
issues

Missed TSDF inspections violate the RCRA legal
requirement and can increase the risk of
exposure to hazardous substances.

23-N-0025

18


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Appendix B

Fifteen High-Priority Open or Unresolved Recommendations

This appendix details the 15 open or unresolved high-priority recommendations as of May 31, 2023. The
appendix contains two subsections that specify the benefits to be gained from the Agency's implementation of
associated corrective actions.

Recommendations with Human Health or Environmental Benefits

By Developing a Plan to Define and Provide Appropriate Oversight, Region 9 Can Ensure
Transparency on the Decontamination and Closure of the Red Hill Facility (1 recommendation)

Report number

23-E-0015

Date issued

April 25, 2023

Report title

EPA Region 9 Must Continue Oversight Throughout the Decontamination and Closure of the Red Hill
Facility

Responsible office

Region 9

High-priority
recommendations
issued within
report

2. Collaborate with the Hawaii Department of Health and the Navy, as appropriate, to clearly

communicate risk and remediation information to the public.

a)	Corrective Action 2.1 - Require Navy/DLAto host quarterly public updates on defueling,
closure, completion of the implementation of the Drinking Water Long Term Monitoring
Plan, and environmental investigation and remediation work with participation from EPA
and Hawaii Department of Health pursuant to proposed 2023 Consent Order.

b)	Corrective Action 2.2 - Develop a web-based application to make Red Hill groundwater
monitoring well data more easily available to the public.

c)	Corrective Action 2.3 - With input from Hawaii Department of Health, develop a Community
Involvement Plan, which will include a section on improving public communication through
website updates and FAQs.

d)	Corrective Action 2.4 - Collaborate with Hawaii Department of Health to host a three-part
webinar series to share information with the public on what agencies are doing to address
impacts to human health and the environment from Red Hill releases. The first webinar was
completed January 12, 2023, and is posted on EPA's Red Hill website.

Associated top management challenge: enforcing compliance with environmental laws
and regulations.

Status of

high-priority

recommendations

Open

Recommendation 2:

•	Planned completion date for Corrective Action 2.1

•	Planned completion date for Corrective Action 2.2

•	Planned completion date for Corrective Action 2.3

•	Planned completion date for Corrective Action 2.4

June 1, 2023
August 1, 2023
December 1, 2023
December 1, 2023

Report impact
statement

Decontamination and closure of the Red Hill facility requires transparency and accountability to
protect the Oahu aquifer—the primary drinking water source on the island.

23-N-0025

19


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The EPA Did Not Follow the Typical Intra-Agency Review and Clearance Process of the
January 2021 PFBS Toxicity Assessment (4 recommendations)

Report number

23-E-0013

Date issued

March 7, 2023

Report title

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

Responsible office

Office of Research and Development, Office of Mission Support, and Office of the Administrator

High-priority
recommendations
issued within
report

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.

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.

4.	Develop or update existing policies, procedures, or guidance to require policymakers 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.

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.

Associated top management challenge: safeguarding scientific integrity principles.

Status of

high-priority

recommendations

Unresolved
Recommendation 1:

•	Planned completion date: Unresolved

Recommendation 3:

•	Planned completion date: Unresolved

Recommendation 4:

•	Planned completion date: Unresolved

Recommendation 5:

•	Planned completion date: Unresolved

Report impact
statement

Without the required testing and an effective system of internal controls, the EPA cannot make
measurable progress toward complying with statutory requirements or safeguarding human health
and the environment against risks from endocrine-disrupting chemicals.

23-N-0025

20


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The EPA's Decision to Not Adhere to Standard Operating Procedures Undermines Public
Confidence in Transparency to Prevent Unreasonable Impacts on Human Health
(1 recommendation)

Report number

22-E-0053

Date issued

July 20, 2022

Report title

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

Responsible office

Office of Chemical Safety and Pollution Prevention

High-priority
recommendations
issued within
report

8. Conduct an external peer review on the 1,3-Dichloropropene cancer-risk assessment.
Associated top management challenge: providing for the safe use of chemicals.

Status of

high-priority

recommendations

Unresolved
Recommendation 8:

• Planned Completion date: Unresolved

Report impact
statement

Deficiencies and a lack of transparency in the 1,3-Dichloropropene pesticide cancer-assessment
process has undermined scientific credibility and public confidence.

Testing and Controls Are Necessary for the EPA to Make Measurable Progress to Safeguard
Against the Risk of Endocrine-Disrupting Chemicals (1 recommendation)

Report number

21-E-0186

Date issued

July 28, 2021

Report title

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

Responsible office

Office of Chemical Safety and Pollution Prevention

High-priority
recommendations
issued within
report

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.

Associated top management challenge: providing for the safe use of chemicals.

Status of

high-priority

recommendations

Open

Recommendation 1:

• Planned completion date: September 30, 2025

Report impact
statement

Without the required testing and an effective system of internal controls, the EPA cannot make
measurable progress toward complying with statutory requirements or safeguarding human health
and the environment against risks from endocrine-disrupting chemicals.

23-N-0025

21


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Limited Oversight of Permits May Allow Facilities to Emit Excess Pollution that Would
Otherwise Be Subject to Stringent Clean Air Act Requirements (1 recommendation)

Report number

21-P-0175

Date issued

July 8, 2021

Report title

EPA Should Conduct More Oversight of Synthetic-Minor-Source Permitting to Assure Permits
Adhere to EPA Guidance

Responsible office

Office of Air and Radiation

High-priority
recommendations
issued within
report

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

Associated top management challenge: enforcing compliance with environmental laws
and regulations.

Status of

high-priority

recommendations

Open

Recommendation 5:

• Planned completion date: December 31, 2023

Report impact
statement

Without clear and enforceable limitations in synthetic-minor-source permits, facilities may emit
excess pollution that would otherwise subject them to more stringent requirements of the Clean Air
Act major-source permitting programs.

The EPA Lacks Internal Controls to Address Inspection Frequency Deficiencies, Leading to
Inconsistent Data (1 recommendation)

Report number

21-P-0114

Date issued

March 29, 2021

Report title

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

Responsible office

Office of Enforcement and Compliance Assurance

High-priority
recommendations
issued within
report

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.

Associated top management challenge: managing business operations and resources.

Status of

high-priority

recommendations

Open

Recommendation 2:

•	Planned completion date: Unresolved

•	Revised completion date: March 29, 2024

Report impact
statement

The EPA's inspection frequency of TSDFs with RCRA units closed with waste in place does not
meet the EPA's statutory requirement or policy.

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Improving Implementation of the Scientific Integrity Policy Will Enable the EPA to More
Effectively Carry Out Its Mission to Protect Human Health and the Environment
(2 recommendations)

Report number

20-P-0173

Date issued

May 20, 2020

Report title

Further Efforts Needed to Uphold Scientific Integrity Policy at EPA

Responsible office

Office of Research and Development/EPA Science Advisor

High-priority
recommendations
issued within
report

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

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.

Associated top management challenge: safeguarding scientific integrity principles.

Status of

high-priority

recommendations

Open

Recommendation 7:

•	Planned completion date: September 30, 2020

•	Revised completion dates: April 30, 2022; June 30, 2022; March 31, 2023; and June 30,
2024

Recommendation 8:

•	Planned completion date: June 30, 2021

•	Revised completion date: June 30, 2022; March 31, 2023; and June 30, 2024

Report impact
statement

Improving implementation of the Scientific Integrity Policy will enable the EPA to more effectively
carry out its mission to protect human health and the environment.

Flint, Michigan's Residents Were Exposed to Lead in Drinking Water Partially Because of
the EPA's Delayed Response (1 recommendation)

Report number

18-P-0221

Date issued

July 19, 2018

Report title

Management Weaknesses Delayed Response to Flint Water Crisis

Responsible office

Office of Enforcement and Compliance Assurance

High-priority
recommendations
issued within
report

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.

Associated top management challenge: integrating and leading environmental justice across the
Agency and government.

Status of

high-priority

recommendations

Reopened by OIG
Recommendation 8:

•	Planned completion date: July 7, 2021

•	Revised completion date: April 28, 2023, and October 27, 2023

Report impact
statement

The EPA should strengthen its oversight of state drinking water programs to improve the efficiency
and effectiveness of the Agency's response to drinking water contamination emergencies.

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Since 2008, the EPA Has Been Unable to Complete the Corrective Action to Reclassify or
Transfer $27.8 Million of the Stringfellow Superfund Special Accounts (1 recommendation)

Report number

08-P-0196

Date issued

July 9, 2008

Report title

Making Better Use of Stringfellow Superfund Special Accounts

Responsible office

Region 9

High-priority
recommendations
issued within
report

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.

Associated top management challenge: managing business operations and resources.

Status of

high-priority

recommendations

Open

Recommendation 2:

•	Upon issuance: December 31, 2012

•	Revised: September 30, 2023, and September 30, 2026

Report impact
statement

The EPA could reallocate some portion of its other Trust Fund dollars to other priority sites or needs.
Alternatively, if funds are transferred to the Trust Fund, there are numerous Superfund requirements
and priorities elsewhere in the United States that could be addressed by putting the approximately
$27.8 million of idle funds to better use.

Recommendations with Administrative or Business Operation Benefits

The EPA Did Not Adequately Conclude Whether Its Programs with Annual Outlays Greater
than $10 Million Were Likely to Make Improper Payments (1 recommendation)

Report number

22-P-0050

Date issued

June 27, 2022

Report title

The EPA Was Not Compliant with the Payment Integrity Information Act for Fiscal Year 2021

Responsible office

Office of the Chief Financial Officer

High-priority
recommendations
issued within
report

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.

Associated top management challenge: managing business operations and resources.

Status of

high-priority

recommendations

Open

Recommendation 2:

•	Upon issuance: Unresolved

•	Revised: November 15, 2023

Report impact
statement

The EPA needs to implement appropriate control measures to better identify and reduce the risk of
its improper payments.

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The EPA Continues to Lack Current, Accurate, and Complete Data Necessary for Effective Post
Closeout Monitoring of Brownfields Program Income (1 recommendation)

Report number

22-P-0033

Date issued

March 31, 2022

Report title

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

Responsible office

Office of Land and Emergency Management

High-priority
recommendations
issued within
report

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

Associated top management challenge: managing business operations and resources.

Status of

high-priority

recommendations

Open

Recommendation 6:

•	Planned completion date: Unresolved

•	Revised completion date: September 30, 2024

Report impact
statement

The Office of Brownfields and Land Revitalization did not complete all certified corrective actions and
still lacks current and accurate information needed to monitor an estimated $46.6 million of program
income.

