OFFICE OF INSPECTOR GENERAL

U.S. ENVIRONMENTAL PROTECTION AGENCY

CUSTOMER SERVICE ~ INTEGRITY ~ ACCOUNTABILITY

FISCAL YEAR 2023

OVERSIGHT PLAN


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VISION

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

MISSION

Conduct independent audits, evaluations, and investigations;
make evidence-based recommendations to promote economy,
efficiency, and effectiveness; and prevent and detect fraud,
waste, abuse, mismanagement, and misconduct for the
U.S. Environmental Protection Agency and the
U.S. Chemical Safety and Hazard Investigation Board.

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INSPECTOR GENERAL

U.S. Environmental Protection Agency

January 9, 2023

I am pleased to present the U.S. Environmental Protection Agency Office of
Inspector General's Fiscal Year 2023 Oversight Plan. The Oversight Plan is
the EPA OIG's guide for the audits, evaluations, and other oversight
engagements that fulfill our mission to:

•	Prevent, detect, and deter waste, fraud, and abuse in the EPA's and
U.S. Chemical Safety and Hazard Investigation Board's programs and
operations.

•	Improve the efficiency and effectiveness of the EPA and the CSB.

•	Ensure ethical conduct throughout the EPA and the CSB.

•	Keep the EPA, the CSB, Congress, and the American people fully and
currently informed of problems and deficiencies.

When determining which audits and evaluations to include in our
Oversight Plan, we independently considered the EPA's top management challenges; the work conducted
by the OIG, both statutorily required and discretionary, and the U.S. Government Accountability Office;
remarks from Agency leadership, Congress,1 and the White House; and the EPA's strategic vision, which
is outlined in the EPA's FY 2022-2026 Strategic Plan2

The Fiscal Year 2023 Oversight Plan describes our planned and ongoing oversight projects, which we
have organized by top management challenge.' In our EPA's Fiscal Year 2023 Top Management-
Challenges report, we identified what we consider the top management challenges to the EPA
accomplishing its mission for fiscal year 2023. We retained the fiscal year 2022 top management
challenges with one modification—we split the "managing infrastructure funding and business
operations" challenge into two challenges. This resulted in a total of eight management challenges.

1.	Mitigating the Causes and Adapting to the Impacts of Climate Change.

2.	Integrating and Leading Environmental Justice Across the Agency and Government.

3.	Providing for the Safe Use of Chemicals.

4.	Safeguarding Scientific Integrity Principles.

5.	Ensuring Agency Systems and Other Critical Infrastructure Are Protected Against Cyberthreats.

1	This includes consideration of the supplemental EPA funding provided in the Infrastructure Investment and Jobs Act.

2	Prior to fiscal year 2020, we published an OIG Annual Plan to guide our work each fiscal year. Since fiscal year 2021, we
have published an Oversight Plan,

3	EPA OIG, EPA's Fiscal Year 2023 Top Management Challenges (Nov. 28, 2022).



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Sean W. O'Donnell
Inspector General

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6.	Managing Business Operations and Resources.

7.	Enforcing Compliance with Environmental Laws and Regulations.

8.	Managing Increased Investment in Infrastructure.

Since the EPA OIG also provides oversight to the CSB, to include both mandatory and discretionary
projects, we also independently considered the CSB's top management challenges. In our report Fiscal
Year 2023 U.S. Chemical Safety and Hazard Investigation Board Management Challenges ,4 we identified
three top management challenges that we believe represent the most significant barriers to the CSB
accomplishing its mission for fiscal year 2023. We retained one of the challenges from our previous top
management challenges report and added two new challenges.

1.	Accomplishment of the CSB's Mission Remains Impaired Until the Full Board Is
Confirmed (initially identified in fiscal year 2019).

