^7

U.S. Environ
OFFICE OF

L PLAN

YEAR 2015

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about the EPA OIG.


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The Office of Inspector General Annual Plan is produced by the Office of Inspector General with
input from the U.S. Environmental Protection Agency Administrator, Deputy Administrator,
Assistant Administrators and Regional Administrators, as well as congressional stakeholders
and the Office of Management and Budget.

This plan is available in hard copy from:

Office of Inspector General

U.S. Environmental Protection Agency

MC 2491T

1200 Pennsylvania Avenue, NW
Washington, DC 20460

by calling (202) 566-2391

or via the Internet at: www.epa.gov/oig

Abbreviations

CSB	U.S. Chemical Safety and Hazard Investigation Board

EPA	U.S. Environmental Protection Agency

FY	Fiscal Year

OI	Office of Investigations

OIG	Office of Inspector General

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

EPA Inspector General Hotline

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

OIG Hotline@epa.gov

More information at www.epa.gov/oiq/hotline.html.

EPA, Office of Inspector General

1200 Pennsylvania Avenue, NW (241OT)
Washington, DC 20460
(202) 566-2391
www.epa.gov/oig

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Message from the Inspector General

I am pleased to present the U.S. Environmental Protection Agency
(EPA) Office of Inspector General (OIG) Annual Plan for fiscal year
(FY) 2015. This document describes how the OIG will achieve its
statutory mission of promoting economy, efficiency, effectiveness and
integrity relating to the programs and operations of the EPA and the
U.S. Chemical Safety and Hazard Investigation Board (CSB). This
plan reflects the priority work that the OIG believes is necessary to
keep the Administrator and Congress fully informed about problems
and deficiencies relating to the administration of agency programs and
operations.

This OIG Annual Plan identifies mandated and selected assignment
topics continuing from FY 2014 and scheduled to start during
FY 2015. Although this plan provides a framework for activities we
intend to carry out in FY 2015, the OIG is often required to perform unanticipated work based on
legislative mandates, congressional inquiries, hotline requests or governmentwide reviews.

Our plan is implemented through audits, evaluations, investigations and follow-up reviews in
compliance with the Inspector General Act, the appli cable professional standards of the
Comptroller General of the United States, and the Quality Standards for Federal Offices of
Inspector General of the Council of the Inspectors General on Integrity and Efficiency. Readers
are encouraged to consult our website, www.epa.gov/oig. for the most current listing of recently
issued reports relating to our implementation of the plan.

Primary sources of input for the assignments listed in this plan included risk assessments across
agency programs and operations based upon prior OIG work, U.S. Government Accountability
Office high-risk assessments, congressional interest, Office of Management and Budget
priorities, agency vulnerability/internal control assessments under Office of Management and
Budget Circular A-123 and the Federal Managers' Financial Integrity Act, and identification of
key agency challenges and strategic planning priorities. Our current planning also reflects direct
outreach and solicitation of topics and assignment suggestions from EPA's leadership and
external stakeholders (see Appendix B). Other assignments are required or are self-initiated
based upon our strategic themes, which are focused on providing the greatest value and risk
reduction to the agency and the greatest benefit to public health.

We want to thank each member of the agency leadership, as well as external stakeholders and
our staff, for their direct participation in this process. We look forward to continuing an open
dialogue for receiving their ideas, suggestions and feedback. We welcome input into our
planning process and feedback on the quality and value of OIG products and services from all
customers, clients, stakeholders and the public via webcomments.oig@epa.gov.

Inspector General

Arthur A. Elkins Jr.


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Table of Contents

1 About the EPA Office of Inspector General

1	EPA Office of Inspector General

2	EPA's Mission

3	Matrix of Agency Goals and Strategies the OIG Plans to Address
With Audits and Evaluations

7	OIG's Strategic Plan Outline

8 Identifying the Risks

8	Top EPA Management Challenges—Reported by the OIG for FY 2014

9	EPA Internal Control Risks and Weaknesses Identified by the OIG for FY 2014

9	Risks, Priorities and Issues Identified by EPA Through OIG Stakeholder
Outreach Interviews

10 Annual Plan Strategy

10	Making Choices—A Customer-Driven Process

10 Criteria Considered in Identifying and Selecting Audit and Evaluation
Assignments for FY 2015

The Plan: Continuing and New Assignments for FY 2015

12 Office of Audit

13 Contracts and Assistance Agreement Audits

15	Efficiency Audits

16	Forensic Audits

17	Financial Audits

19 Information Resources Management Audits

20 Office of Program Evaluation

21	Air

23	Water

24	Land Cleanup and Waste Management

26	Toxics, Chemical Management and Pollution Prevention

27	Science, Research and Management Integrity

28	Special Program Reviews

29 Office of Investigations

31 OIG Assignments Planned for CSB

Appendices

33 Appendix A — Performance Measures and Targets

34 Appendix B — Risks, Priorities, and Issues Identified by OIG During EPA Outreach
Interviews With Agency Management


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About the EPA

Office of Inspector General

EPA Office of Inspector General

The Office of Inspector General (OIG) is an independent office of the
U.S. Environmental Protection Agency (EPA) that detects and prevents fraud, waste and
abuse to help the agency protect human health and the environment more efficiently and
cost effectively.

The EPA OIG was created and is governed by the Inspector General Act of 1978 as
amended (5 U.S.C. App. 3). The act established offices of Inspector General as
independent and objective units to:

1.	Conduct and supervise audits and investigations relating to the programs and
operations of their agencies.

2.	Review existing and proposed legislation and regulations relating to the programs
and operations of their agencies.

3.	Provide leadership and coordination, and recommend policies for activities
designed to promote economy, efficiency and effectiveness, and to prevent and
detect fraud and abuse.

4.	Provide a means for keeping the head of the establishment and Congress fully and
currently informed about problems and deficiencies, and the necessity for any
progress of corrective actions.

EPA OIG staff members are physically located at headquarters in Washington, D.C.;
at regional headquarters offices for all 10 EPA regions; and at other EPA locations
including Research Triangle Park, North Carolina, and Cincinnati, Ohio.

In fiscal year (FY) 2004, Congress designated the EPA Inspector General to also serve as
the Inspector General for the U.S. Chemical Safety and Hazard Investigation Board
(CSB).

1


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EPA's Mission

The EPA's mission is to protect human health and the environment. The OIG Strategic and
Annual Plans are specifically designed to connect implementation of the Inspector General
Act with the EPA's mission for the most economical, efficient and effective achievement of
the EPA's performance goals. In Appendix A, we provide more details about our FY 2015
annual performance measures and targets.

Our audits and evaluations are designed to take into account the EPA's strategic goals and
cross-agency fundamental strategies. Following is a table noting the goals and strategies and
then a matrix noting the goals and strategies each project in our plan is designed to address.

EPA's FY 2014-2018 Strategic Goals
and Cross-Agency Strategies

EPA's Strategic Goals

Addressing Climate Change and Improving Air Quality

Reduce greenhouse gas emissions and develop adaptation strategies to address climate change, and
protect and improve air quality.

Protecting America's Waters

Protect and restore waters to ensure that drinking water is safe and sustainably managed, and that aquatic
ecosystems sustain fish, plants, wildlife, and other biota, as well as economic, recreational, and subsistence
activities.

Cleaning Up Communities and Advancing Sustainable Development

Clean up communities, advance sustainable development, and protect disproportionately impacted
low-income and minority communities. Prevent releases of harmful substances and clean up and restore
contaminated areas.

Ensuring the Safety of Chemicals and Preventing Pollution

Reduce the risk and increase the safety of chemicals and prevent pollution at the source.

Protecting Human Health and the Environment by Enforcing Laws and Assuring Compliance

Protect human health and the environment through vigorous and targeted civil and criminal enforcement.
Use Next Generation Compliance strategies and tools to improve compliance with environmental laws.

EPA's Cross-Agency Fundamental Strategies

Working Toward a Sustainable Future

Working to Make a Visible Difference in Communities

Launching a New Era of State, Tribal, Local, and International Partnerships

Embracing EPA as a High-Performing Organization

2


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Matrix of Agency Goals and Strategies the OIG Plans to Address
With Audits and Evaluations

OIG Project

Climate
Change/

Air
Quality

Protecting
America's
Waters

Cleaning
Communities/
Sustainable
Development

Safe
Chemicals/
Preventing
Pollution

Enforcing

Laws/
Ensuring
Compliance

Working
Toward
Sustainable
Future

Making
Difference in
Communities

State, Tribal,
Local and
International
Partnerships

Embracing
EPA as High-
Performing
Organization

Contracts and



















Assistance Agreement Audits



















Charge Card Annual Report - Status of
Recommendations

















X

EPA Conferences: Maximizing
Cost Efficiencies

















X

EPA Use of Title 42 Hiring Authority









X

X





X

Grant Advanced Monitoring

















X

Hotline - Help Desk Charging

















X

Improper Payments - FY 2014

















X

Oversight of Clean Water State Revolving
Loan Funds



X











X



Periodic Assessment of Purchase Card

















X

and Convenience Check Program



















Pioneer Valley Commission





X





X

X

X



EPA's Simplified Acquisitions

















X

EPA's Working Capital Fund Background
Investigations Services

















X

OIG Purchase Card Transactions

















X

Special Appropriation Act Project Audit
Follow-up



X











X

X

Superfund Technical Assessment and





X



X

X

X



X

Response Team (START) IV awarded to
TetraTech Inc.



