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Appendix C

Twenty-Two Unresolved Recommendations

This appendix details 22 unresolved recommendations as of May 31, 2023, including summaries of OIG findings,
the responsible office, and resolution progress towards agreement. These 22 unresolved recommendations were
issued across six reports.

The EPA's January 2021 PFBS Toxicity Assessment Did Not Uphold the Agency's Commitments
to Scientific Integrity and Information Quality (5 recommendations)

Report number

23-E-0013

Date issued

March 7, 2023

Summary of
findings

The EPA did not follow the typical intra-agency review and clearance process during the
development and publication of the January 2021 perfluorobutane sulfonic acid, or PFBS, toxicity
assessment. During final clearance, a political appointee directed that a last-minute review be
conducted of the uncertainty factors used to calculate toxicity values, resulting in a scientific
disagreement that caused delay, confusion, and significant changes to the near-final, peer-reviewed
work product. These changes included replacing single toxicity values with unprecedented toxicity
ranges. Users of the PFBS toxicity assessment— for example, regulated entities cleaning up PFBS
contamination—could have selected a less stringent value within this range, which may have been
less costly but also 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 policies and
procedures to address these concerns. Without updates to policies and procedures, the Agency
cannot fulfill its commitment to scientific integrity and information quality.

Responsible office

Office of Research and Development

Unresolved
Recommendations

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.

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.

4.	Develop or update existing policies, procedures, or guidance to require policymakers 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.

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.

Associated top management challenge: safeguarding scientific integrity principles.

Resolution
progress

The Agency provided a response to the final report on May 5, 2023, disagreeing with the report
recommendations. OIG staff contacted the responsible offices to schedule a meeting to discuss the
report and its recommendations before the Agency provided its response, but the Agency declined to
meet with them. On May 30, 2023, the OIG issued a memorandum highlighting the need to work
through the resolution process on these important issues.

Report impact
statement

Without the required testing and an effective system of internal controls, the EPA cannot make
measurable progress toward complying with statutory requirements or safeguarding human health
and the environment against risks from endocrine-disrupting chemicals.

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The EPA's Residential Wood Heater Program Does Not Provide Reasonable Assurance that
Heaters Are Properly Tested and Certified Before Reaching Consumers (6 recommendations)

Report number

23-E-0012

Date issued

February 28, 2023

Summary of
findings

The EPA's residential wood heater program does not provide reasonable assurance that wood
heaters are properly tested and certified before reaching consumers. The EPA's 2015 New Source
Performance Standards for residential wood heaters is flawed, and the EPA has approved methods
that lack clarity and allow too much flexibility. 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. In fact, data from an EPA-approved testing lab indicate
that some certified wood heaters do not meet emission standards. Although the EPA withdrew some
flawed certification test methods, wood heaters certified based on those withdrawn test methods
remain available for sale.

Additionally, the EPA lacks internal controls to ensure that certification test reports are valid and that
certification tests are conducted appropriately. As a result, test reports contained deficiencies that
should have been found during the certification process. Effective internal controls would include
policies, procedures, and guidance; standardized certification test report formats; and systematic
compliance audit tests. State regulators told us that they cannot rely on the EPA's certifications of
wood heaters and, therefore, develop their own standards and lists of approved wood heaters for
sale.

The EPA operates and supports changeout programs intended to replace older, dirtier wood heaters
with newer, cleaner models. The EPA distributed approximately $82 million in grants for residential
wood heater changeout programs from fiscal years 2015 through 2021. However, if the replacement
models do not meet emission standards because of the reasons described above, millions of federal,
state, and local dollars could be wasted.

Responsible office

Office of Enforcement and Compliance Assurance and Office of Air and Radiation

Unresolved
Recommendations

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.

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.

5.	Develop and adopt an EPA cord wood test method that is supported by data to provide the
public reasonable assurance that certified appliances meet emission standards.

6.	Establish mechanisms to promote independence between emissions testing labs and third-party
certifiers.

Associated top management challenge: enforcing compliance with environmental laws and
regulations.

Resolution
progress

The Agency provided a response to the final report on April 28, 2023. As of the date of this
Compendium, the OIG was developing a response. Resolution efforts are ongoing.

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Report impact	The EPA's ineffective residential wood heater program puts human health and the environment at

statement	risk for exposure to dangerous fine-particulate-matter pollution by allowing sales of wood heaters

that may not meet emission standards.

The EPA Met 2018 Water Security Requirements but Needs to Improve Oversight to Support
Water System Compliance (4 recommendations)

Report number

23-P-0003

Date issued

November 21, 2022

Summary of
findings

The EPA met the requirements of section 2013 of the America's Water Infrastructure Act of 2018 to
consult with stakeholders and develop malevolent acts baseline information by August 2019. The
EPA updated its baseline information 18 months later in response to an increase in the frequency of
cyberattacks. However, the deadlines imposed by the Act for medium and large water systems to
complete their risk and resilience assessments had passed, and the systems were not required to
update their assessments.

Approximately 19 percent of water systems did not certify that they had completed their risk and
resilience assessments by the statutory deadlines. These noncompliant water systems may not be
aware of their vulnerability to malevolent acts that could result in loss of service or unsafe drinking
water. Furthermore, 95 percent of the noncompliant water systems were small water systems, and
noncompliant small water systems more likely served disadvantaged communities than compliant
systems.

The EPA did not provide adequate oversight to ensure the compliance of water systems—
particularly small water systems—with the requirements of the America's Water Infrastructure Act.
Specifically, the EPA did not maintain accurate contact information for water systems, publish
guidance regarding enforcement actions against noncompliant water systems, provide sufficient
assistance to support small water system compliance, or review the quality of the risk and resilience
assessments and emergency response plans. Water systems may therefore fail to meet the Act's
requirements and may not understand their vulnerability to malevolent acts.

Responsible office

Office of Water

Unresolved
Recommendations

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.

Associated top management challenge: ensuring Agency systems and other critical infrastructure

are protected against cyberthreats.

Resolution
progress

In its February 15, 2023 response to the final report, the Agency proposed planned corrective actions
and estimated completion dates for the four unresolved recommendations. In its May 5, 2023

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response, the OIG wrote that planned corrective actions were only partly responsive to the
recommendations. As a result, the recommendations remain unresolved.

Report impact
statement

If water systems do not complete risk and resilience assessments or emergency response plans,
they are more vulnerable to cyberattacks and other malevolent acts. The 19 percent of water
systems that did not certify completion of these assessments and plans serve 40 million people.

The EPA Needs to Improve the Transparency of Its Cancer-Assessment Process for Pesticides
(1 recommendation)

Report number

22-E-0053

Date issued

July 20, 2022

Summary of
findings

The EPA did not adhere to standard operating procedures and requirements for the
1,3-Dichloropropene pesticide cancer-assessment process, which undermines public confidence in
and the transparency of the Agency's scientific approaches to prevent unreasonable impacts on
human health. Specifically, the EPA used two scientific approaches, kinetically derived maximum
dose and weight-of-evidence, in its cancer-assessment process for 1,3-Dichloropropene, even
though it did not have guidance outlining how to use those approaches. The EPA also did not adhere
to docketing and transparency requirements to provide the public and stakeholders with information
that may have influenced the EPA's cancer-assessment decision. Further, the EPA did not follow its
literature-search procedures and neglected to document its review of all health effects data that may
have impacted the results of the 1,3-Dichloropropene draft human health risk assessment, which is
informed by the cancer assessment. The EPA's Cancer Risk Assessment Committee did not adhere
to the EPA's Peer Review Handbook and the Office of Management and Budget's guidance on peer
review in the areas of composition, independence, and expertise. These deficiencies undermined the
scientific credibility of the 1,3-Dichloropropene cancer assessment, which led to questioning by
multiple stakeholders. An external peer review would have improved the credibility of the cancer
assessment.

Responsible office

Office of Chemical Safety and Pollution Prevention

Unresolved
Recommendations

8. Conduct an external peer review on the 1,3-Dichloropropene cancer-risk assessment.
Associated top management challenge: providing for the safe use of chemicals.

Resolution
progress

The Agency provided a response to the final report on September 15, 2022, which outlined the
Agency's planned corrective actions and estimated milestone dates for three unresolved
recommendations. As stated in our October 13, 2022 memorandum, based on the information and
supporting documentation provided, we agreed that the proposed corrective actions met the intent of
two recommendations. However, we did not agree with the planned corrective action for
Recommendation 8, and we consider this recommendation unresolved.

Report impact
statement

Deficiencies and a lack of transparency in the 1,3-Dichloropropene pesticide cancer assessment
process has undermined scientific credibility and public confidence.

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Resource Constraints, Leadership Decisions, and Workforce Culture Led to a Decline in Federal
Enforcement (3 recommendations)

Report number

21-P-0132

Date issued

May 13, 2021

Summary of
findings

EPA-led compliance monitoring activities, enforcement actions, monetary enforcement results, and
environmental benefits generally declined from fiscal year 2007 through 2018 nationwide. This
downward trend also occurred at the regional level and on a statute-by-statute basis. While annual
enforcement measures, such as penalty dollars assessed or commitments to clean up pollution,
declined, the results varied year-to-year based on the conclusion of large cases.

The decline in enforcement resources was a primary driver behind the observed declining
enforcement trends, resulting in fewer compliance monitoring activities and concluded enforcement
actions. EPA leadership also made strategic decisions that affected enforcement trends, such as
focusing limited resources on the most serious cases and, in 2017, emphasizing deference to state
enforcement programs and compliance assistance. From 2006 through 2018, growth in the domestic
economy and new laws increased the size and level of activity in key sectors that the EPA regulated,
but the EPA's capacity to meet that need decreased.

The EPA's annual enforcement reports do not provide context for understanding the EPA's
enforcement accomplishments and the impact these enforcement activities have on human health
and the environment. For example, the EPA does not measure or report data for compliance-
assistance activities, informal enforcement actions, and noncompliance rates. The EPA could also
provide additional information that would provide context about the scope of activities captured by its
enforcement measures, such as the type of inspections conducted and the types and toxicity of
pollutants removed from the environment.

Responsible office

Office of Enforcement and Compliance Assurance

Unresolved
Recommendations

1.	Assess the needs of the Agency's enforcement program by completing a workforce analysis to
determine the level of staffing necessary to achieve and maintain a strong enforcement
presence in the field that protects human health and the environment.

2.	Integrate the results of the workforce analysis into the Office of Enforcement and Compliance
Assurance's annual and strategic planning processes.

5. Establish additional measures for Agency-led compliance assistance activities and informal
enforcement actions and include these new measures in future annual enforcement results
reports with the appropriate context.

Associated top management challenge: enforcing compliance with environmental laws and

regulations.