2.	Minimize Mission Critical Staff Vacancies and Attrition Rates.

3.	Improve Cybersecurity Weaknesses.

The Fiscal Year 2023 Oversight Plan reflects the priority work that the OIG believes is necessary to keep
the EPA, the CSB, and Congress fully informed about issues related to the administration of Agency
programs and operations. The OIG's planning efforts are not static and the projects included in this plan
may be modified throughout the year as challenges and risks for the EPA and the CSB continue to evolve
and emerge, especially as it relates to the distribution and implementation of funding to state, local, and
tribal governments and to other eligible recipients, as provided under the recently enacted Inflation
Reduction Act of 2022.

We look forward to meeting or exceeding our goals and to fulfilling our mission. For those interested in
our planning process, we welcome feedback on the quality and value of our products and services.

Sincerely,

Sean W. O'Donnell

4 EPA OIG, Fiscal Year 2023 U.S. Chemical Safety and Hazard Investigation Board Management Challenges, (Oct. 21, 2022).

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Fiscal Year 2023

Introduction	7

Challenge 1: Mitigating the Causes and Adapting to the Impacts of Climate Change	8

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Planned Projects 	8

Ongoing Projects ^	9

Challenge 2: Integrating and Leading Environmental Justice Across the Agency and
Government	10

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Planned Projects 	10

Ongoing Projects W	11

Challenge 3: Providing for the Safe Use of Chemicals	12

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Planned Projects 	12

Ongoing Projects ^	13

Challenge 4: Safeguarding Scientific Integrity Principles	14

Ongoing Projects ^	14

Challenge 5: Ensuring Agency Systems and Other Critical Infrastructure Are Protected Against
Cyberthreats	15

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Planned Projects 	15

Ongoing Projects ^	16

Challenge 6: Managing Business Operations and Resources	18

f

Planned Projects ^	18

Ongoing Projects ^	22

Challenge 7: Enforcing Compliance with Environmental Laws and Regulations	23

Planned Projects 	23

Ongoing Projects ^	25

Challenge 8: Managing Increased Investment in Infrastructure	27

f

Planned Projects ^	27

Developing Projects 	28

—continued—

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U.S. Chemical Safety and Hazard Investigation Board	29

Planned Projects 	29

Ongoing Projects ^	30

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Introduction

The U.S. Environmental Protection Agency Office of Inspector General, which was established
by the Inspector General Act of 1978, as amended, 5 U.S.C. app., is an independent office of the
EPA that aims to prevent and detect fraud, waste, abuse, and misconduct, and to promote
economy and efficiency in EPA programs and operations. The EPA OIG fulfills the same role for
the U.S. Chemical Safety and Hazard Investigation Board.

Our Fiscal Year 2023 Oversight Plan describes the oversight projects that we intend to conduct
during the fiscal year. Typical oversight projects include audits, evaluations, and investigations
of Agency programs and operations. The Oversight Plan is subject to change throughout the
fiscal year. As challenges and risks evolve and emerge, we may identify additional discretionary
projects that could provide high-impact oversight to EPA and CSB programs. We cannot plan for
some projects, such as those that arise from congressional requests, hotline tips, and emerging
issues or crises.

In developing the Oversight Plan, we focused on projects related to the OIG-identified top
management challenges. During its identification of the top management challenges for the
EPA and the CSB, the OIG considered the Agencies' missions and the budgetary priorities set
forth by Congress. For the Oversight Plan, we also considered the findings, recommendations,
and observations from previous OIG and U.S. Government Accountability Office reports; key
strategic documents, such as the EPA strategic plan; congressional hearings, legislation, and
feedback from members of Congress; and projects related to the Infrastructure Investment and
Jobs Act, or IIJA.5 Collectively, these considerations help ensure that we undertake audits and
evaluations that address the EPA's and the CSB's most pressing challenges.