Travel Card Review

















X

Efficiency Audits



















Controls for Travel of EPA Employees

















X

EPA Investments in Information

















X

Technology Products and Services



















EPA Transit Subsidy Program

X















X

EPA's Fleet Management





X







X



X

Management and Disposal of
Underutilized Personal Property Stored in





X







X



X

Warehouse Spaces



















Oversight of Guam, American Samoa,



X

X



X

X

X

X

X

Commonwealth of the Northern Mariana



















Islands and U.S. Virgin Islands



















Positioning EPA for the Digital Age:
Technological Changes Create
T ransformation Opportunities

X







X

X





X

Forensic Audits



















Brownfields Revolving Loan Fund





X







X





Assistance Agreement Audits



















Congressional Request - EPA's Process
Used to Determine and Track Employee

















X

Overtime Compensation



















Congressional Request - Timekeeping
Practices

















X

Construction Grants Awarded to the



X





X





X



District of Columbia Water and Sewer



















Authority



















FY 2015 Single Audit Program

X

X

X

X

X



X

X



Oregon Health Authority -
Labor Charging



X







X







Pegasus Technical Services Inc. Contract





X





X







Region 9 Request - Review of Selected
Tribes in Nevada





X



X





X



Region Request - Manchester Band of
Pomo Indians









X





X



3


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OIG Project

Climate
Change/

Air
Quality

Protecting
America's
Waters

Cleaning
Communities/
Sustainable
Development

Safe
Chemicals/
Preventing
Pollution

Enforcing

Laws/
Ensuring
Compliance

Working
Toward
Sustainable
Future

Making
Difference in
Communities

State, Tribal,
Local and
International
Partnerships

Embracing
EPA as High-
Performing
Organization

Financial Audits



















EPA's Accountable Property

















X

EPA's Accounts Receivable Internal

















X

Controls



















FY 2013 Financial Statements:







X











Pesticide Registration Fund



















FY 2013 Financial Statements: Pesticides







X











Reregistration and Expedited Processing
Fund



















FY 2014 EPA Financial Statements

















X

FY 2014 Financial Statements:









X







X

Hazardous Waste Electronic Manifest



















System Fund



















FY 2014 Financial Statements:







X











Pesticide Registration Fund



















FY 2014 Financial Statements: Pesticides







X











Reregistration and Expedited Processing
Fund



















FY 2015 EPA Financial Statements

















X

Oversight of Superfund State Contract for
Remedial Activities





X



X



X



X

Independent Government Cost Estimates
and Indirect Costs for EPA's Interagency

















X

Agreements



















Working Capital Fund Cost Rates

X

X

X

X

X







X

Information Resources Management
Audits



















EPA's Contractor Information Technology

















X

Systems



















EPA's Leasing of Computer Equipment

















X

EPA's System Development Activities for
the Hazardous Waste Electronic Manifest





X

X



X



X

X

System



















EPA's Use of Electronic Reporting to
Enhance Enforcement Activities









X







X

Data Quality Review of Self-Reported
Information in EPA's XACTA System

















X

Follow-Up on Significant Information
Technology Security Findings

















X

FY 2014 EPA Federal Information

















X

Security Management Act Audit



















FY 2015 EPA Federal Information

















X

Security Management Act Audit



















Status of Cloud-Computing Environments

















X

Within the Federal Government



















Air Evaluations



















Use of Remote Sensing Data to Assess





X













Contamination at Delisted Superfund
Sites - Phase 2



















Selected Ambient Air Quality Monitoring
Networks

X







X

X



X



Enforcement Decree Compliance for
Selected Clean Air Act Sources

X







X









EPA Efforts to Incorporate Environmental

X



X



X



X





Justice into Clean Air Act Inspections for
Air Toxics



















EPA Region 2 Oversight of the
Environmental Programs Operated by the
U.S. Virgin Islands (collaborative effort
with Water and Land Cleanup and Waste

X

X

X

X

X



X

X

X

Management product lines)



















Title V Annual Compliance Certifications

X













X



Implementation of Benzene Fuel Content
Standards

X

















4


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OIG Project

Climate
Change/

Air
Quality

Protecting
America's
Waters

Cleaning
Communities/
Sustainable
Development

Safe
Chemicals/
Preventing
Pollution

Enforcing

Laws/
Ensuring
Compliance

Working
Toward
Sustainable
Future

Making
Difference in
Communities

State, Tribal,
Local and
International
Partnerships

Embracing
EPA as High-
Performing
Organization

Assessment of EPA Efforts to Address









X



X





Workload Imbalances in its Clean Air Act



















Risk Management Program



















EPA Oversight of Enforcement Actions
for Selected Startup, Shutdown and
Malfunction Events

X







X



X





Effectiveness of Compliance Assurance
Activities for Major and Synthetic Minor
Clean Air Act Sources

X







X





X



Water Evaluations



















Safe Drinking Water in Small Drinking
Water Systems



X





X



X

X



Municipal Sewer and Stormwater



X





X





X

X

Systems: Consent Decree Progress and
Challenges



















EPA's Oversight of Hydraulic Fracturing



X



X











EPA Region 2 Oversight of the
Environmental Programs Operated by the
U.S. Virgin Islands (collaborative effort
with Air and Land Cleanup and Waste

X

X

X

X

X



X

X

X

Management product lines)



















Drinking Water State Revolving Fund



X











X



BEACH ACT: Review of the



X





X

X

X

X



Effectiveness of Identifying Contaminated



















Recreational Waters and Communicating
Health Risks



















EPA Programs to Protect the Public from
Mercury Contamination in Fish



X





X

X



X



EPA Programs to Protect Drinking Water
from Contamination Incidents



X











X

X

Clean Water State Revolving Fund



X







X

X





Green Project Reserve Program



















Land Cleanup and Waste Management
Evaluations



















EPA Oversight of the Import of
Hazardous Waste





X

X

X





X



Sitting Renewable Energy on Potentially
Contaminated Land and Mine Sites:





X













Environmental, Health and Financial



















Risks



















Environmental Risks from Resource





X

X







X



Conservation and Recovery Act
Hazardous Waste Post-Closure Landfills



















EPA Region 2 Oversight of the
Environmental Programs Operated by the
U.S. Virgin Islands (collaborative effort
with Air and Water product lines)

X

X

X

X

X



X

X

X

Optimization of Superfund-Financed
Pump and Treat Systems





X





X

X

X



EPA Progress on Meeting Resource
Conservation and Recovery Act Statutory
Mandate for Minimum Frequency of
Inspections at Hazardous Waste Disposal
Facilities





X



X

X

X

X



Confirmation of EPA Time-Critical





X







X





Removal Actions



















EPA Progress on Reducing Taxpayer
Environmental Liabilities





X



X

X

X



X

Long-Term Risks from Short-Term

X



X



X

X

X





Disposal of Debris from Natural Disasters



















5


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OIG Project

Climate
Change/

Air
Quality

Protecting
America's
Waters

Cleaning
Communities/
Sustainable
Development

Safe
Chemicals/
Preventing
Pollution

Enforcing

Laws/
Ensuring
Compliance

Working
Toward
Sustainable
Future

Making
Difference in
Communities

State, Tribal,
Local and
International
Partnerships

Embracing
EPA as High-
Performing
Organization

Toxics, Chemical Management and
Pollution Prevention Evaluations



















National Pesticide Information Center







X







X



Federal Insecticide, Fungicide and
Rodenticide Act Programs Enforcement



















Referrals



















Adequacy of EPA's Oversight of State
Federal Insecticide, Fungicide and
Rodenticide Act Programs







X

X





X



Pollution Prevention Grant Results and



X

X

X



X







Measures



















Office of Pesticide Program's Genetically
Engineered Corn Insect Resistance
Management







X

X

X







P2 Green Chemistry Challenge Program
Results







X



X







EPA Policies and Responsiveness to
Public Petitions on Pesticide Issues







X











EPA's Regional Negotiated Commitments
with States for Federal Insecticide,







X

X









Fungicide and Rodenticide Act



















Compliance Inspections



















Science, Research and



















Management Integrity Evaluations



















EPA's Assessment of Potential Mining



X





X

X

X

X



Impacts in Bristol Bay, Alaska



















Equipment Utilization Within the Office of

X

X

X

X









X

Research and Development



















Region 6 Coastal Wetlands

















X

Controls over Science to Achieve Results

















X

Grants for Research Misconduct



















Office of Research and Development's
Management of Reimbursable Funds for
Research