Resolution
progress

The Agency provided a response to the final report on July 12, 2021, which outlined the Agency's
planned corrective actions and estimated milestone dates for the three unresolved recommendations
issued in our report. As stated in our August 18, 2021 memorandum, based on the information and
supporting documentation provided in the response, the OIG did not agree with the Agency's
planned corrective actions. Resolution efforts are ongoing.

Report impact
statement

A decline in the EPA's enforcement activities may expose the public and the environment to
undetected harmful pollutants.

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EPA Needs to Improve Its Emergency Planning to Better Address Air Quality Concerns During
Future Disasters (3 recommendations)

Report number

20-P-0062

Date issued

December 16, 2019

Summary of
findings

Most air toxic emission incidents during Hurricane Harvey occurred within a five-day period of the
storm's landfall. The majority of these emissions were due to industrial facilities shutting down and
restarting operations in response to the storm and storage tank failures. However, state, local, and
EPA mobile air monitoring activities were not initiated in time to assess the impact of these
emissions. Additionally, once started, monitoring efforts did not always generate data considered
suitable for making health-based assessments, in part because there was no guidance outlining how
to monitor air quality following an emergency.

The air monitoring data collected did not indicate that the levels of individual air toxics after Hurricane
Harvey exceeded the health-based thresholds established by the state of Texas and the EPA.
However, these thresholds do not consider the cumulative impact of exposure to multiple air
pollutants at one time. Further, the EPA's thresholds are based on short-term exposure to a single
air pollutant and do not consider lifetime exposures. Consequently, the thresholds may not be
sufficiently protective of residents in communities that neighbor industrial facilities and experience
repeated or ongoing exposures to air toxics.

We did not identify instances of inaccurate communication from the EPA to the public regarding air
quality after Hurricane Harvey. However, public communication of air monitoring results was limited.
As a result, communities were unaware of the Agency's activities and data collection efforts. This
lack of awareness can diminish public trust and confidence in the EPA.

Responsible office

Office of Land and Emergency Management

Unresolved
Recommendations

1.	Develop general guidance to help state and local agencies and external stakeholders develop
air monitoring plans for emergency situations in heavily industrialized areas so that usable data
are collected in targeted areas of concern.

2.	Develop, in coordination with the Associate Administrator for Public Affairs, a plan for providing
public access to air monitoring data collected during an emergency response.

3.	Coordinate with the Office of Research and Development and the Office of Air Quality Planning
and Standards within the Office of Air to assess the availability and use of remote and portable
monitoring methods to monitor air toxics when stationary monitoring methods are not available.

Associated top management challenge: integrating and leading environmental justice across the

Agency and government.

Resolution
progress

The Agency provided a formal response to the final report on February 28, 2020. A meeting to
discuss the proposed corrective actions with the Agency was held in October 2022, after which the
Agency provided all revised deliverables for concurrence. Our assessment is ongoing.

Report impact
statement

Developing EPA guidance for collecting and communicating air quality data could improve public
confidence in the Agency during future disaster responses.

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Appendix D

Open Recommendations by Program Office and Region

This appendix provides a breakdown, by responsible region and program office, of the 91 recommendations that
were open as of May 31, 2023.

Table D-1: Office of the Administrator (2 recommendations)

Report no.

Report title

Number of open
recommendations

20-N-0128

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

1

18-P-0240

EPA Needs a Comprehensive Vision and Strategy for Citizen Science that Aligns with Its Strategic Objectives
on Public Participation

1

Table D-2: Office of Air and Radiation (17 recommendations)

Report no.

Report title

Number of open
recommendations

22-E-0026

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

1

22-E-0017

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

3

21-P-0175

EPA Should Conduct More Oversight of Synthetic-Minor-Source Permitting to Assure Permits Adhere to
EPA Guidance

5

21-P-0129

EPA Should Conduct New Residual Risk and Technology Reviews for Chloroprene- and Ethylene Oxide-
Emitting Source Categories to Protect Human Health

3

20-P-0146

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

2

19-P-0207

EPA Effectively Screens Air Emissions Data from Continuous Monitoring Systems but Could Enhance
Verification of System Performance

1

16-P-0275

EPA Has Not Met Certain Statutory Requirements to Identify Environmental Impacts of Renewable
Fuel Standard

2

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Table D-3: Office of Chemical Safety and Pollution Prevention (22 recommendations)

Report no.

Report title

Number of open
recommendations

22-E-0053

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

7

22-P-0010

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

1

21-E-0186

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

7

21-E-0146

EPA Deviated from Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision

1

19-P-0195

Pesticide Registration Fee, Vulnerability Mitigation and Database Security Controls for EPA's FIFRA and PR!A
Systems Need Improvement

1

18-P-0080

EPA Needs to Evaluate the Impact of the Revised Agricultural Worker Protection Standard on Pesticide
Exposure Incidents

1

17-P-0053

Additional Measures Can Be Taken to Prevent Deaths and Serious Injuries from Residential Fumigations

1

11-P-0215

EPA's Endocrine Disruptor Screening Program Should Establish Management Controls to Ensure More
Timely Results

3

Table D-4: Office of the Chief Financial Officer (2 recommendations)

Report no.

Report title

Number of open
recommendations

22-P-0050

The EPA Was Not Compliant with the Payment Integrity Information Act for Fiscal Year 2021

1

21-P-0042

EPA Needs to Substantially Improve Oversight of Its Military Leave Processes to Prevent Improper Payments

1

Table D-5: Office of Enforcement and Compliance Assurance (11 recommendations)

Report no.	Report title	Number of open

recommendations

22-E-0051 Additional internal Controls Would Improve the EPA's System for Electronic Disclosure of Environmental	3

Violations

22-E-0047 The EPA Continues to Fail to Meet Inspection Requirements for Hazardous Waste Treatment, Storage, and	1

Disposal Facilities

22-P-0046 The EPA Needs to Fully Address the OIG's 2018 Flint Water Crisis Report Recommendations by Improving	1

Controls, Training, and Risk Assessments

22-F-0007 EPA's Fiscal Years 2021 and 2020 (Restated) Consolidated Financial Statements	1

21-P-0131 Staffing Constraints, Safety and Health Concerns at EPA's National Enforcement Investigations Center May	2

Compromise Ability to Achieve Mission

21-P-0114 EPA Does Not Consistently Monitor Hazardous Waste Units Closed with Waste in Place or Track and Report	1

on Facilities That Fall Under the Two Responsible Programs

18-P-0221 Management Weaknesses Delayed Response to Flint Water Crisis	1

16-P-0104 EPA Has Not Met Statutory Requirements for Hazardous Waste Treatment, Storage and Disposal Facility	1

Inspections, but Inspection Rates Are High

23-N-0025

33


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Table D-6: Office of General Counsel (3 recommendations)

Report no.

Report title

Number of open
recommendations

20-E-0333

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

3

Table D-7: Office of Land and Emergency Management (6 recommendations)

Report no.

Report title

Number of open
recommendations

22-P-0033

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

4

21-P-0114

EPA Does Not Consistently Monitor Hazardous Waste Units Closed with Waste in Place or Track and Report
on Facilities That Fall Under the Two Responsible Programs

1

17-P-0368

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

1

Table D-8: Office of Mission Support (5 recommendations)

Report no.

Report title

Number of open
recommendations

22-P-0019

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

1

22-P-0018

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

1

22-P-0001

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

1

21-E-0124

EPA Needs to Improve Processes for Updating Guidance, Monitoring Corrective Actions, and Managing
Remote Access for External Users

1

16-P-0333

Enhanced Controls Needed to Prevent Further Abuse of Religious Compensatory Time

1

Table D-9: Office of Mission Support and Office of the Chief Financial Officer (8 recommendations)

Report no.

Report title

Number of open
recommendations

21-P-0042

EPA Needs to Substantially Improve Oversight of Its Military Leave Processes to Prevent Improper Payments

8

Table D-10: Office of Research and Development and Science Advisor (3 recommendations)

Report no.

Report title

Number of open
recommendations

20-P-0173

Further Efforts Needed to Uphold Scientific Integrity Policy at EPA

3

Table D-11: Office of Water (4 recommendations)

Report no.

Report title

Number of open
recommendations

21-E-0264

EPA Needs an Agencywide Strategic Action Plan to Address Harmful Algal Blooms

1

21-P-0130

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

2

10-P-0224

EPA Should Revise Outdated or Inconsistent EPA-State Clean Water Memoranda of Agreement

1

23-N-0025

34


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Table D-12: Region 2 (2 recommendations)

Report no.

Report title

Number of open
recommendations

21-P-0032

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

2

Table D-13: Region 3 (1 recommendation)

Report no.

Report title

Number of open
recommendations

21-P-0122

Improved Review Processes Could Advance EPA Regions 3 and 5 Oversight of State-Issued National Pollutant
Discharge Elimination System Permits

1

Table D-14: Region 5 (1 recommendation)

Report no.

Report title

Number of open
recommendations

21-P-0122

Improved Review Processes Could Advance EPA Regions 3 and 5 Oversight of State-Issued National Pollutant
Discharge Elimination System Permits

1

Table D-15: Region 6 (1 recommendation)

Report no.

Report title

Number of open
recommendations

14-P-0109

Internal Controls Needed to Control Costs of Emergency and Rapid Response Services Contracts, as
Exemplified in Region 6

1

Table D-16: Region 9 (3 recommendations)

Report no.

Report title

Number of open
recommendations

21-E-0254

Pandemic Highlights Need for Additional Tribal Drinking Water Assistance and Oversight in EPA Regions 9
and 10

2

08-P-0196

Making Better Use of Stringfellow Superfund Special Accounts

1

23-N-0025

35


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Appendix E

Fifty-Two Corrective Actions Scheduled to Take
Three Years or More to Implement

This appendix provides details for the 27 reports containing 52 open recommendations, as of May 31, 2023, for
which the Agency's corrective actions are scheduled to take three years or longer to implement. The reports are
listed in order of projected implementation of corrective actions, from three years to 18 years.

EPA Should Conduct More Oversight of Synthetic-Minor-Source Permitting to Assure Permits
Adhere to EPA Guidance (3 recommendations)

Report number

21-P-0175

Date issued

July 8, 2021

Summary of
findings

While the EPA oversees state and local compliance monitoring for synthetic-minor-source permits,
the EPA conducts only limited oversight of the permits themselves. The EPA has issued guidance to
state and local agencies to develop enforceable permit limitations in synthetic-minor-source permits,
but the Agency does not review permits to ensure the agencies meet this guidance.