In this Oversight Plan, we have 72 projects for the EPA—42 planned and 24 ongoing6—and six
projects for the CSB—four planned and two ongoing.5 In the following chapters, we outline
each planned or ongoing project by the fiscal year 2023 top management challenge and include
a summary of the project's objective(s).7

5	H.R.3684 - Infrastructure Investment and Jobs Act, November 15, 2021.

6	These projects reflect planned and ongoing projects as of September 30, 2022. Some projects labeled as planned
or ongoing may have been initiated or had reports published after September 30, 2022, before the publishing of
this plan. For these projects and reports, we have indicated their initiation or publication in footnotes.

7	Some projects may address multiple management challenges. For this plan, we have organized each project by
what we consider the primary management challenge.

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Challenge 1: Mitigating the Causes and
Adapting to the Impacts of Climate Change

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The first challenge among those we identified for fiscal year 2023 is

Mitigating the Causes and Adapting to the Impacts of Climate Change. According to the EPA's
Clean Energy Glossary, the EPA defines climate change as significant changes in measures of
climate—such as temperature, precipitation, and wind patterns—that last for extended periods
of time. To meet this challenge, the Agency will need to effectively allocate resources to
facilitate its coordination with local, state, federal, and international partners for the
development of comprehensive strategies that will mitigate the effects of climate change.
Implementing these strategies will require the Agency to adhere to principles of scientific
integrity in its decision-making processes.

Planned Projects ^

Evaluation of State Inspection of Diesel-Fueled Vehicles

To determine the extent to which state enhanced inspection and maintenance programs
inspect diesel-fueled vehicles to identify and remove aftermarket defeat devices and tampered
vehicles from U.S. roadways.

Audit of Effectiveness of the Resource Conservation and Recovery Act Program
in Preventing Releases of Hazardous Substances during Natural Disasters

To assess the effectiveness of the Resource Conservation and Recovery Act program in
preventing releases of hazardous substances during natural disasters.

Audit of Water Infrastructure Resilience Against Climate Change

To determine if the EPA has adequate strategies and resources in place to ensure water utilities
meet the goal of Executive Order 14008 by incorporating climate change resiliency
considerations into water infrastructure projects.8

i

8 Executive Order 14008, Tackling the Climate Crisis at Home and Abroad (Jan. 27, 2021).

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Ongoing Projects

Audit of the EPA's Oversight of the Renewable Fuel Standards Renewable
Identification Number Market

To determine whether the EPA's Moderated Transaction System and Quality Assurance
Program include controls to identify and reduce the generation and trading of invalid
renewable identification numbers that are used to demonstrate compliance with renewable
fuel standards as overseen by the EPA's Office of Transportation and Air Quality.

Evaluation of the Office of Enforcement and Compliance Assurance's National
Compliance Initiative for Stopping Aftermarket Defeat Devices for Vehicles and
Engines

To determine (1) the EPA's progress toward achieving the goals and measures in the EPA's fiscal
years 2020-2023 National Compliance Initiative titled Stopping Aftermarket Defeat Devices for
Vehicles and Engines, and (2) the extent to which existing measures track and promote the
achievement of the initiative's goals.

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Challenge 2: Integrating and Leading
Environmental Justice Across the Agency
and Government

The second challenge, Integrating and Leading Environmental Justice
Across the Agency and Government, addresses the EPA's challenges as it leads the federal
effort to identify and address disproportionately high and adverse human health or
environmental effects on communities facing environmental justice concerns. Environmental
justice is, according to the EPA, the fair treatment and meaningful involvement of all people
regardless of race, color, national origin, or income, with respect to the development,
implementation, and enforcement of environmental laws, regulations, and policies. The
challenges facing the Agency include effectively communicating risks, assessing cumulative
impacts, and integrating environmental justice principles into civil rights enforcement. As
environmental justice continues to be woven into EPA decisions, and across multiple programs,
EPA decision-makers must have the proper tools and training to properly assess and mitigate
the environmental effects of its decisions.