X





X

EPA's Use of Other Federal Agencies,

X

X

X

X



X





X

Universities and Foundations for



















Research



















2015 Management Challenges and
Internal Controls Weaknesses

X

X

X

X

X







X

Special Program Review Evaluations



















EPA's Progress Under Environmental

X

X

X

X

X









Justice Plan 2014



















Follow-Up Report - EPA Inaction in
Identifying Hazardous Waste
Pharmaceuticals May Result in Unsafe



X



X

X



X





Disposal



















Alternate Asbestos Control Method





X









X



Follow On



















EPA's Antimicrobial Testing Program







X



X





X

Fol low-Up Report - EPA Should Revise



X





X





X

X

Outdated or Inconsistent EPA-State



















Clean Water Act Memorandums of



















Agreement



















Fol low-Up Report - Improvements
Needed in EPA Training and Oversight
for Risk Management Program
Inspections

X

X

X

X

X



X



X

Workforce Restructuring Under Voluntary
Early Retirement Authority/Voluntary
Separation Incentive Payment

















X

Effectiveness of EPA's Environmental

X

X

X

X

X



X





Education Activities



















EPA's Classification of National Security

















X

Information (Second Evaluation)



















Totals

21

28

33

28

39

23

20

30

56

6


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OIG's Strategic Plan Outline

_

Vision

Be the best in public service and oversight for a better environment tomorrow.

Mission

Promote economy, efficiency, effectiveness, and prevent and detect fraud, waste, and abuse
through independent oversight of the programs and operations of the Environmental Protection
Agency and Chemical Safety and Hazard Investigation Board.

i!

Contribute to
improved human health,
safety and the
environment



Goals

e

Contribute to
improved EPA and CSB
business practices and
accountability





Be responsible
stewards of taxpayer
dollars



0

Be the best in public
service



w

Objectives

•	Influence programmatic and
systemic changes and
actions that contribute to
improved human health,
safety and environmental
quality

•	Add to and apply
knowledge that contributes
to reducing or eliminating
environmental and
infrastructure security risks
and challenges

•	Make recommendations to
improve EPA and CSB
programs

Influence actions that
improve operational
efficiency and
accountability, and achieve
monetary savings

Improve operational
integrity and reduce risk of
loss by detecting and
preventing fraud, waste,
abuse or breach of security

Identify best practices,
risks, weaknesses and
monetary benefits to make
recommendations for
operational improvements



w

' Promote and maintain an
accountable, results-
oriented culture

1 Ensure our products and
services are timely,
responsive, relevant, and
provide value to our
customers and
stakeholders

1 Align and apply our
resources to maximize
return on investment

1 Ensure our processes and
actions are cost effective
and transparent

1 Maintain the highest ethical
standards

1 Promote and maintain a
diverse workforce that is
valued, appreciated and
respected

1 Enhance constructive
relationships and foster
collaborative solutions

1 Provide leadership, training
and technology to develop
an innovative and
accomplished workforce



w

7


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Identifying the Risks

As required by the Reports Consolidation Act of 2000, the OIG reviewed the major risks,
challenges and planning priorities across the EPA and solicited first-hand input from agency
leadership to identify and select OIG products and topics that would be of greatest benefit to the
agency and the American public it serves. This section summarizes and applies the key FY 2014
agencywide risks, issues and management challenges that help guide the general direction and
focus of OIG audits, evaluations and investigative work.

Top EPA Management Challenges—Reported by the OIG for FY 2014

1.	Oversight of Delegations to States: Due to differences between state and federal policies,
interpretations, strategies and priorities, the EPA needs to more consistently and effectively
oversee its delegation of programs to the states, assuring that delegated programs are
achieving their intended goals.

2.	Safe Reuse of Contaminated Sites: The EPA's duty is to ensure that reused contaminated
sites are safe for humans and the environment. The EPA must strengthen oversight of the
long-term safety of sites, particularly within a regulatory structure in which non-EPA parties
have key responsibilities, site risks change over time, and all sources of contamination may
not be removed.

3.	EPA's Framework for Assessing and Managing Chemical Risks: The EPA's
effectiveness in assessing and managing chemical risks is limited by its authority to regulate
chemicals under the Toxic Substances Control Act. Chemicals manufactured before 1976
were not required to develop and produce data on toxicity and exposure, which are needed to
properly and fully assess potential risks.

4.	EPA Needs to Improve Its Workload Analysis to Accomplish Its Mission Efficiently
and Effectively: The EPA's human capital is an internal control weakness in part due to
requirements released under the President's Management Agenda. The EPA has not
developed analytical methods, and does not collect data needed to measure its workload and
the corresponding workforce levels necessary to carry out that workload.

5.	Enhancing Information Technology Security to Combat Cyber Threats: The EPA's
information security challenges stem from four key areas: (1) risk management planning,
(2) security information and event management tool implementation, (3) computer security
incident response capability and network operation integration, and (4) computer security
incident response capability relationship building.

6.	Improved Management Oversight to Combat Fraud and Abuse: Recent events and
activities indicate a possible "culture of complacency" among some supervisors at the EPA
regarding time and attendance controls, employee computer usage, and real property
management. EPA managers must emphasize and reemphasize the importance of compliance
and ethical conduct throughout the agency and ensure it is embraced at every level.

8


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EPA Internal Control Risks and Weaknesses Identified by the OIG
for FY 2014

We identified the following EPA internal control weakness as part of our annual Federal
Managers' Financial Integrity Act activities.

• EPA Needs Continued Improvement on Contract Management Internal Controls.

Risks, Priorities and Issues Identified by EPA Through
OIG Stakeholder Outreach Interviews

The following information identifies cross-cutting risks, priorities and issues identified through
outreach solicitations and meetings with EPA leadership. In Appendix B, we provide further
details.

•	Emergency Preparedness/Homeland Security.

•	Better Collaboration/Coordination with States and Other Federal Agencies With
Environmental Mission and Authority.

•	Limitations of EPA Authority.

•	Consistent and Reliable Data and Performance Measurement.

•	Improving EPA Organizational Design and Coordination of Resources to Eliminate
Duplication and Modernization of EPA.

•	Monitoring of States, Grants Management, Compliance and Enforcement.

•	Human Capital Management—Skill Gaps/Alignment With Functions and Workforce
Restructuring.

•	Better Use of Technology, Information and Research.

•	EPA's Regulatory Process (Better and Faster Analysis of Costs, Science and Benefits).

•	Planning and Priority Setting for Better Application of Resources.

•	Hydraulic Fracturing, Water Infrastructure, Financing and Water Availability.

•	Climate Change and Air Quality.

•	Brownfields/Environmental Justice, Tribal Capacity.

9


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Annual Plan Strategy

Annual planning is a dynamic process and requires adjustments throughout the year to meet
priorities and to anticipate and respond to emerging issues with the resources available.
The OIG examines the challenges, prior work, future priorities and customer input to develop
and prioritize its FY 2015 work.

Making Choices—A Customer-Driven Process

OIG work that is not mandated is proposed, considered and selected through a rigorous process
using the criteria listed below to develop a portfolio of assignments that represent the best
possible return on investment in terms of monetary or public value. We conducted considerable
outreach to agency leaders and stakeholders on environmental and management risks, challenges
and opportunities. We conducted an assessment based upon previously identified risks and
challenges. We invited our entire staff to formulate assignment suggestions from their
knowledge of EPA operations and the consideration of stakeholder input and risks.

Criteria Considered in Identifying and Selecting Audit and Evaluation
Assignments for FY 2015	

Environmental/Human Health/Business Risks Addressed, Including:

•	What is the known extent of the issue (e.g., sensitive or other populations impacted, area
involved, and environmental justice)?

•	What is the potential environmental or human health benefits (return on investment) to be
derived and the reduction or prevention of environmental, human health or business risks?

Potential Risk of Fraud, Waste or Abuse:

•	What resources and data, physical or cyber security equipment, and program integrity and
violations of laws/regulations are involved?

Opportunity for Improved Business Systems/Accountability, Including:

•	How does the project align with the EPA's strategic goals/objectives?

•	What is the expected return on investment (for example, potential questioned costs, funds
put to better use or other potential monetary benefits, improved decision-making, improved
data quality/reliability, reduced vulnerabilities, and strengthened internal controls)?

EPA Dollar/Full-Time Equivalent Investment/Financial Impact (in relation to the EPA's

overall resource level):

•	What headquarters and regional resources are committed to the program, including full-
time equivalents?