We reviewed 16 natural gas extraction industry synthetic-minor-source permits from Colorado and
Oklahoma and found that many of the permit limitations did not adhere to the EPA's guidance. For
example, in those permits, we found that 102 of 529 permit limits did not have sufficient information
within the permits or their supporting documentation to determine whether the limits were technically
accurate. We also found that 26 limits did not specify the method for assessing compliance. In
addition, 55 limits did not have sufficient monitoring requirements to determine whether the facility's
assumed pollution reduction from pollution control devices was being achieved. This could result in a
synthetic-minor facility emitting pollutants at or above major-source levels without being detected.

In addition, we found that the EPA had not communicated several key expectations for synthetic
minor-source permitting to state and local agencies via guidance. Further, Oklahoma does not allow
the public to participate in its permitting process for certain synthetic-minor-source permits, as
required by EPA regulations. EPA staff said this may be the case in other states as well.

Responsible office

Office of Air and Radiation

Recommendation
open three years
or more

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.

c)	Procedures to resolve any permitting deficiencies identified during the initial and periodic
reviews.

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

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

23-N-0025

36


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Planned

completion date

Recommendation 2:

•	Upon issuance: October 31, 2024 (more than three years after report issuance)

Recommendation 3:

•	Upon issuance: December 31, 2024 (more than three years after report issuance)

Recommendation 4:

•	Upon issuance: October 31, 2024 (more than three years after report issuance)

Report impact
statement

Without clear and enforceable limitations in synthetic-minor-source permits, facilities may emit
excess pollution that would otherwise subject them to the more stringent requirements of the Clean
Air Act major-source permitting programs.

Staffing Constraints, Safety and Health Concerns at EPA's National Enforcement
Investigations Center May Compromise Ability to Achieve Mission (2 recommendations)

Report number

21-P-0131

Date issued

May 12, 2021

Summary of
findings

NEIC addressed internal and external findings and implemented corrective actions related to safety
and health, yet concerns persisted. These concerns included unconducted internal safety and health
audits and management reviews, hazardous waste mismanagement, noncompliance with safety
procedures, and staff concerns about safety and health at NEIC.

NEIC was addressing findings and implementing corrective actions related to its Quality
Management System, which is designed to generate scientifically sound and legally defensible
information to support environmental enforcement. We found that NEIC should improve tracking
issues, such as observations, comments, concerns, and opportunities for improvement identified
from audits; management review action items; and customer complaints.

NEIC had unresolved action items from Office of Criminal Enforcement, Forensics, and Training's
Professional Integrity and Quality Assurance unit's 2017 inspection report related to staffing
shortages, trust in management, and hazardous waste management. The Office of Criminal
Enforcement, Forensics, and Training did not conduct a follow-up review to examine the
effectiveness of the implemented corrective actions. In 2020, as a result of an inspection by the State
of Colorado, NEIC was cited for several hazardous waste violations. Further, NEIC's 2019 Federal
Employee Viewpoint Survey results are 22 percent lower than the EPA's averages for questions
related to management and work environment.

NEIC has been challenged by high attrition rates among staff and the inability to backfill vacant
positions since 2016. If staffing levels continue to fall, NEIC risks a reduction in analytical capabilities
and the ability to accomplish its mission.

Responsible office

Office of Enforcement and Compliance Assurance

Recommendation
open three years
or more

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.

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

Planned

completion date

Recommendation 9:

•	Upon issuance: Unresolved

•	Revised: June 28, 2024 (more than three years after report issuance)

Recommendation 10:

•	Upon issuance: Unresolved

•	Revised: June 28, 2024 (more than three years after report issuance)

Report impact
statement

Safety, health, and attrition issues may compromise NEIC's ability to support the EPA's civil and
criminal enforcement efforts.

23-N-0025

37


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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 (1 recommendation)

Report number

21-P-0114

Date issued

March 29, 2021

Summary of
findings

The EPA did not consistently verify the continued protection of human health and the environment at
TSDFs with RCRA units that were closed with hazardous waste in place. Specifically, almost half
(339 of 687, or 49.3 percent) of TSDFs with RCRA units closed with waste in place were not
inspected at the frequency set by EPA policy.

EPA regional oversight of TSDF inspections by authorized states is also inconsistent. Five of the
ten EPA regions incorporate inspection commitments in their annual state RCRA grant negotiations
to verify that their authorized states are complying with the inspection policy. Two regions have
similar processes in place, but their processes do not include all their states, and three regions do
not have any process in place to verify compliance. Because of the lack of inspections, a hazardous
waste leak from a compromised unit could go undetected for years, with dire human health and
environmental consequences. For example, a leak that is not expeditiously detected could
contaminate groundwater, resulting in a loss of drinking water supply, high cleanup costs, and
human exposure to contaminants.

During our analysis of units closed with waste in place, we observed some issues with interactions
between the RCRA and Superfund programs. EPA oversight of RCRA units referred to the
Superfund program and those deferred back to the RCRA program is incomplete. The lack of
procedures and the use of differing facility identification numbers in the two programs have hindered
the EPA's tracking of facilities transferred between the two programs. As a result, it is uncertain
whether either program is appropriately managing RCRA units and protecting human and
environmental health.

Fifty-six RCRA Corrective Action facilities that were closed with waste in place are also managed by
the Superfund program. Ineffective EPA oversight of these sites resulted in 42 possible conflicting
and 126 double-counted accomplishment milestones. Because these milestones are used to
communicate site status to the public, communities could be confused or misled as to the cleanup
status of the sites.

Responsible office

Office of Enforcement and Compliance Assurance

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 2:

•	Upon issuance: Unresolved

•	Revised: March 29, 2024 (three years after report issuance)

Report impact
statement

The EPA's inspection frequency of TSDFs with RCRA units closed with waste in place does not
meet the EPA's statutory requirement or policy.

23-N-0025

38


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Improved Review Processes Could Advance EPA Regions 3 and 5 Oversight of State-Issued
National Pollutant Discharge Elimination System Permits (1 recommendation)

Report number

21-P-0122

Date issued

April 21, 2021

Summary of
findings

In Regions 3 and 5, the EPA did not follow all relevant CWA and NPDES regulations and guidelines
while reviewing permits.

Region 3 did not adequately perform its oversight responsibilities to ensure that NPDES permits
issued by the State of West Virginia meet CWA and NPDES regulatory requirements. Specifically,
West Virginia reissued 286 NPDES mining permits to reflect revisions made to its water-quality
regulations in 2015, but it is unclear whether Region 3 took steps to verify that the CWA's
anti-backsliding provisions were met. In addition, Region 3 experienced permit review delays, and
states within the region issued permits without addressing the EPA's comments.

Region 5 did not address all CWA and NPDES regulations during its review of a draft NPDES permit
for a mine and processing facilities to be built by PolyMet Mining Inc. along the St. Louis River in
northeastern Minnesota. Despite its concerns about the NPDES permit, Region 5 did not provide
written comments to Minnesota, contrary to the region's standard operating procedures and per
common EPA practice. In addition, Region 5 repeatedly declined to make a formal determination
under CWA § 401 (a)(2) regarding whether discharges from the PolyMet NorthMet project may
impact the quality of waters within the jurisdiction of the Fond du Lac Band of Lake Superior
Chippewa, whose tribal lands are 125 miles downstream from the site of the PolyMet NorthMet
project. The tribe was, therefore, unable to avail itself of the NPDES permit objection process set forth
in CWA §401 (a)(2).

Responsible office

Region 3

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 2:

•	Upon issuance: Unresolved

•	Revised: December 31, 2022, and January 31, 2025 (more than three years after
report issuance)

Report impact
statement

Improved EPA oversight could ensure that state NPDES programs are protecting human health and
the environment.

23-N-0025

39


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Improved EPA Oversight of Funding Recipients' Title VI Programs Could
Prevent Discrimination (3 recommendations)

Report number

20-E-0333

Date issued

September 28, 2020

Summary of
findings

The External Civil Rights Compliance Office has not fully implemented an oversight system to
provide reasonable assurance that organizations receiving EPA funding are properly implementing
Title VI. As an initial matter, the office does not conduct proactive compliance reviews to determine
funding recipients' compliance with Title VI. Instead, only once an investigation has been lodged will
the office review the foundational elements of the recipient's nondiscrimination program using a
checklist. This checklist documents the existence of a nondiscrimination program but does not
necessarily document the successful implementation of Title VI. We used the checklist to conduct a
limited review of the nondiscrimination programs in all 50 states and three territories. We found that
81 percent lacked some of the required foundational elements on their websites. Meanwhile, the
External Civil Rights Compliance Office does not systematically collect program data from EPA
funding recipients, and state personnel told us they need training and guidance to help them address
discrimination complaints related to permits and cumulative impacts. Three of the seven states we
interviewed indicated that they had not received training from the office.

Since the External Civil Rights Compliance Office assumed management of the EPA's Title VI
program in December 2016, it has focused its efforts on reducing a significant backlog of
discrimination complaints while simultaneously developing policy and guidance documents. It
resolved a backlog of 61 cases from fiscal year 2017 through 2019. Improved oversight could
prevent future case backlogs at the EPA and help ensure funding recipients comply with Title VI.

Responsible office

Office of General Counsel

Recommendation
open three years
or more

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.

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.

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.

Planned

completion date

Recommendation 1:

•	Upon issuance: Unresolved

•	Revised: September 30, 2022, and September 30, 2023 (more than three years after
report issuance)

Recommendation 5:

•	Upon issuance: Unresolved

•	Revised: March 31, 2023, and September 30, 2023 (more than three years after report
issuance)

Recommendation 6:

•	Upon issuance: Unresolved

•	Revised: March 31, 2022, and September 30, 2023 (more than three years after report
issuance)

Report impact
statement

Despite elimination of the case backlog, additional improvements in the EPA's oversight of Title VI
funding recipients could prevent discrimination.

23-N-0025

40


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EPA's Processing Times for New Source Air Permits in Indian Country Have Improved, but
Many Still Exceed Regulatory Time Frames (2 recommendations)

Report number

20-P-0146

Date issued

April 22, 2020

Summary of
findings

Of the tribal minor-source New-Source-Review permits that the EPA issued between 2011 and
August to October 2018, 62 percent exceeded the applicable regulatory time frame. In addition, more
than half of the permits still in process exceeded the applicable time frame. However, since 2011, the
average number of days it has taken the EPA to issue two types of minor-source permits has
declined. Further, the EPA processed permits for the construction of new facilities faster than it
processed permits for existing facilities. Processing permits for new facility construction is more
critical since delays could have negative economic impacts on industry and tribal communities.