#

Planned Projects ^

Audit of State Revolving Fund Programs' Progress to Increase Investment in
Disadvantaged Communities Infrastructure Investment and Jobs Act

To determine if state revolving fund programs have appropriately evaluated and revised their
disadvantage community definition, affordability criteria, and point system, as required by the
EPA IIJA implementation guidance. Additionally, to determine if state revolving fund programs
have begun efforts to use available IIJA technical assistance funding or engage residents and
community stakeholders in disadvantaged communities.

Audit of the EPA's Adherence to American Rescue Plan Act Requirements to
Improve Human Health and Environmental Protections for Environmental Justice
Communities

To determine whether the EPA awarded and distributed American Rescue Plan Act of 2021
funds for projects that identify and address disproportionate environmental or public health
harms and risks in minority populations or low-income populations, in accordance with
American Rescue Plan Act section 6002.

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Ongoing Projects

Evaluation of Air Quality at U.S. Maritime Ports

To determine what steps, if any, the EPA is taking to address the increase in air pollution from
oceangoing vessels at U.S. maritime ports.

Audit of Benzene Fenceline Monitoring at Refineries

To determine to what extent oversight of the benzene fenceline monitoring program by the
EPA and delegated state and local agencies assures that refineries take corrective action and
lower benzene, as required, when measured benzene concentrations exceed the action level.

Audit of Cumulative Impacts on Communities with Environmental Justice
Concerns

To determine what actions the EPA has taken to identify and address any disproportionate
health effects to disadvantaged communities located on or near a selected Superfund site in
accordance with the EPA's mission, program goals, and applicable executive orders.

Audit of Drinking Water State Revolving Fund Loan Subsidies to Disadvantaged
Communities

Determine to what extent (1) states have met their Drinking Water State Revolving Fund loan
subsidy goals for disadvantaged communities, as identified in their intended use plans, and (2)
the EPA has identified and addressed barriers, if any, that hindered states from spending the
maximum allowed on loan subsidies for disadvantaged communities in their Drinking Water
State Revolving Fund.

Audit of the Use of the EPA's Elevation Policy to Address Lead in the Benton
Harbor; Michigan Community Water System

To determine the extent to which the EPA followed its 2016 elevation policy in responding to
evidence of drinking water lead contamination in the City of Benton Harbor's community water
system.

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Challenge 3: Providing for the
Safe Use of Chemicals

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The third challenge, providing for the Safe Use of

Chemicals, focuses on the EPA's mission to protect human health and the environment from
harmful chemicals and pesticides. The EPA assesses chemicals and their risks to find ways to
prevent or reduce pollution in the environment. The Agency also regulates the manufacture
and use of all pesticides to safeguard the nation's food supply. The EPA must be able to conduct
credible and timely assessments of the risks that pesticides, toxic chemicals, and other
environmental chemicals pose. In 2016, the EPA's regulatory authority under the Toxic
Substances Control Act was expanded, increasing the need for timely and accurate risk
assessments. Further, the EPA must continue to conduct the registration and reregistration of
hundreds of pesticides per year and to ensure that it sets appropriate exposure levels for
contaminants in drinking water. Without appropriate resource and implementation plans in
place to demonstrate that the EPA can accomplish this work and accurately conduct
scientifically sound risk assessments, the public's trust and confidence in the ability of the EPA
to accomplish its mission of protecting human health and the environment will be at risk.

Planned Projects



Evaluation of the EPA's Response to PFAS Contamination from Plastic Containers
Used to Store Pesticides and Other Chemicals

To determine what steps, if any, the EPA has taken to identify risks and protect human health
from exposure to PFAS, or per- and polyfluoroalkyl substances, occurring through the storage of
chemicals, specifically pesticides, in fluorinated high-density polyethylene and similar plastic
containers.