•	What resources are used, including contracts, grants, state programs or other
mechanisms, such as state funding, to accomplish the goals? How might this impact the
program's implementation? What percentage of the program's funding is coming from
state, other federal or private partnership resources?

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Prior Audit/Evaluation Results:

•	What are the conditions or changes since prior review by the EPA OIG, U.S. Government
Accountability Office or other auditing body?

•	What new information or indications of auditable issues are available?

Stakeholder/Public Interest:

•	Is the topic of the project generating interest from Congress, the public and news
organizations? What is the interest and why?

•	Who are the expected users of the project's product? How would it be used?

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The Plan: Continuing and
New Assignments for FY 2015

Office of Audit

OIG audit work focuses on five areas, with emphasis on identifying opportunities for cost
savings and reducing risk of resource loss. Funds awarded for assistance agreements and
contracts account for approximately two-thirds of the EPA's budget. Producing timely and
reliable financial statements remains a priority across the federal government. Equally important
is the need to gather, protect and use financial and program performance information to improve
the EPA's accountability and program operations. The Office of Audit's five product lines are:

•	Contracts and Assistance Agreement Audits.

•	Efficiency Audits.

•	Forensic Audits.

•	Financial Audits.

•	Information Resources Management Audits.

Specific assignments are listed on the following pages and will emphasize:

•	Testing for fraud in grants, contracts and operational activities.

•	Cost savings resulting from audits of grantee and contractor claims.

•	Continued improvements in assistance agreements and contract administration.

•	The EPA's preparation of timely, informative financial statements.

•	Identification of cost savings and potential cost recoveries, reduce risks and
maximize results achieved from its environmental programs.

•	Reviews of the EPA's internal controls, including its risk assessment processes and
allocation/application of human resources.

•	The EPA's integrity of data and system controls, as well as compliance with a variety of
federal information security laws and requirements, to ensure system and data integrity.

•	Environmental effect of weaknesses identified and improvements made from these audit
projects.

Following are definitions of OIG carryover, discretionary and mandated assignments:

•	Carryover Assignments: Assignments still in progress that started in a prior fiscal year.

•	Discretionary Assignments: Assignments designed to identify and prioritize projects in
areas of highest risk.

•	Mandated Assignments: Assignments that the OIG is required to conduct by law or
regulation.

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Contracts and Assistance Agreement Audits

The Contracts and Assistance Agreement Audits product line is responsible for conducting
performance audits of the EPA's management of contracts, grants, cooperative agreements
and interagency agreements.

Point of Contact: Janet Kasper (312) 886-3059

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

Grant Advanced
Monitoring

To determine whether EPA's advanced
administrative monitoring system is effective at
ensuring that grant recipient costs are allowable.

March 2014

Special Appropriation Act
Project Audit Follow-up

To determine whether the corrective actions taken
in response to the 2010 audit have been effective in
reducing the unobligated and unliquidated funds
associated with Special Appropriation Act Project
grants.

March 2014

EPA Use of Title 42 Hiring
Authority

To determine whether EPA is properly managing its
Title 42 hiring authority.

March 2014

Pioneer Valley
Commission

To determine whether funds were expended in
accordance with federal regulations and
environmental results were achieved in accordance
with recipients' grant requirements.

March 2014

Hotline - Help Desk
Charging

To determine whether the contractor is correctly
charging EPA for costs associated with operation of
the help desk.

April 2014

OIG Purchase Card
Transactions

To examine OIG purchases to identify prohibited
transactions.

April 2014

Superfund Technical
Assessment and
Response Team (START)
IV awarded to Tetra Tech
Inc.

To assess whether EPA is monitoring the contractor
for compliance and contractor is billing costs in
accordance with the contract terms and conditions.

August 2014

Discretionary

EPA's Simplified
Acquisitions

To determine whether EPA has sufficient controls
over purchase orders to identify potentially illegal,
improper and erroneous use of purchase orders;
and purchase orders are used in accordance with
applicable regulations and guidance, and were for
allowable and necessary goods and services.

April 2015

EPA's Working Capital
Fund Background
Investigations Services

To determine whether the contractor is correctly
charging the agency for background investigations
in accordance with the contract terms and
conditions, and EPA has adequate oversight
controls in place to ensure that its contractor is
meeting the contract requirements for background
investigations.

September 2014

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Title

Primary Objective

Estimated/
Actual Start Date

EPA Conferences:
Maximizing
Cost Efficiencies

To determine whether EPA has the internal controls
over conferences to ensure expenses are
appropriate, necessary, and managed in a manner
that minimizes expenses to taxpayers and provides
optimum use of resources.

September 2014

Oversight of Clean Water
State Revolving Loan
Funds

To determine whether EPA regions provide
sufficient oversight of state Clean Water State
Revolving Loan Fund programs and regions follow
EPA guidance when providing oversight.

June 2015

Mandated

Improper Payments - FY
2014

To assess compliance with the Improper Payments
Elimination Act of 2002, as amended.

November 2014

Charge Card Annual
Report - Status of
Recommendations

To determine the status of EPA's implementation of
recommendations related to charge cards and travel
cards.

December 2014

Periodic Assessment of
Purchase Card and
Convenience Check
Program

To conduct an annual assessment of EPA's
purchase card and convenience check programs.

July 2015

Travel Card Review

To conduct periodic audits of travel card programs
to analyze the risks of illegal, improper or erroneous
use to travel purchases and payments.

April 2015

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Efficiency Audits

The Efficiency Audits product line is responsible for identifying ways for EPA programs and
operations to improve processes and realize cost savings, thus freeing resources for high
priority environmental projects.

Point of Contact: Mike Davis (513) 487-2363

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

Oversight of Guam,
American Samoa,
Commonwealth of the
Northern Mariana Islands
and U.S. Virgin Islands

To examine whether EPA has controls and
processes in place to ensure proper oversight of
Guam, American Samoa, Commonwealth of the
Northern Mariana Islands and U.S. Virgin Islands.

January 2014

EPA Investments in
Information Technology
Products and Services

To determine whether information technology
investments in the EPA's Office of Environmental
Information are efficiently and effectively managed
to meet the agency's strategic goals and mission.

January 2014

Controls for Travel of EPA
Employees

To determine the effectiveness of EPA oversight
and controls for employees in travel status.

April 2013

Management and Disposal
of Underutilized Personal
Property Stored in
Warehouse Spaces

To determine the extent to which the EPA's
personal property stored in select warehouse
spaces are effectively utilized, accounted for and
disposed of by the EPA.

April 2013

EPA's Fleet Management

To determine whether the EPA's fleet program is in
accordance with the federal fleet requirements for
utilization and fuel energy conservation.

June 2013

Discretionary

EPA Transit Subsidy
Program

To evaluate the EPA's compliance with procedures
for compensating employees with transit subsidy
benefits.

October 2014

Positioning EPA for the
Digital Age: Technological
Changes Create
Transformation
Opportunities

To review the agency's current printing practices: Is
the EPA using its publication dollars in the most
effective way.

October 2014

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Forensic Audits

The Forensic Audits product line is responsible for conducting financial audits of EPA
assistance agreements and contracts to identify potentially fraudulent actions and determine
the acceptability of costs claimed under specific financial instruments.

Point of Contact: Robert Adachi (415) 947-4537

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

Congressional Request -
Timekeeping Practices

To address a Senator's request concerning internal
controls over EPA timekeeping practices.

October 2013

Region Request -
Manchester Band of Pomo
Indians

To determine the propriety of recent drawdowns
made by the Manchester Band of Pomo Indians
under EPA grants and whether the historical costs
incurred are reasonable, allocable and allowable
under federal regulations and the grant terms and
conditions.

April 2014

Congressional Request -
EPA's Process Used to
Determine and Track
Employee Overtime
Compensation

To determine whether EPA properly documents how
overtime is distributed to employees.

May 2014

Pegasus Technical
Services Inc. Contract

To determine whether the costs billed were
reasonable, allocable and allowable.

December 2012

Region 9 Request -
Review of Select Tribes in
Nevada

To review EPA grants opened or closed within the
past 3 years involving selected tribes in Nevada.

February 2014

Discretionary

Brownfields Revolving
Loan Fund Assistance
Agreement Audits

To perform assistance agreement audits of selected
Brownfields Revolving Loan Fund recipients to
determine whether funds were expended in
accordance with federal regulations and
environmental results were achieved in accordance
with recipients' grant requirements.

January 2015

Construction Grants
Awarded to the District of
Columbia Water and
Sewer Authority

To determine whether the costs claimed under the
grants are reasonable, allocable and allowable and
whether the objectives of the grant have been met.

March 2015

Mandated

FY 2015 Single Audit
Program

To review and process Single Audit reports that are
prepared by Certified Public Accountant firms under
the Single Audit Act.

January 2015

Oregon Health Authority -
Labor Charging

To examine Oregon Health Authority's labor
charging practice.