The main causes of permitting delays included time-consuming back-and-forth communication
between the applicant and the EPA during the application process, as well as competing and limited
resources. In April 2018, staff and managers from EPA headquarters and regions met to identify
ways to make the New-Source-Review permitting process more efficient, but as of the date we
issued our report, they had not implemented all the recommendations from that meeting. The EPA
began tracking processing times in the summer of 2018.

In addition, not all EPA regions were accurately documenting the date that applications were
deemed complete, which is the basis for computing processing time frames. Without accurate
application completion dates, the Agency cannot accurately assess the timeliness of permitting
actions. We also found that the EPA does not have a systematic approach to identify non-filers,
which are facilities on tribal lands that need a New-Source-Review permit but have not applied for
one.

Responsible office

Office of Air and Radiation

Recommendation
open three years
or more

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.

2.	Establish and implement an oversight process to verify that the regions update the tribal-New-
Source-Review permit tracking system on a periodic basis with the correct and required
information.

Planned

completion date

Recommendation 1:

•	Upon issuance: September 30, 2021

•	Revised: September 30, 2022, and September 30, 2023 (more than three years after
report issuance)

Recommendation 2:

•	Upon issuance: March 31, 2022

•	Revised: September 30, 2022, and September 30, 2023 (more than three years after
report issuance)

Report impact
statement

Delays in processing tribal New-Source-Review permits could impact construction projects and
increase the risk that existing facilities awaiting a permit could be emitting more pollution than would
be allowed if they were operating under an approved permit.

23-N-0025

41


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Pesticide Registration Fee, Vulnerability Mitigation and Database Security Controls for EPA's
FIFRA and PRIA Systems Need Improvement (1 recommendation)

Report number

19-P-0195

Date issued

June 21, 2019

Summary of
findings

The EPA has adequate controls over the posting of FIFRA and PRIA financial transactions in the
Agency's accounting system, Compass Financials. However, the EPA's FIFRA and PRIA systems
have internal control deficiencies relating to the fee registration process, system vulnerability
mitigation, and database security. We tested controls in these areas to verify their compliance with
federal standards and guidance, as well as with EPA policies and procedures. We noted the
following conditions:

•	There were inconsistencies and errors related to transactions in the FIFRA and PRIA fee
data posted between the Office of Pesticide Programs' pesticide registration system and
Compass Financials.

•	Twenty of the 29 high-level vulnerabilities identified by the Agency in 2015 and 2016
remained uncorrected after the allotted remediation time frame. In addition, we tested ten of
the 20 uncorrected vulnerabilities and found that required plans of action and milestones for
remediation were not created for any of them.

•	The Office of Pesticide Programs needs to improve the security for one of the FIFRA and
PRIA databases, including password controls, timely installation of security updates, and
restriction of administrative privileges.

Responsible office

Office of Chemical Safety and Pollution Prevention

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 2

•	Upon issuance: December 31, 2020

•	Revised: December 31, 2022, June 30, 2023, and January 31, 2024 (more than four years
after report issuance)

Report impact
statement

Proper vulnerability testing, fee registration, and database controls are essential to the security of the
EPA's FIFRA and PRIA systems.

23-N-0025

42


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EPA Needs an Agencywide Strategic Action Plan to Address Harmful Algal Blooms
(1 recommendation)

Report number

21-E-0264

Date issued

September 29, 2021

Summary of
findings

The EPA does not have an agencywide strategy for addressing harmful algal blooms, despite
Congress appointing the EPA administrator as the leader for federal actions focused on reducing,
mitigating, and controlling freshwater harmful algal blooms. Federal guidance instructs agencies to
establish systems, such as developing strategic plans, that will promote effective government
programs. By developing an agencywide harmful-algal-bloom strategy, the EPA can improve in four
strategic planning areas: (1) purpose, scope, and methodology; (2) problem definition and risk
assessment; (3) organizational roles, responsibilities, and coordination; and (4) integration and
implementation. By creating an agencywide strategy that addresses these planning areas, the EPA
can reduce harmful algal blooms and their impacts on human health and the environment using the
authorities and tools provided by the Clean Water and Safe Drinking Water Acts.

We also found that the EPA has not fulfilled its 2015 commitment to Congress to develop additional
drinking water health advisories for cyanotoxins associated with some blooms as information
became available. In addition, the EPA needs to take further action to develop revised nitrogen and
phosphorus numeric water quality criteria recommendations for states to adopt to better control
levels of these nutrients in water bodies.

Responsible office

Office of Water

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 4:

•	Upon issuance: December 31, 2022

•	Revised: December 31, 2025 (more than four years after report issuance)

Report impact
statement

Scientists predict that harmful algal bloom occurrences in recreational waters and drinking water
sources will increase as excess nutrients continue to flow into water bodies, temperatures warm, and
extreme weather events occur due to climate change.

23-N-0025

43


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EPA's Endocrine Disruptor Screening Program Has Made Limited Progress in
Assessing Pesticides (4 recommendations)

Report number

21-E-0186

Date issued

July 28, 2021

Summary of
findings

Twenty-four years after the Food Quality Protection Act of 1996 amendments were passed, the
Office of Chemical Safety and Pollution Prevention has not implemented section 408(p)(3)(A) of the
Federal Food, Drug, and Cosmetic Act to test all pesticide chemicals for endocrine-disruption
activity. In addition, the Office of Chemical Safety and Pollution Prevention's Office of Pesticide
Programs recommended in 2015 that 17 pesticides needed additional testing for endocrine
disruption in wildlife in order to provide the data needed to conduct an ecological risk assessment.
However, that recommendation has not been implemented. EDSP testing delays are inconsistent
with the Federal Food, Drug, and Cosmetic Act, which directs the EPA to take appropriate action to
protect public health if a substance is found to influence the human endocrine system.

We also found that the EPA does not have controls in place to effectively implement the EDSP, such
as strategic guidance documents or performance measures. Additionally, the EDSP has not
conducted annual internal program reviews to monitor or assess progress in fulfilling regulatory
requirements. The EDSP has also not effectively communicated with internal and external
stakeholders. Moreover, previous Office of Chemical Safety and Pollution Prevention leadership
provided acceptable corrective actions to meet the recommendations in a 2011 OIG report regarding
the EDSP. However, they failed to implement those corrective actions beyond an initial period of
compliance with them. Lastly, some EPA staff indicated that they were instructed to function as if the
EDSP was eliminated from the EPA's budget.

Because the EDSP has not had effective internal controls in place since 2015, it cannot have
reasonable assurance that the program will accomplish its objectives and its resources will be
allocated efficiently and effectively. Moreover, an established system of management controls would
provide mechanisms for consistent program operations.

Responsible office

Office of Chemical Safety and Pollution Prevention

Recommendation
open three years
or more

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.

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.

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.

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.

Planned

completion date

Recommendation 1:

•	Upon issuance: September 30, 2025 (more than four years after report issuance)

Recommendation 2:

•	Upon issuance: September 30, 2024 (more than three years after report issuance)

Recommendation 3:

•	Upon issuance: September 30, 2024 (more than three years after report issuance)

Recommendation 6:

•	Upon issuance: October 1, 2024 (more than three years after report issuance)

Report impact
statement

Without the required testing and an effective system of internal controls, the EPA cannot make
measurable progress toward complying with statutory requirements or safeguarding human health
and the environment against risks from endocrine-disrupting chemicals.

23-N-0025

44


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EPA Deviated from Typical Procedures in Its 2018 Dicamba Pesticide Registration Decision
(1 recommendation)

Report number

21-E-0146

Date issued

May 24, 2021

Summary of
findings

The EPA's Scientific Integrity Policy affirms that the Agency's ability to pursue its mission to protect
human health and the environment depends upon the integrity of the science on which the EPA
relies. Per the policy, the EPA's scientists and managers are expected 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. Additionally, federal
and EPA requirements include documenting the formulation and execution of policies and decisions.
For pesticide registration decisions, the Office of Chemical Safety and Pollution Prevention's Office
of Pesticide Programs must review registrations and document its decisions.

We found that the EPA's 2018 decision to extend registrations for three dicamba pesticide products
varied from typical operating procedures. Namely, the EPA did not conduct the required internal peer
reviews of scientific documents created to support the dicamba decision. While division-level
management review is part of the typical operating procedure, interviewees said that senior leaders
in the Office of Chemical Safety and Pollution Prevention's immediate office were more involved in
the dicamba decision than in other pesticide registration decisions. This led to senior-level changes
to or omissions from scientific documents. For instance, these documents excluded some
conclusions initially assessed by staff scientists to address stakeholder risks. We also found that
staff felt constrained or muted in sharing their concerns on the dicamba registrations. The EPA's
actions on the dicamba registrations left the decision legally vulnerable, resulting in the Ninth Circuit
Court of Appeals vacating the 2018 registrations for violating FIFRA by substantially understating
some risks and failing to acknowledge others entirely.

Responsible office

Office of Chemical Safety and Pollution Prevention

Recommendation
open three years
or more

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.

Note: This recommendation requires the Office of Chemical Safety and Pollution Prevention to
conduct and document annual training once a year for five years. The office completed the first year
of the corrective action on February 16, 2022. That was the date that the office held its first annual
training series on its commitment to the Scientific Integrity Policy and principles and to promote a
culture of scientific integrity. The office has completed annual trainings for 2022 and 2023 on time
and plans to host annual trainings until 2026 to implement this recommendation.

Planned

completion date

Recommendation 3:

•	Upon issuance: March 31, 2022

•	Revised: March 31, 2026 (more than four years after report issuance)

Report impact
statement

The EPA needs to document and follow established procedures to ensure scientifically sound
decisions regarding pesticides. The EPA's actions on the dicamba registrations left the decision
legally vulnerable, resulting in the Ninth Circuit Court of Appeals vacating the 2018 registrations for
violating FIFRA by substantially understating some risks and failing to acknowledge others entirely.

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Further Efforts Needed to Uphold Scientific Integrity Policy at EPA (3 recommendations)

Report number

20-P-0173

Date issued

May 20, 2020

Summary of
findings

The results of our 2018 agencywide survey on scientific integrity—which received 4,320 responses,
a 23.5 percent response rate—showed that 3,987 respondents were aware of or had some familiarity
with the Scientific Integrity Policy. Among those respondents with a basis to judge, the majority
(56 percent; 1,025 of 1,842) were satisfied with the overall implementation of the EPA's Scientific
integrity Policy. The survey also revealed some concerns with specific aspects of scientific integrity
at the EPA, including dissatisfaction with the EPA's culture of scientific integrity (59 percent; 1,425 of
2,402) and the release of scientific information to the public (57 percent; 1,049 of 1,842).