February 2015

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Financial Audits

The Financial Audits product line is responsible for rendering opinions on financial statements
produced by the EPA, and also conducts performance audits of EPA financial matters for
efficiency and effectiveness.

Point of Contact: Paul Curtis (202) 566-2523

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

FY 2013 Financial
Statements: Pesticides
Reregistration and
Expedited Processing
Fund

To render an opinion on the agency's statements,
and determine compliance with laws and
regulations.

February 2014

FY 2013 Financial
Statements:

Pesticide Registration
Fund

To render an opinion on the agency's statements,
and determine compliance with laws and
regulations.

February 2014

Independent Government
Cost Estimates and
Indirect Costs for EPA's
Interagency Agreements

To determine whether EPA promotes sound
financial practices.

February 2014

EPA's Accounts
Receivable Internal
Controls

To determine whether EPA's accounts receivable
internal controls function is effective and ensures
the reliability of financial reports.

February 2013

FY 2014 EPA Financial
Statements

To determine whether EPA's consolidated financial
statements were fairly stated in all material
respects.

April 2014

Discretionary

Oversight of Superfund
State Contract for
Remedial Activities

To evaluate the control the agency exerts over the
Superfund State Contract process and whether the
agency is recovering its lawful costs from the states.

November 2014

Working Capital Fund
Cost Rates

To determine whether the Working Capital Fund is
operating as intended and is helping to reduce
EPA's cost of doing business.

November 2014

EPA's Accountable
Property

To determine whether EPA promotes sound
fiduciary responsibilities by providing timely and
accurate inventory information.

January 2015

Mandated

FY 2014 Financial
Statements: Pesticides
Reregistration and
Expedited Processing
Fund

To render an opinion on the agency's statements,
and determine compliance with laws and
regulations.

March 2015

FY 2014 Financial
Statements:

Pesticide Registration
Fund

To render an opinion on the agency's statements,
and determine compliance with laws and
regulations.

March 2015

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Estimated/

Title

Primary Objective

Actual Start Date

FY 2014 Financial
Statements: Hazardous
Waste Electronic Manifest
System Fund

To determine whether: (1) the financial statements
were fairly presented in all material respects,
(2) EPA's internal controls over financial reporting
were in place, and (3) EPA management complied
with applicable laws and regulations.

January 2015

FY 2015 EPA Financial
Statements

To determine whether EPA's consolidated financial
statements were fairly stated in all material
respects.

April 2015

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Information Resources Management Audits

The Information Resources Management Audits product line reviews the economy, efficiency
and effectiveness of the agency's investments in systems for achieving environmental goals
and ensuring integrity of data used for decision making; and reviews strategies for setting
priorities, developing plans to accomplish the priorities, and measuring performance.

Point of Contact: Rudolph Brevard (202) 566-0893

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

Follow-Up on Significant
Information Technology
Security Findings

To determine whether EPA has implemented
corrective actions to address significant information
technology security findings.

March 2014

Status of Cloud-Computing
Environments Within the
Federal Government

To determine to what extent the federal
government relies on cloud-based technologies.

January 2014

Data Quality Review of
Self-Reported Information
in EPA's XACTA System

To determine whether the EPA implemented
management control processes for maintaining the
quality of data in the EPA's XACTA System.

March 2014

EPA's Contractor
Information Technology
Systems

To determine the extent that EPA relies on
contractor systems for information processing and
programmatic support that mitigate the information
security risks posed by these systems.

March 2014

FY 2014 EPA Federal
Information Security
Management Act Audit

To determine whether the EPA's Computer
Security Program is comprehensive and actively
implemented throughout the agency to balance risk
and mission.

March 2014

Discretionary

EPA's Leasing of Computer
Equipment

To determine whether EPA has established
adequate controls over equipment leasing.

December 2014

EPA's Use of Electronic
Reporting to Enhance
Enforcement Activities

To determine whether EPA has an effective
electronic reporting process to enhance
enforcement activities against entities for
noncompliance of regulatory requirements.

January 2015

EPA's System
Development Activities for
the Hazardous Waste
Electronic Manifest System

To evaluate whether EPA is effectively managing
the system development process of the e-Manifest
system and to determine whether the project is
achieving desired outcomes.

May 2015

FY 2015 EPA Federal
Information Security
Management Act Audit

To determine whether the EPA's Computer
Security Program is comprehensive and actively
implemented throughout the agency to balance risk
and mission.

March 2015

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Office of Program Evaluation

The Office of Program Evaluation examines root causes, effects and opportunities leading to
conclusions and recommendations that influence program change and contribute to the
accomplishment of the agency's mission. Program evaluations answer questions about how well
a program or activity is designed, implemented or operating in achieving EPA goals. Program
evaluations may produce conclusions about the value, merits or worth of programs or activities.
The results of program evaluations can be used to improve the operations of EPA programs and
activities, sustain best practices and effective operations, and facilitate accomplishment of EPA
goals. Evaluations by the Office of Program Evaluation are performed by staff with diverse
backgrounds, including accounting, economics, environmental management and the sciences,
and they comply with Government Auditing Standards.

Evaluation topics and priorities in our plan are driven by our assessment of organizational risk in
relation to available resources and based on input from the EPA's leadership, Congress and
stakeholders. Program evaluations are conducted by the following six product lines:

•	Air

•	Water

•	Land Cleanup and Waste Management

•	Toxics, Chemical Management and Pollution Prevention

•	Science, Research and Management and Integrity

•	Special Program Reviews

Assignments concentrate on all of the OIG themes, reflecting our attention to the agency's
mission as well as the agency's operational and systemic risks. Specific assignment titles are
listed on the following pages.

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Air

The Air product line is responsible for conducting evaluations to assess EPA's programs and
activities to protect human health and the environment through progress toward air quality
and climate change goals.

Point of Contact: Rick Beusse (919) 541-5747

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

Use of Remote Sensing
Data to Assess
Contamination at Delisted
Superfund Sites - Phase 2

To determine whether hyperspectral imaging data
can be used to assess pollution concentrations in
vegetation as a potential indication of pollutant
concentrations at delisted Superfund sites.

March 2012

Selected Ambient Air Quality
Monitoring Networks

To assess whether EPA effectively used annual
network reviews to determine how well the
monitoring network is achieving its objectives.

July 2014

Enforcement Decree
Compliance for Selected
Clean Air Act Sources

To determine whether EPA ensured that selected
facilities with Clean Air Act violations comply with
terms of their enforcement agreement.

June 2014

EPA Efforts to Incorporate
Environmental Justice into
Clean Air Act Inspections for
Air Toxics

To determine whether EPA has targeted
overburdened communities or communities with
disproportionate impacts for air toxics inspections.

March 2014

EPA Region 2 Oversight of
the Environmental Programs
Operated by the U.S. Virgin
Islands (collaborative effort
with Water and Land
Cleanup and Waste
Management product lines)

To assess whether the environmental programs
the U.S. Virgin Islands implements on EPA's
behalf meet EPA programmatic requirements, and
what steps Region 2 has taken to ensure that the
Virgin Islands' programs achieve the intended
environmental benefits.

November 2013

Title V Annual Compliance
Certifications

To assess the extent to which EPA and state and
local agencies verify the accuracy of Title V
annual compliance certifications submitted by Title
V facilities.

October 2014

Discretionary

Implementation of Benzene
Fuel Content Standards

To determine the effectiveness of EPA's process
and controls for ensuring that gasoline refiners
and importers meet EPA standards for benzene
content in gasoline.

February 2015

Assessment of EPA Efforts
to Address Workload
Imbalances in its Clean Air
Act Risk Management
Program

To determine the effectiveness of EPA's efforts to
address past workload imbalances in its Risk
Management Program.

March 2015

EPA Oversight of
Enforcement Actions for
Selected Startup, Shutdown
and Malfunction Events

To determine whether EPA's oversight has
ensured proper enforcement of the requirements
for selected startup, shutdown and malfunction
events.

November 2014

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Title

Primary Objective

Estimated/
Actual Start Date

Effectiveness of Compliance
Assurance Activities for
Major and Synthetic Minor
Clean Air Act Sources

To determine the effectiveness of EPA's
compliance assurance activities for major and
synthetic minor Clean Air Act sources not
inspected as called for in EPA's Clean Air Act
Compliance Monitoring Strategy.

July 2015

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Water

The Water product line is responsible for conducting evaluations to assess the EPA's protection
and restoration of healthy aquatic communities and waters that sustain human health.

Point of Contact: Dan Engelberg (202) 566-0830

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

Safe Drinking Water in Small
Drinking Water Systems

To determine how the EPA helps states and
territories ensure that small water utilities with
serious violations come into compliance with
health-based standards and treatment
requirements.

September 2014

Municipal Sewer and
Stormwater Systems:
Consent Decree Progress
and Challenges

To determine what results the major municipal
stormwater improvement programs had on
compliance and environmental quality.

August 2014

EPA's Oversight of Hydraulic
Fracturing

To determine whether EPA is effectively and
efficiently managing the environmental and health
risks to drinking water and surface water.

February 2014

EPA Region 2 Oversight of
the Environmental Programs
Operated by the U.S. Virgin
Islands (collaborative effort
with Air and Land Cleanup
and Waste Management
product lines)

To assess whether the environmental programs
the U.S. Virgin Islands implements on EPA's behalf
meet EPA programmatic requirements, and what
steps Region 2 has taken to ensure that the Virgin
Islands' programs achieve the intended
environmental benefits.

November 2013

Drinking Water State
Revolving Fund

To determine how the EPA and states demonstrate
that completed Drinking Water State Revolving
Fund projects met project and program goals and
contributed to improved drinking water quality and
public health.

November 2013

Discretionary

BEACH ACT: Review of the
Effectiveness of Identifying
Contaminated Recreational
Waters and Communicating
Health Risks

To evaluate whether states, territories and tribes
have effective beach monitoring programs.

April 2015

EPA Programs to Protect the
Public from Mercury
Contamination in Fish

To examine how effectively EPA and states are
protecting the public from the threats of mercury
contamination in fish.

August 2015

EPA Programs to Protect
Drinking Water from
Contamination Incidents

To assess the adequacy of programs to prevent
contamination from chemical spills, excess
nitrogen from farm fields, algal blooms, and threats
from diminishing levels of groundwater and surface
water sources.

August 2015

Clean Water State Revolving
Fund Green Project Reserve
Program

To examine the benefits of green projects funded
in the Clean Water State Revolving Fund.

October 2014

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Land Cleanup and Waste Management

The Land Cleanup and Waste Management product line is responsible for conducting evaluations
to assess EPA programs, activities and initiatives to protect human health and the environment
through cleanup and waste management, accident prevention and emergency response.

Point of Contact: Tina Lovingood (202) 566-2906

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

EPA Oversight of the Import
of Hazardous Waste

To determine whether EPA oversight of the import
of hazardous waste is accomplishing the identified
goals.

November 2013

Siting Renewable Energy on
Potentially Contaminated
Land and Mine Sites:
Environmental, Health and
Financial Risks

To determine whether EPA's efforts to promote
sitting renewable energy on potentially
contaminated land and mine sites ensure short-
and long-term human health protection.

December 2013

Cross Program
Revitalization Measure
Hyperspectral Imaging
Region 4

To determine whether hyperspectral imaging data
is a useful tool for assessing
contamination and cleanup at Brownfields and
Superfund sites.

April 2013

CTS Update: Sampling
Monitoring Communication
and Opportunities for
Cleanup Efficiencies

To determine if the sampling and monitoring
activities at the CTS site meet established
requirements and procedures.

July 2014

Environmental Risks from
Resource Conservation and
Recovery Act Hazardous
Waste Post-Closure Landfills

To determine the public health, environmental and
fiscal risks associated with the expiration of the 30-
year post-closure time period.

November 2013

EPA Region 2 Oversight of
the Environmental Programs
Operated by the U.S. Virgin
Islands (collaborative effort
with Air and Water product
lines)

To assess whether environmental programs the
U.S. Virgin Islands implements on EPA's behalf
meet EPA programmatic requirements, and what
steps Region 2 has taken to ensure that the Virgin
Islands' programs achieve the intended
environmental benefits.

November 2013

Discretionary

Optimization of Superfund-
Financed Pump and Treat
Systems

To identify whether EPA implemented the
recommendations from the 2000-2002 EPA
Nationwide Fund-Lead Pump and Treat
Optimization Project at the 20 Superfund pump and
treat sites.

July 2015

EPA Progress on Meeting
Resource Conservation and
Recovery Act Statutory
Mandate for Minimum
Frequency of Inspections at
Hazardous Waste Disposal
Facilities

To examine whether EPA ensures that Resource
Conservation and Recovery Act inspections are
performed at the required frequency for high-
impact treatment, storage and disposal facilities.

October 2014

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Title

Primary Objective

Estimated/
Actual Start Date

Confirmation of EPA Time-
Critical Removal Actions

To examine whether EPA can provide
documentation that imminent and substantial
endangerment threats to public health at time-
critical removal sites have been addressed.

July 2015

EPA Progress on Reducing
Taxpayer Environmental
Liabilities

To examine whether EPA reviews nationwide
Superfund and Resource Conservation and
Recovery Act financial liabilities for companies with
multiple facilities/sites to verify financial assurance
mechanisms are valid.

April 2015

Long-Term Risks from
Short-Term Disposal of
Debris from Natural
Disasters

To evaluate whether EPA has controls in place to
ensure the long-term safety of landfills used to
dispose of disaster debris.

April 2015

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Toxics, Chemical Management and Pollution
Prevention

The Toxics, Chemical Management and Pollution Prevention product line is responsible for
conducting evaluations to assess the EPA's management of chemical risks and programs to
prevent pollution.

Point of Contact: Jeffrey Harris (202) 566-0831

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

National Pesticide
Information Center Federal
Insecticide, Fungicide and
Rodenticide Act Programs
Enforcement Referrals

To determine whether Federal Insecticide,
Fungicide and Rodenticide Act and pesticide
misuse issues that have been reported to the
National Pesticide Information Center are being
adequately resolved by federal or state authorities.

April 2014

Adequacy of EPA's
Oversight of State Federal
Insecticide, Fungicide and
Rodenticide Act Programs

To determine the efficiency of EPA's oversight of
states' implementation of the Federal Insecticide,
Fungicide and Rodenticide Act program.

October 2013

Discretionary

Pollution Prevention Grant
Results and Measures

To evaluate whether results reported under the
Pollution Prevention Government Performance and
Results Act performance measures are accurate,
transparent and supported.

April 2015

Office of Pesticide
Program's Genetically
Engineered Corn Insect
Resistance Management

To determine the extent to which the Office of
Pesticide Program collects and reviews industry
Compliance Assurance Program reports submitted
by genetically engineered corn seed registrants.

October 2014

P2 Green Chemistry
Challenge Program Results

To ensure that all reported contributions to the
EPA's performance measures are adequately
supported.

October 2014

EPA Policies and
Responsiveness to Public
Petitions on Pesticide Issues

To determine whether there is an effective process
to track the receipt, disposition and resolution of
public petitions.

October 2014

EPA's Regional Negotiated
Commitments with States for
Federal Insecticide,

Fungicide and Rodenticide
Act Compliance Inspections

To evaluate EPA's procedures for determining and
periodically reviewing state commitments for
Federal Insecticide, Fungicide and Rodenticide Act
compliance inspections.

April 2015

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Science, Research and Management Integrity

The Science, Research and Management Integrity product line conducts independent evaluations
of EPA's research and development programs and operations managed and directed by the
Office of Research and Development. Particular focus is given to those areas that support human
health and environmental protection. The product line also develops, coordinates and reports on
OIG-identified agency management challenges and internal control weaknesses.

Point of Contact: Patrick Gilbride (303) 312-6969

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

EPA's Assessment of
Potential Mining Impacts in
Bristol Bay, Alaska

To determine whether the EPA adhered to laws,
regulations, policies and procedures in developing
its assessment of potential mining impacts on
ecosystems in Bristol Bay, Alaska.

May 2014

Equipment Utilization Within
the Office of Research and
Development

To determine whether the Office of Research and
Development has adequate controls over research
equipment, including utilization, maintenance
safeguarding and calibration.

June 2014

Region 6 Coastal Wetlands

To examine the Water Quality Protection Division
used Coastal Wetlands Planning, Protection and
Restoration Act trust funds in accordance with
applicable federal laws and regulations, as well as
any agreement with the U.S. Army Corps of
Engineers.

February 2013

EPA's Use of Other Federal
Agencies, Universities and
Foundations for Research

To determine the extent to which EPA utilizes
external sources, such as other federal agencies,
universities, and foundations for agency research.

October 2014

OIG Hotline Complaint -
Management of Travel and
Trust Funds in Region 6
Water Quality Protection

To determine whether the division's Marine and
Coastal Section used trust funds in accordance
with applicable federal laws and regulations as well
as any agreement with the Army Corps of
Engineers.

February 2013

Discretionary

Controls over Science to
Achieve Results Grants for
Research Misconduct

To determine whether the Office of Research and
Development has controls in place within the
Science to Achieve Results program to detect and
prevent research misconduct.

December 2014

Office of Research and
Development's Management
of Reimbursable Funds for
Research

To evaluate Office of Research and Development
processes and procedures for managing
reimbursable funds for research.

August 2015

Mandated

2015 Management
Challenges and Internal
Controls Weaknesses

To provide the Administrator and Congress those
issues which present the greatest challenge to
EPA.