While our 2018 survey results provide only a snapshot in time, comparing them with the EPA's
2016 scientific integrity survey suggests areas that have improved and areas in need of
improvement. Our 2018 survey results demonstrate higher levels of awareness of the Scientific
Integrity Policy and how to report a potential scientific integrity violation. However, our survey
revealed lower measures of perceived leadership support of scientific integrity and of satisfaction
with the review and clearance of scientific documents.

Also, while the Scientific Integrity Committee, including the scientific integrity official, have
implemented many policy requirements and identified actions to improve scientific integrity at the
EPA, we found that procedures to address potential violations were not finalized, mandatory training
was not tracked, annual reporting was not timely, and the release of scientific products was not
supported by a centralized clearance system. With improvements in these areas, the Scientific
Integrity Committee could more consistently implement the Scientific Integrity Policy across the EPA.

Responsible office

Office of Research and Development/Science Advisor

Recommendation
open three years
or more

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.

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

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.

Planned

completion date

Recommendation 6:

•	Upon issuance: June 30, 2022

•	Revised: June 30, 2024 (more than four years after report issuance)

Recommendation 7:

•	Upon issuance: September 30, 2020

•	Revised: April 30, 2022, June 30, 2022, March 31, 2023, and June 30, 2024 (more than
four years after report issuance)

Recommendation 8:

•	Upon issuance: June 30, 2021

•	Revised: June 30, 2022; March 31, 2023; and June 30, 2024 (more than four years after
report issuance)

Report impact
statement

Improving implementation of the Scientific Integrity Policy will enable the EPA to more effectively
carry out its mission to protect human health and the environment.

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Management Weaknesses Delayed Response to Flint Water Crisis (1 recommendation)

Report number

18-P-0221

Date issued

July 19, 2018

Summary of
findings

The circumstances and response to Flint's drinking water contamination involved implementation
and oversight lapses at the EPA; the State of Michigan; the Michigan Department of Environmental
Quality, or MDEQ; and the City of Flint. Since January 21, 2016, the EPA has overseen the
implementation of its emergency administrative order and amendment, issued in response to the
drinking water contamination. EPA Region 5 and EPA headquarters officials have worked with the
MDEQ and Flint personnel to help improve the city's water system. As of May 2018, the State of
Michigan and City of Flint have completed some actions and are working on remaining actions.

Michigan: Under the MDEQ's supervision, the Flint water system did not adhere to two Lead and
Copper Rule requirements: (1) develop and maintain an inventory of lead service lines needed for
sampling and (2) maintain corrosion-control treatment after the water source switch in April 2014.
The rule requires utilities to minimize consumers' exposure to lead in drinking water. As the primacy
agency, the MDEQ is responsible for enforcing this rule for Michigan water systems. The MDEQ did
not issue a notice of violation or take other formal enforcement action regarding either requirement
until August 2015. Instead, the MDEQ advised Flint public water system staff to conduct additional
tests and to delay corrosion-control treatment installation. The decision to delay corrosion-control
treatment prolonged residents' exposure to lead.

The EPA: The Agency retains oversight and enforcement authorities to provide assurance that
states with primacy comply with Safe Drinking Water Act requirements, such as those in the Lead
and Copper Rule. However, Region 5 did not implement management controls that could have
facilitated more informed and proactive decision-making when Flint and the MDEQ did not properly
implement the Lead and Copper Rule. While Flint residents were being exposed to lead in drinking
water, the federal response was delayed, in part, because the EPA did not establish clear roles and
responsibilities, risk-assessment procedures, effective communication, and proactive oversight tools.

Responsible office

Office of Enforcement and Compliance Assurance

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 8:

•	Upon issuance: July 7, 2021

•	Revised: April 28, 2023, and October 27, 2023 (more than five years after
report issuance)

Report impact
statement

The EPA should strengthen its oversight of state drinking water programs to improve the efficiency
and effectiveness of the Agency's response to drinking water contamination emergencies.

23-N-0025

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Brownfields Program-Income Monitoring Deficiencies Persist Because the EPA Did Not
Complete All Certified Corrective Actions (2 recommendations)

Report number

22-P-0033

Date issued

March 31, 2022

Summary of
findings

EPA Regions 1 and 10 effectively completed all corrective actions for their six recommendations in
OIG ReDort No. 17-P-0368. Of the 17 recommendations addressed to the Office of Land and
Emergency Management, the Office of Brownfields and Land Revitalization did not fully complete the
agreed-to corrective actions for five, despite certifying that those actions were completed, and
program-income monitoring deficiencies persist. Corrective actions for three of those five
recommendations were not completed because the Agency had not determined an appropriate level
of program income-tracking and oversight. Corrective actions for the two other recommendations
were not completed because the EPA's guidance did not include program income-tracking and post
closeout reporting. Office of Management and Budget and EPA policies require the Agency to take
corrective actions promptly.

As a result, the EPA continues to lack current, accurate, and complete data necessary for effective
post-closeout monitoring of program income. Without such data, the Office of Brownfields and Land
Revitalization is unable to determine whether an estimated $46.6 million of program income under
closed cooperative agreements was used timely and for the purposes authorized under the closeout
agreements as required by federal regulation or whether actions are needed to address
noncompliance with closeout agreement terms and conditions.

Responsible office

Office of Land and Emergency Management

Recommendation
open three years
or more

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.

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

Planned

completion date

Recommendation 1:

•	Upon issuance: Unresolved

•	Revised: September 30, 2027 (more than five years after report issuance)

Recommendation 5:

•	Upon issuance: Unresolved

•	Revised: September 30, 2027 (more than five years after report issuance)

Report impact
statement

The Office of Brownfields and Land Revitalization did not complete all certified corrective actions and
still lacks current and accurate information needed to monitor an estimated $46.6 million of
program income.

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EPA Effectively Screens Air Emissions Data from Continuous Monitoring Systems but Could
Enhance Verification of System Performance (1 recommendation)

Report number

19-P-0207

Date issued

June 27, 2019

Summary of
findings

The EPA's automated screening of facility-reported Continuous Emissions Monitoring System data
worked as intended and was effective in verifying the quality of the reported data. However, we
found a small number of inaccuracies and inconsistencies in the reported data. While these
instances had no impact on whether the data met quality assurance requirements, the inaccurate
data could have a negative impact on data users by providing inaccurate or misleading information.
The EPA can prevent these problems by adding specific screening checks to its existing reporting
software.

Although the EPA's automated screening process was effective, the validity of the reported data can
only be fully established when that process is supplemented with on-site field audits to verify that the
Continuous Emissions Monitoring System monitoring requirements were met. However, we found
that the EPA and state agencies conducted a limited number of these audits. Out of over
1,000 facilities subject to Acid Rain Program and/or Cross-State Air Pollution Rule requirements, the
EPA conducted field audits at only 16 facilities between 2016 and the end of June 2018. In addition,
nine of the ten state agencies we contacted were not conducting field audits. In response to our
work, the EPA initiated a process to develop a streamlined Continuous Emissions Monitoring System
field audit approach that state and local agencies can use when conducting other on-site visits at
facilities.

Responsible office

Office of Air and Radiation

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 1:

• Upon issuance: March 31, 2025 (more than five years after report issuance)

Report impact
statement

Data from the Continuous Emissions Monitoring System are used to determine whether sources,
such as power plants, comply with emissions limits designed to improve air quality and achieve
environmental and public health goals.

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EPA Needs a Comprehensive Vision and Strategy for Citizen Science that Aligns with Its
Strategic Objectives on Public Participation (1 recommendation)

Report number

18-P-0240

Date issued

September 5, 2018

Summary of
findings

Although citizen science is carried out throughout the EPA, the Agency has not developed controls
necessary to manage citizen science agencywide, including a clear vision and objectives for using
results. Absent this, the EPA cannot undertake a systematic effort to analyze the risks and
opportunities that citizen science presents.

EPA staff identified barriers to effectively using citizen science results—including lack of a
comprehensive vision and support or resources from senior management, and lack of understanding
and buy-in for citizen science—that exist because EPA leadership has not developed a strategy for
citizen science. Citizen science is evolving as advancements in technology provide greater access to
the public. Thus, as public involvement grows, it will place pressure on the EPA to understand and
determine how to use the data collected and provided to the Agency.

Responsible office

Deputy Administrator (within the Office of the Administrator)

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 2:

•	Upon issuance: December 31, 2020

•	Revised: March 31, 2023, and December 31, 2023 (more than five years after
report issuance)

Report impact
statement

Without uniform guidance and direction, the EPA will be unable to fully use citizen science data that
could contribute to the Agency's mission.

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50


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EPA Needs to Evaluate the Impact of the Revised Agricultural Worker Protection Standard on
Pesticide Exposure Incidents (1 recommendation)

Report number

18-P-0080

Date issued

February 15, 2018

Summary of
findings

The EPA had policies and procedures in place to implement the revised Agricultural WPS. Further,
the Agency provided training to regional staff, state inspectors, and program leads. However, we
found that management controls to implement the revised WPS were not fully adequate as of
January 2, 2017, when compliance with most of the revised rule was required.

Essential training and implementation materials were not available by January 2, 2017. In addition,
two key documents—the WPS Inspection Manual and the How to Comply manual—were not
available when the EPA conducted the majority of its training and outreach activities for states and
tribes in 2016. As a result, many state officials said they did not have the time, tools, or resources to
successfully implement the revised WPS by the January 2, 2017 compliance date. The EPA granted
a state agricultural association's petition to delay the compliance date until the necessary training
resources and educational materials were made available to state agencies responsible for
implementing the WPS. However, in a December 21, 2017, Federal Register notice, the EPA
rescinded its plan to delay compliance dates. The Agency announced that compliance dates in the
revised WPS published on November 2, 2015, remain in effect and that the Agency does not intend
to extend them. The EPA also announced plans to revise certain WPS requirements.

The EPA does not have the ability to collect agricultural pesticide exposure incident data to measure
the impact of the revised WPS rule among target populations. The Agency relies on information
assessed during pesticide reevaluations and from voluntary reporting databases. The EPA is
working on improving its Incident Data System, but the Agency stated that the improvements will not
enable the collection of additional occupational exposure data.

Responsible office

Office of Chemical Safety and Pollution Prevention

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 1:

•	Upon issuance: Unresolved

•	Revised: December 31, 2022, and December 31, 2023 (more than five years after
report issuance)

Report impact
statement

Over 2 million agricultural workers and pesticide handlers are protected by the WPS. Revisions to
the standard are intended to reduce exposure to pesticides and provide enhanced protection to
agricultural workers, pesticide handlers, and their families.