December 2014

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Special Program Reviews

The Special Program Reviews product line is responsible for conducting evaluations to
assess agency programs and functions to determine whether sufficient controls are in place to
reduce the agency's risk of fraud, waste and abuse in its operations.

Point of Contact: Eric Lewis (202) 566-2664

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

EPA's Progress Under
Environmental Justice Plan
2014

To assess the effectiveness of the Environmental
Justice 2014 plan.

October 2013

Alternate Asbestos Control
Method Follow On

To determine whether the execution of AACM
experiments resulted in CERCLA 103 violations.

June 2013

Workforce Restructuring
Under Voluntary Early
Retirement Authority/
Voluntary Separation
Incentive Payment

To evaluate the workforce restructuring goals by
program and regional office for consistency of
practices.

September 2014

EPA's Antimicrobial Testing
Program

To determine whether EPA needs to consider
upgrades to its antimicrobial testing program that
stakeholders have stated is ineffective.

January 2014

Follow Up Evaluation EPA
Inaction in Identifying
Hazardous Waste
Pharmaceuticals May Result
in Unsafe Disposal

To determine the status of corrective actions for
two of the three recommendations that the
corrective actions have been completed.

February 2014

Discretionary

Follow-Up Report - EPA
Should Revise Outdated or
Inconsistent EPA-State
Clean Water Act
Memorandums of
Agreement

To follow up and verify corrective actions
completed and accuracy of Management Audit
Tracking System reporting.

October 2014

Follow-Up Report -
Improvements Needed in
EPA Training and Oversight
for Risk Management
Program Inspections

To verify corrective actions completed and
Management Audit Tracking System data quality to
determine whether EPA strengthened its
management controls to ensure that Risk
Management Program inspectors and supervisors
meet their minimum training requirements.

October 2014

Effectiveness of EPA's
Environmental Education
Activities

To determine whether EPA has developed the
framework and tools to allow for the measurement
of the environmental education program.

October 2014

Mandated

EPA's Classification of
National Security Information
(Second Evaluation)

To review agency implementation of previous
recommendations as required by the Reducing
Over Classification Act.

June 2015

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Office of Investigations

The OIG's Office of Investigations (01) primarily employs criminal investigators (Special
Agents), as well as computer specialists and support staff. 01 maintains a presence in most EPA
regions and at selected EPA laboratories, other facilities and headquarters. The majority of
investigative work is reactive in nature.

01 receives hundreds of allegations of criminal activity and serious misconduct in EPA programs
and operations that may undermine the integrity of, or confidence in, programs, and create
imminent environmental risks. To prioritize its work, 01 evaluates allegations to determine
which investigations may have the greatest impact on agency resources and on the integrity of an
EPA program and operation, and produce the greatest deterrent effect. 01 contributes to EPA's
strategic goals by ensuring that the agency's resources are not pilfered by criminal activity or
criminals.

01 has identified the following major areas on which to focus its investigative activity:

•	Financial fraud (contracts and assistance agreements).

•	Threats directed against EPA employees, facilities and assets.

•	Alleged criminal conduct or serious administrative misconduct by EPA employees.

01 supports the agency and conducts OIG oversight and assistance, as directed by statute and the
Office of Management and Budget, by providing fraud awareness, detection and prevention
training to federal, state, tribal and local officials. 01 manages the EPA OIG Hotline Program,
which receives hundreds of complaints, referrals and allegations of abuse and misconduct.
Additionally, 01 is responsible for identifying and investigating attacks against the EPA's
computer and network systems to protect resources, infrastructure and intellectual property.

Point of Contact: Patrick Sullivan (202) 566-0308

Investigations begun prior to FY 2015 and new investigations will examine:

•	Criminal activities in the award, performance and payment of funds under EPA contracts,
grants, and other assistance agreements to individuals, companies and organizations.

•	Contract laboratory fraud relating to water quality and Superfund data, as well as
payments made by the EPA for erroneous environmental testing data and results that
could undermine the bases for EPA decision making, regulatory compliance and
enforcement actions.

•	Alleged criminal conduct or serious administrative misconduct by EPA employees.

•	Criminal activity or serious misconduct affecting the integrity of EPA programs that
could erode the public trust.

•	Threats directed against EPA employees, facilities and resources.

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•	Intrusions into and attacks against the EPA's network, as well as incidents of hijacking
EPA computers and/or systems in furtherance of criminal activities, and use of outside
computers to commit fraud against the EPA.

•	Disaster relief spending, including participating with other federal OIGs and the EPA
OIG Office of Audit on the Hurricane Sandy Fraud Taskforce.

01 will continue fraud awareness briefings and training of key EPA officials and other
stakeholders to increase their awareness of the indicators of contract and grant fraud and to
identify and report funds at risk, as well as recognize and refer cyber threat issues and indicators
of vulnerabilities.

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OIG Assignments Planned for CSB

The U.S. Chemical Safety and Hazard Investigation Board (CSB)
was created by the Clean Air Act Amendments of 1990. The
CSB's mission is to investigate accidental chemical releases at
facilities, report to the public on the root causes, and recommend
measures to prevent future occurrences.

In FY 2004, Congress designated the EPA Inspector General to serve as the Inspector General
for CSB. The OIG has the responsibility to audit, evaluate, inspect and investigate the CSB's
programs, and to review proposed laws and regulations to determine their potential impact on
CSB programs and operations. During FY 2015, the OIG plans to assess the following for CSB:

•	Does CSB provide timely, accurate, complete and useful information for
decisionmaking?

•	Are CSB programs and operations performing with the greatest efficiency and
effectiveness in regard to allocation and application of resources?

•	Are the CSB's computer security and privacy programs comprehensive and actively
implemented throughout the organization to balance risk and mission requirements?

Point of Contact: Kevin Christensen (202) 566-1007

Title

Primary Objective

Estimated/
Actual Start Date

Carryover

CSB FY 2014 Financial Statements
Audit (Contracted)

To monitor contractor to complete audit
of FY 2014 financial statements.

April 2014

CSB Contracts

To examine whether the CSB effectively
manages its support contracts.

February 2014

CSB FY 2014 Federal Information
Security Management Act Audit

To conduct an independent audit of the
CSB's compliance with the Federal
Information Security Management Act.

March 2014

Discretionary

CSB's Overtime Processes for
Employee Compensation

To determine whether CSB: (1) properly
documented how overtime is distributed
to employees, and if so, what is the
process used; (2) has the ability to break
down the activities that received overtime
benefits for FYs 2013 and 2014; (3) was
compensated overtime for travel; and
(4) followed federal and internal policies
covering overtime compensation.

June 2015

Audit of CSB's Governance

To determine if CSB is following its
internal controls through Board actions
and has governance over the use of non-
government email accounts.

October 2014

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Title

Primary Objective

Estimated/
Actual Start Date

Mandated

CSB FY 2015 Financial Statements
Audit (Contracted)

To monitor contractor to complete audit
of FY 2015 financial statements.

April 2015

CSB FY 2015 Federal Information
Security Management Act Audit

To conduct an independent audit of the
CSB's compliance with the Federal
Information Security Management Act.

March 2015

CSB FY 2015 Proposed Management
Challenges and Internal Control
Weaknesses

To develop the OIG input to the CSB
FY 2015 Proposed Management
Challenges and Internal Control
Weaknesses.

June 2015

CSB Purchase Card Risk Assessment
and Compliance with the Improper
Payment Act

To perform required annual risk
assessment of CSB's purchase cards
and to determine whether CSB was
compliant in FY 2014 with the policies
and procedures governing the Improper
Payment Act.

October 2014

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Appendix A—Performance Measures and Targets

The Government Performance and Results Act requires federal agencies to develop goal-based
budgets supported by annual performance plans that link the organization's mission and strategic
goals to its annual performance goals. The annual performance goals are quantifiable targets
supported by measures and indicators representing the expected outputs and outcomes. The
agency's annual Performance Accountability Report includes actual results compared to targets
to inform the Office of Management and Budget, Congress, and the public about the value they
are receiving for funds invested and how well the OIG is achieving its goals.

This annual plan explains how the OIG will convert its resources into results and benefits of its
work through required and priority assignments. Outcome results and benefits from OIG work
reflect measurable actions and impacts, but there is typically a time lag between the completion
of OIG work and recognition of such results and benefits. Therefore, results and benefits from
OIG audits, evaluations, investigations and reviews are recorded in the year they are recognized
regardless of when the work was performed. Through current-year outputs and long-term
outcomes, OIG targets and seeks to measure and demonstrate the many ways the OIG promotes
economy, efficiency and effectiveness; and prevents and detects fraud, waste and abuse. The
following are the OIG annual performance goals that this plan is designed to achieve, pending
final budget agreements:

Annual performance
measures

Supporting indicators

FY 2015 targets

(based upon
President's
Budget funding
level)

Environmental and business actions
taken for improved performance
and reduction of risk from or
influenced by OIG work

o Policy, process, practice, or control changes

implemented
o Environmental or operational risks reduced or
eliminated

o Critical congressional or public concerns resolved

260 total

Environmental and business
recommendations or risks identified
for corrective action by OIG work

o Recommendations or best practices identified for

implementation
o Risks or new management challenges identified
for action

o Certifications, verifications, or analysis for decision

or assurance
o Outreach/technical advisory briefings

721 total

Potential monetary return on
investment in the OIG, as a
percentage of the OIG budget

o Recommended questioned costs
o Recommended cost efficiencies and savings
o Fines, penalties, settlements, restitutions

139% return on
investment of
budget

Criminal, civil, administrative and
fraud prevention actions taken from
OIG work

o Criminal convictions/civil judgments
o Indictments/informations
o Administrative actions (staff actions and
suspension or debarments)

131 total

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Appendix B—Risks, Priorities and Issues Identified by
OIG During EPA Outreach Interviews With Agency

Management

The OIG is highly committed to being a customer-driven organization that provides
products and services that address the needs and concerns of agency management. Our
planning processes are highly dependent upon, and reflective of, the input received
through our outreach to the agency. A summary of current identified areas of concern
from the agency is provided below. This information is used by staff as a foundation to
lead to the selection of well-supported assignments that answer compelling needs with
measurable results.

EPA Cross-Cutting Risks	EPA Outreach Interviews Areas of Concern

Emergency Preparedness/
Homeland Security

Preparedness for emergencies (natural or
manmade disasters) is an unknown risk and
needs greater attention. In addition, EPA needs
to continue to mitigate the past and future
impacts of disasters.

Protection of drinking water from emerging
contaminants (Water Sentry program) requires a
coordinated effort.

Waste management under possible disaster
conditions presents a secondary risk that needs
attention.

Data security and protection controls may be
vulnerable and should be tested to guard against
cyber attack.

Clarification of roles and responsibilities (within
the EPA, and between federal agencies and
states) needs to be determined and articulated for
better collaboration.

The need for a statute on how we deal with
imports (with possible health impacts on
citizens) is needed to ensure emergency
preparedness/homeland security.	

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EPA Cross-Cutting Risks

Better

Collaboration/Coordination With
States and Other Federal
Agencies

EPA Outreach Interviews Areas of Concern

The 30 federal agencies with an environmental
mission need better coordination in planning and
implementation.

There is a lack of direct lines of authority
(coordination) among and between Assistant
Administrators and regions.

Plans, resources, data, authority and measures
are not aligned with risks and priorities across
the EPA.

Better collaboration internally and with
stakeholders is needed to align processes,
leverage resources, implement controls, reduce
duplication, examine best practices and align
resources with priorities.

The EPA needs to coordinate with Department
of Homeland Security for streamlined efforts on
the new President Directive on Cyber Security
for Water Security.

Oil and gas issues on tribal land complicate
environmental issues and require better
collaboration.

Gulf Coast restoration requires collaboration and
coordination with states and other federal
agencies.	

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EPA Cross-Cutting Risks

EPA Outreach Interviews Areas of Concern

Consistent and Reliable Data and
Performance Measurement

• There are gaps and inconsistencies in the
information that drives the decisionmaking

process.

•	Questions exist as to whether the EPA is
collecting the right data, of sufficient quality,
and is making that data available. The agency
needs to examine the quality of performance
measures to ensure activities are properly
compiled.

•	The EPA's information systems are not aligned
for efficiency, consistency, accessibility and
security.

•	Control of laboratory data, personally
identifiable information and confidential
business information outside of the EPA,
especially related to registration and
re-registration of pesticides and other formulas
regulated by the Toxic Substances Control Act,
all present significant risks. Improvements to
data quality from contract laboratories are
needed.

•	Clean Water Act standards are measured
differently in each state so information collected
is not consistent.

•	Better quality data is needed from multiple data
points to ensure consistent and reliable
information.

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EPA Cross-Cutting Risks

Improving EPA Organizational
Design and Coordination of
Resources to Eliminate
Duplication

EPA Outreach Interviews Areas of Concern

The EPA and its partners need a clear linkage
among goals, resources, processes, actions taken
and outcomes.

There are no standards or agreements among
stakeholders on which to base measures of
environmental risks and outcomes (states vs.
national).

Program efficiency, progress and results are not
measured meaningfully.

The EPA does not know what activities cost and
what efficiency measures are needed. The
agency lacks information needed to assist with
determining when investments need to be made
in relation to other priorities.

Existing statutes are very prescriptive and allow
limited flexibility in managing compliance.
Many statutes may not be relevant today and
revision may be needed to comply with existing
high risk areas.

Differences exist in the ways environmental
laws are monitored and enforced between the
EPA and states/tribes. Monitoring requirements
for grants are underfunded.

The EPA must streamline administrative
functions to eliminate unnecessary redundancy.

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EPA Cross-Cutting Risks

EPA Outreach Interviews Areas of Concern

Monitoring of States, Grants
Management, Compliance and
Enforcement (How Much
Delegation? Federal vs. State
Roles?)

•	The EPA lacks control of fund management and
accountability once the funds for assistance
agreements to grantees are distributed; half of
the agency's budget is allocated to these
agreements.

•	The highest risk in the grants management
process is at the point that funds are spent by
grantees and are sometimes commingled with
other sources of grant funds.

•	Grantees have limited capacity or incentive to
account for funds or performance.

•	The EPA lacks resources to adequately monitor
grants and lacks uniform reporting and
accountability conditions.

•	The EPA should execute and manage grants for
measurable success vis-a-vis their intended
goals.

•	The EPA needs to determine how to get the best
balance for return on investment between
mandatory and voluntary actions.

Human Capital Management -
Skill Gaps/Alignment With
Functions

•	The EPA should analyze its workforce to
identify and fill skill gaps and to implement its
Human Capital Strategy.

•	The EPA needs to determine programs and areas
that can be done locally versus nationally to
decrease overhead.

•	The EPA must determine whether employees in
its workforce are aligned in the right places.

Better Use of Technology,
Information and Research

•	The EPA should manage its resources and the
performance of contractors to optimize their
value added.

•	The EPA needs operational controls to protect
and account for costs, assets, information and
performance.

•	The EPA should more strongly implement the
Federal Managers' Financial Integrity Act and
Office of Management and Budget Circular A-
123 process.

•	The Working Capital Fund lacks the
transparency or accountability necessary to
prove its efficiency.

•	Agency management should better understand
and be accountable for taking agreed-to actions
on OIG recommendations.

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EPA Cross-Cutting Risks

EPA Outreach Interviews Areas of Concern

EPA's Regulatory Process
(Better and Faster Analysis of
Costs, Science and Benefits)

•	The EPA's extremely complex regulatory
process should be streamlined without
compromising its required integrity.

•	Competing interests of stakeholders and the
regulated community may lead to overlaps, gaps
and conflicts.

•	Many policies are out of date or are based on
outdated science and technology.

•	EPA should evaluate how to use voluntary
incentives for compliance.

Cross-Media Risk Assessment,
Planning and Priority Setting for
Better Application of Resources

•	The EPA should use a consistent approach to
evaluate actual and relative environmental and
operational risk and program effectiveness,
assign resource priorities, make regulatory
decisions, take enforcement actions, and inform
its stakeholders.

•	The EPA should ensure the integrity of
laboratory data, results and scientific research;
knowledge and innovative technology should be
transferred in a timely manner in the regulatory
and policy process.

•	Agency programs need a consistent approach for
determining relative risk and demonstrating
outcome results.

Water Infrastructure, Financing
and Water Availability

•	The EPA needs to address failing infrastructure
for drinking and storm water systems.
Approximately $20 billion will be needed to
stabilize infrastructure across states.

•	It is unclear who will pay for needed
infrastructure investment.

•	Hydro fracking in New York needs a before-and-
after study.

•	EPA should examine how natural gas should be
regulated under the Clean Water Act.

Land and Superfund

•	It appears that Superfund sites are taking an
extraordinarily long time to address. The agency
needs to address this issue and determine
whether management issues are preventing sites
from doing cleanups.

•	The EPA needs to examine chemical safety and
ensure that states are monitoring this problem to
ensure safety of communities.

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EPA Cross-Cutting Risks

EPA Outreach Interviews Areas of Concern

Climate Change and Air

•	The EPA should determine how to use creative
financing and leverage funding through
public/private partnerships.

•	The EPA should utilize a better method for
understanding air toxics and their monitoring.

•	The EPA needs a clear and unified strategy,
including participation of other federal agencies
and other national governments.

•	Climate change in the northeast needs to be
analyzed and determine why rebuilding always
focuses on the same places.

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