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51


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EPA Needs to Substantially Improve Oversight of Its Military Leave Processes to Prevent
Improper Payments (9 recommendations)

Report number

21-P-0042

Date issued

December 28, 2020

Summary of
findings

The EPA has not fully complied with federal laws related to military leave, reservist differential, and
military offset. This occurred because Agency management did not establish effective internal
controls to implement these laws. The EPA instead relied on reservists, their supervisors, and the
Agency's federal payroll provider to comply with federal requirements.

The U.S. Government Accountability Office's Standards for Internal Control in the Federal
Government and the Office of Management and Budget's Circular No. A-123 state that management
is responsible for complying with applicable federal laws and regulations, as well as for designing,
implementing, and monitoring internal controls to achieve its objectives. When effective and
systematic internal controls are in place, compliance with laws and regulations becomes more likely.

EPA management's lack of internal controls to effectively implement federal laws resulted in potential
overpayments or underpayments to EPA reservists. Based on the transactions we reviewed, the
Agency had a 75 percent error rate for 36 of 48 reservists tested for compliance with military leave
requirements. These errors resulted in about $129,000 in potential improper payments.

Responsible office

Office of Mission Support and Office of the Chief Financial Officer

Recommendation
open three years
or more

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

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

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.

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.

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.

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.

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.

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.

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.

23-N-0025

52


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Planned

completion date

Recommendations 1 and 2:

•	Upon issuance: April 30, 2022

•	Revised: July 29, 2022; October 1, 2022; and June 30, 2025 (more than four years after
report issuance)

Recommendation 3:

•	Upon issuance: June 30, 2022

•	Revised: July 29, 2022, and June 3, 2027 (more than six years after report issuance)

Recommendation 4:

•	Upon issuance: September 30, 2021

•	Revised: March 31, 2022; July 29, 2022; and September 3, 2026 (more than five years
after report issuance)

Recommendations 5 and 6:

•	Upon issuance: August 31, 2021

•	Revised: December 15, 2021; December 30, 2022; and August 31, 2026 (more than five
years after report issuance)

Recommendation 7:

•	Upon issuance: February 28, 2022

•	Revised: September 30, 2022, and December 31, 2026 (more than six years after
report issuance)

Recommendation 8:

•	Upon issuance: February 28, 2022

•	Revised: December 30, 2022, and February 28, 2027 (more than six years after
report issuance)

Recommendation 9:

•	Upon issuance: December 1, 2021

•	Revised: December 1, 2022, and December 1, 2024 (more than three years after
report issuance)

Report impact
statement

The EPA paid 124 reservists about $1.4 million in military leave pay from January 2017 through
June 2019. We identified potential improper payments of $129,000 related to 104 of the 1,628
payroll transactions that we audited.

23-N-0025

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Improved Management of the Brownfields Revolving Loan Fund Program Is Required to
Maximize Cleanups (1 recommendation)

Report number

17-P-0368

Date issued

August 23, 2017

Summary of
findings

Approximately $10.9 million available to clean up brownfields is not being used as intended.
Contaminated brownfield properties are not being cleaned up and redeveloped for ten of the
20 closed Brownfields Revolving Loan Fund cooperative agreements reviewed. The recipients of the
cooperative agreements have not re-loaned or spent program income collected after the closeout
agreement was signed.

The U.S. Environmental Protection Agency's (EPA's) 2008 Revolving Loan Fund Grant Program
Administrative Manual states the following: "EPA regions should encourage the recipient to maximize
the amount of money loaned out for cleanup purposes at all times. RLF funds should not remain
idle."

We found confusion among EPA regions and Revolving Loan Fund recipients and dissimilarities in
terms and conditions, leading to inconsistencies in program application. Program income was not
maximized by depositing funds into an interest-bearing account, and sources of program income
were excluded from the terms and conditions of cooperative agreements and closeout agreements.
Another source of confusion was knowing when post-closeout program income was used, and when
a closeout agreement can be terminated. These issues resulted in inconsistencies that could
potentially affect the long-term sustainability of the Brownfields Revolving Loan Fund Program.
We also found that the EPA's Office of Brownfields and Land Revitalization's data management
system did not meet federal standards. In addition, some regional project officers could not review
annual reports for Revolving Loan Fund recipients. We questioned over $2.7 million from three
recipients.

Responsible office

Office of Land and Emergency Management

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 14:

•	Upon issuance: March 19, 2019

•	Revised: December 31, 2023 (more than six years after report issuance)

Report impact
statement

For ten of the 20 closed Brownfields Revolving Loan Fund cooperative agreements reviewed,
approximately $10.9 million available to clean up brownfields is not being used as intended.

23-N-0025

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Enhanced Controls Needed to Prevent Further Abuse of Religious Compensatory Time
(1 recommendation)

Report number

16-P-0333

Date issued

September 27, 2016

Summary of
findings

Based on our analysis, time-and-attendance records support that the retired employee earned the
accumulated Religious Compensatory Time hours. However, we identified concerns with the EPA's
internal controls that allowed the excessive accumulation of Religious Compensatory hours by
Agency employees, and the Office of Chemical Safety and Pollution Prevention employee received a
payout of $32,469 for unused Religious Compensatory Time upon retirement.

EPA policy and procedures on accumulation and use of Religious Compensatory Time meet the
requirements of federal laws and regulations but are not specific enough to prevent abuse. The
Agency's controls do not enforce the requirement for employees to link the earning of Religious
Compensatory Time to specific religious observances. The EPA lacks detailed controls covering the
accumulation, use, and monitoring of Religious Compensatory Time, resulting in practices being
noncompliant with the intent of federal law and regulations and not being consistent with U.S. Office
of Personnel Management best practices.

Inadequate controls allowed several Agency employees to maintain significant positive Religious
Compensatory Time balances for extended periods of time without intended use plans. Also,
significant negative balances were retained without a plan to repay the hours. The Agency has not
provided staff with training or established adequate guidance to effectively manage and monitor
Religious Compensatory Time. As a result, in addition to the Office of Chemical Safety and Pollution
Prevention employee, the EPA paid 13 other employees $41,045 for unused Religious
Compensatory Time upon separation. Further, if no action is taken to reduce additional employees'
high balances, future payments totaling up to $81,927 could be made.

Responsible office

Office of Mission Support

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 3:

•	Upon issuance: May 30, 2017

•	Revised: June 23, 2023 (more than six years after report issuance)

Report impact
statement

Inadequate controls for Religious Compensatory Time resulted in payouts to employees of $73,514
and may result in additional payouts of up to $81,927.

23-N-0025

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Additional Measures Can Be Taken to Prevent Deaths and Serious Injuries from Residential
Fumigations (1 recommendation)

Report number

17-P-0053

Date issued

December 12, 2016

Summary of
findings

Since 2002, at least 11 deaths and two serious injuries occurred during residential fumigations in the
two U.S. states with the most fumigation treatments—California and Florida. Compliance with current
pesticide use requirements does not always prevent adverse impacts.

We identified multiple factors that contributed to these adverse impacts, including (1) no requirement
to secure tenting around structures undergoing fumigation, (2) ineffective devices used to detect
pesticide levels inside of structures, and (3) failure to attend mandatory training for residential
pesticide applicators who conduct fumigations.

In addition, we identified other program control risks that, if addressed, could reduce the risk of future
deaths and serious injuries:

•	The EPA could designate residential fumigation as a priority area for enforcement, with
special emphasis placed on locations such as Puerto Rico, which has a high demand for
residential fumigations but lacks information to effectively oversee such fumigations. Data
on sales and use of sulfuryl fluoride in Puerto Rico are not reported and are unknown.

•	The EPA could require site-specific residential fumigation management plans. Such plans
can prevent accidents, identify appropriate emergency procedures, and demonstrate
compliance with requirements.

•	The EPA could complete work to develop a comprehensive national pesticide incident
database to monitor residential fumigation risks. The EPA has an ongoing pesticide incident
database initiative to collect data, but there is no scheduled completion date.

Responsible office

Office of Chemical Safety and Pollution Prevention

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 3:

•	Upon issuance: November 30, 2017

•	Revised: August 31, 2021; December 31, 2022; June 30, 2023; and September 30, 2023
(more than six years after report issuance)

Report impact
statement

The EPA can better prevent deaths and serious injuries caused during residential fumigations by
amending sulfuryl fluoride labels and monitoring compliance.

23-N-0025

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EPA Should Conduct New Residual Risk and Technology Reviews for Chloroprene- and
Ethylene Oxide-Emitting Source Categories to Protect Human Health (3 recommendations)

Report number

21-P-0129

Date issued

May 6, 2021

Summary of
findings

Results from the EPA's modeling and monitoring efforts indicate that people in some areas of the
country may be exposed to unacceptable health risks from chloroprene and ethylene oxide
emissions. Despite the EPA classifying chloroprene as a likely human carcinogen in 2010 and
ethylene oxide as a carcinogen in 2016, the EPA has not conducted new RTRs for most types of
industrial sources, referred to as source categories, that emit chloroprene or ethylene oxide. The
EPA should take the following steps to ensure its RTR process sufficiently identifies and addresses
these emissions:

•	Conduct new residual risk reviews for four major-source categories that emit chloroprene or
ethylene oxide using new risk values for these pollutants.

•	Conduct a residual risk review for the hospital sterilizers area source category using the
new risk value for ethylene oxide.

•	Conduct overdue technology reviews for four source categories.

•	Develop new National Emission Standards for Hazardous Air Pollutants for chemical plant
area sources that emit ethylene oxide.

•	Develop a process to initiate timely reviews of existing and uncontrolled emission sources
when new or updated risk information becomes available.

New RTRs should be conducted because the EPA issued new risk values for chloroprene and
ethylene oxide in 2010 and 2016, respectively, to reflect their potent carcinogenicity, as found in
newer scientific evidence. The EPA should exercise its discretionary authority to conduct new
residual risk reviews under the Clean Air Act whenever new data or information indicates an air
pollutant is more toxic than previously determined. Use of such discretionary authority is consistent
with the Agency's position, stated in its April 2006 commercial sterilizer RTR rule.

Responsible office

Office of Air and Radiation

Recommendation
open three years
or more

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.

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.

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.

Planned

completion date

Recommendation 2:

•	Upon issuance: Unresolved

•	Revised: September 30, 2024 (more than three years after report issuance)

Recommendation 3:

•	Upon issuance: Unresolved

•	Revised: September 30, 2028 (more than seven years after report issuance)

Recommendation 4:

•	Upon issuance: September 30, 2024

•	Revised: None (more than three years after report issuance)

Report impact
statement

The EPA should conduct new RTRs for chloroprene- and ethylene oxide-emitting source categories
to address elevated individual lifetime cancer risks impacting over 464,000 people, as found in a
modeling tool, and to achieve environmental justice.

23-N-0025

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EPA Has Not Met Certain Statutory Requirements to Identify Environmental Impacts of
Renewable Fuel Standard (2 recommendations)

Report number

16-P-0275

Date issued

August 18, 2016

Summary of
findings

The EPA's Office of Research and Development has not complied with the requirement to provide a
report every three years to Congress on the impacts of biofuels. The EPA provided a report to
Congress in 2011 but has not provided subsequent reports as required.

In addition, the EPA's Office of Air and Radiation has not fulfilled the anti-backsliding requirements
for RFS, which are to analyze and address any negative air quality impacts of RFS. In 2010, the EPA
completed a comprehensive life cycle analysis to determine greenhouse gas reduction thresholds for
RFS. Although not required to do so, the EPA committed to update this analysis as life cycle science
evolves. However, it does not have a process for initiating an update.

The RFS reporting requirement provides for an objective analysis on the environmental impacts and
unintended consequences of U.S. biofuel policy. This analysis is important given conflicting scientific
opinions about biofuel impacts, potential impacts outside of the EPA's regulatory control, and
divergent RFS interests. The EPA does not have an assessment that meets the requirement to
identify whether RFS creates any impacts on air quality and, thus, take required measures to
mitigate impacts. This information is needed to fully inform the EPA, Congress, and other
stakeholders of the environmental impacts of U.S. biofuel policy. In June 2016, Congress held a
hearing on RFS implementation. Members expressed bipartisan interest in receiving more
information from the EPA on the environmental impacts. This would help assess whether the law's
original intent is being achieved and at what cost.

Responsible office

Office of Air and Radiation

Recommendation
open three years
or more

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.

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.

Planned

completion date

Recommendations 2 and 3:

•	Upon issuance: September 30, 2024 (more than eight years after report issuance)

•	Revised: None

Report impact
statement

The EPA, Congress, and other stakeholders lack key information on biofuel impacts needed to make
science-based decisions about the RFS.

23-N-0025

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EPA Has Not Met Statutory Requirements for Hazardous Waste Treatment, Storage and
Disposal Facility Inspections, but Inspection Rates Are High (1 recommendation)

Report number

16-P-0104

Date issued

March 11, 2016

Summary of
findings

Overall, the EPA had a high inspection completion rate of 91 percent (656 out of 718 TSDFs that we
reviewed). However, specific inspection completion rates varied for the three types of TSDFs:
94 percent for private TSDFs, 85 percent for federal TSDFs, and 54 percent for state or local TSDFs.
Although the EPA's overall inspection completion rate is high, the Agency did not fully meet the legal
requirement for inspecting 100 percent of operating TSDFs for fiscal year 2014. As noted above, the
inspection rate for state and local TSDFs is just over 50 percent.

We also found that the EPA recognizes state-conducted inspections of federal TSDFs as meeting
the federal inspection requirement. Because this practice was inconsistent with the EPA's
documented compliance monitoring strategy, the Agency updated its strategy in September 2015 to
allow this practice.

Inspections deter and monitor for noncompliance. TSDF inspections can identify and reduce
potential risks to human health and the environment resulting from operations that treat, store, and
dispose of hazardous waste. TSDF inspections have identified violations, such as storage of
hazardous waste in an unpermitted area and failure to minimize the possibility of the release of
hazardous waste.

The Office of Enforcement and Compliance Assurance acknowledged that the Agency is not meeting
the inspections requirement due to resource limitations from other competing priorities, such as
inspector training or state oversight activities. The Office of Enforcement and Compliance Assurance
was unable to provide an estimate of the additional resources it would need to meet TSDF inspection
requirements.

Responsible office

Office of Enforcement and Compliance Assurance

Recommendation
open three years
or more

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

Planned

completion date

Recommendation 1:

•	Upon issuance: March 19, 2019

•	Revised: March 29, 2024 (more than eight years after report issuance)

Report impact
statement

Missed TSDF inspections violate the RCRA legal requirement and can increase the risk of exposure
to hazardous substances.

23-N-0025

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Internal Controls Needed to Control Costs of Emergency and Rapid Response Services
Contracts, as Exemplified in Region 6 (1 recommendation)

Report number

14-P-0109

Date issued

February 4, 2014

Summary of
findings

Region 6 manages field activities under the Emergency and Rapid Response Services contracts
within the terms of the contract. However, our review of task order files and invoices submitted under
those task orders showed that infrequent internal control reviews and inadequate staffing levels
hamper Region 6's ability to prevent and detect many contract management shortcomings, such as:

•	Performing required annual invoice reviews.

•	Monitoring contractor adjustment vouchers.

•	Receiving prime contractor negotiated team subcontract agreements on time.

•	Correctly coding task orders in the EPA Acquisition System.

•	Performing adequate internal control reviews.

Without adequate staffing levels, Region 6 is unable to conduct internal control reviews. Such
reviews are a tool for ensuring that products comply with regulations and are consistently of high
quality. Without internal control reviews, crucial aspects in the acquisition cycle cannot be assessed,
and management cannot determine and properly address weaknesses and vulnerabilities.
We identified two conditions that resulted in higher costs to the government. One prime contractor
was applying a general and administrative indirect rate to its team subcontractors' other direct costs,
which went against the prime contractor's proposal and indirect cost rate letter. Also, both prime
contractors were receiving additional profit because the fixed labor rates negotiated between the
EPA and the Emergency and Rapid Response Services prime contractors were based solely on the
prime's labor rates.

Responsible office

Region 6

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 3:

•	Upon issuance: Unresolved

•	Revised: September 30, 2024 (more than ten years after report issuance)

Report impact
statement

Improper application of general and administrative rates resulted in higher costs to the government.

23-N-0025

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EPA's Endocrine Disruptor Screening Program Should Establish Management Controls to
Ensure More Timely Results (3 recommendations)

Report number

11-P-0215

Date issued

May 3, 2011

Summary of
findings

Fourteen years after passage of the Food Quality Protection Act of 1996 and Safe Drinking Water
Act amendments, the EPA's EDSP has not determined whether any chemical is a potential
endocrine disruptor. The EDSP has not developed a management plan laying out its goals and
priorities, nor has it established outcome performance measures to track program results. The EDSP
missed milestones for assay validation and chemical selection established by the 2001 Natural
Resources Defense Council settlement agreement. Completed activities exceeded their targets by
about 4.5 to 6 years. An EDSP manager told us that the EDSP was unaware of the complexities,
resources, and time needed to validate assays until years after the 2001 settlement agreement was
signed. However, the EDSP did not substantially revise its milestones for completing assay
validation in its status reports to the Natural Resources Defense Council. For example, nine of 11
updates that the EPA provided to the Natural Resources Defense Council for the estrogen receptor
binding assay incrementally adjusted the milestones, collectively, by a total of 4.5 years. Concerned
about program progress, in 2007, Congress instituted reporting requirements and, in 2009, specified
deadlines for certain EDSP activities. As a result, the EPA recently published two EDSP documents
for public comment.

We acknowledge the difficulties involved in establishing an effective endocrine disruptor screening
and testing program. However, in addition to lacking a management plan and outcome measures,
the EDSP has not created a final statement of policy, finalized specific procedures to evaluate Tier 1
screening results, or established specific procedures to evaluate Tier 2 testing results. The EDSP
needs to develop and implement plans and performance measures to establish management control
and accountability. The EDSP had planned to develop a management plan for the program but had
not done so at the time of our audit.

Responsible office

Office of Chemical Safety and Pollution Prevention

Recommendation
open three years
or more

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.

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.

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

Planned

completion date

Recommendation 4:

•	Upon issuance: September 23, 2013

•	Revised: October 1, 2024 (more than 13 years after report issuance)

Recommendation 5:

•	Upon issuance: September 23, 2013

•	Revised: December 31, 2022, and June 30, 2023 (more than 12 years after report
issuance)

Recommendation 6:

•	Upon issuance: September 23, 2013

•	Revised: June 30, 2023 (more than 12 years after report issuance)

Report impact
statement

The EDSP will not be able to establish an effective screening-and-testing program without
establishing program control and accountability. As a result, achieving the goal of protecting human
health and the environment from endocrine disruptors will continue to be delayed.

23-N-0025

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EPA Should Revise Outdated or Inconsistent EPA-State Clean Water Act Memoranda
of Agreement (1 recommendation)

Report number

10-P-0224

Date issued

September 14, 2010

Summary of
findings

NPDES memorandums of agreement between the EPA and states do not ensure that the Agency
has management control and effective oversight over a national program administered by states.
EPA headquarters does not hold EPA regional or state offices accountable for updating their
memorandums of agreement when necessary and relies on other planning and management
mechanisms to exercise control over state programs. However, memorandums of agreement are
critical because they are the common denominator for state-authorized programs and should
represent a common baseline. Memorandums of agreement that are outdated or that are not
adhered to reduce the EPA's ability to maintain a uniform program across states that meets the
goals of CWA sections 101 and 402. An effective national program must maintain consistent
management control and oversight of state programs.

Responsible office

Office of Water

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 2-2:

•	Upon issuance: September 28, 2018

•	Revised: September 30, 2020; September 30, 2022; and September 30, 2023 (more than
13 years after report issuance)

Report impact
statement

The current state of the memorandums of agreement means that the EPA cannot confirm it has
effective management control over state programs, which would assure the public that Clean Water
Act objectives are being achieved.

Making Better Use of String fellow Superfund Special Accounts (1 recommendation)

Report number

08-P-0196

Date issued

July 9, 2008

Summary of
findings

The Stringfellow special accounts had a balance of approximately $117.8 million as of June 11,
2008. The $70 million remaining in the accounts are to cover potential EPA cleanup costs if the
responsible party—that is, California—is unable to pay. That leaves up to $47.8 million that can be
transferred to the EPA Hazardous Substance Superfund Trust Fund.

Responsible office

Region 9

Recommendation
open three years
or more

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.

Planned

completion date

Recommendation 2:

•	Upon Issuance: December 31, 2012

•	Revised: September 30, 2023, and September 30, 2026 (more than 18 years after report
issuance)

Report impact
statement

The EPA could reallocate some portion of its other Trust Fund dollars to other priority sites or needs.
Alternatively, if funds are transferred to the Trust Fund, there are numerous Superfund requirements
and priorities elsewhere in the United States that could be addressed by putting the approximately
$27.8 million of idle funds to better use.

23-N-0025

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Whistleblower Protection

U.S. Environmental Protection Agency

The whistleblower protection coordinator's role
is to educate Agency employees about
prohibitions on retaliation and employees' rights
and remedies in cases of reprisal. For more
information, please visit the whistleblower
protection coordinator webpaqe.

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