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Ongoing Projects

Evaluation of the EPA's Response to Reported Incidents of Unintended Effects
from Pet Collar Pesticides

To determine whether (1) the EPA's response to reported pesticide incidents involving Seresto
pet collars provides assurance that the collars can still be used without posing unreasonable
adverse effects to human health and the environment, and (2) the EPA adhered to pesticide
registration requirements in its approval of Seresto pet collars, specifically toxicological data
requirements in 40 C.F.R. part 158.

Audit of the Toxic Substances Control Act's New Chemicals Review Process

To determine the extent to which the EPA is using and complying with applicable records
management and quality assurance requirements, and employee performance standards to
review and approve new chemicals under the Toxic Substances Control Act to manage human
health and environmental risks.

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Challenge 4: Safeguarding Scientific
Integrity Principles

The fourth challenge, Safeguarding

Scientific Integrity Principles, addresses the importance of scientific
integrity in the EPA's decision-making. Per the EPA, science not
only informs all aspects of the EPA's decision-making but also
impacts other domestic and international organizations' decision-
making that is based on the Agency's science. Safeguarding
scientific integrity principles ensures that the federal government's
policies are based upon sound science. Although the EPA has taken
numerous actions to promote scientific integrity, we continue to
find examples of loss of scientific integrity. Additionally, the OIG
continues to receive hotline complaints raising scientific integrity
concerns. The EPA is challenged to fully deploy its scientific integrity concepts throughout the
EPA's culture, potentially hindering its ability to protect human life and the environment. The
OIG will continue to make recommendations related to how the Agency implements its
scientific integrity goals and initiatives.

Source: OIG analysis of survey
results. (EPA OIG image)

Ongoing Projects

Evaluation of the EPA's January 2021 PFBS Toxicity Assessment

To determine whether the EPA's Office of Research and Development and Office of Chemical
Safety and Pollution Prevention followed applicable policies and procedures in the
development and publication of the January 19, 2021, PFBS, or perfluorobutane sulfonic acid,
toxicity assessment.

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Challenge 5: Ensuring Agency
Systems and Other Critical
Infrastructure Are Protected Against
Cyberthreats

The fifth challenge, Ensuring Agency Systems and Other Critical Infrastructure are Protected
Against Cyberthreats, addresses EPA efforts to strengthen the security and resilience of its
critical infrastructure. The federal government, including the EPA, relies heavily on information
technology, or IT, to support its mission and to protect its sensitive information and continues
to face sophisticated attacks on its IT systems, to include those supporting critical
infrastructure. These attacks challenge current cybersecurity defenses, creating an urgent need
for a new security paradigm. Issued in May 2021, Executive Order 14028.9 Improving the
Nation's Cybersecurity, directs federal agencies to invest in their cybersecurity defenses.
Without a robust and mature cybersecurity posture, malicious cyber actors could hinder the
EPA's ability to perform its mission and support its responsibility as the sector risk management
agency for the water and wastewater sectors. This could endanger national security, as well as
the health and safety of the American people.

Planned Projects A

Audit of Classification and Security Controls of EPA's High Value Assets

To determine whether the EPA has (1) developed a risk-based approach to manage its High
Value Asset program in accordance with the requirements of the U.S. Office of Management
and Budget Memorandum M-19-03.10 and (2) implemented required security controls to
protect the EPA's high-value assets' information.

Audit of Active Directory User Account Security Controls Review

To determine whether the EPA's security controls associated with Active Directory user
accounts function as intended to prevent unauthorized access.

9	Executive Order 14028, Improving the Nation's Cybersecurity (May 17, 2021).

10	U.S. Office of Management and Budget Memorandum M-19-03, Strengthening the Cybersecurity of Federal
Agencies by enhancing the High Value Asset Program (December 10, 2018).

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Audit of the EPA's Cybersecurity Incident Detection and Response Capability

To determine whether the EPA's cybersecurity incident response capability adheres to federal
and Agency requirements.

Audit of EPA Compliance with the Federal Information Security Modernization
Act for FY 2023

To assess the EPA's compliance with the fiscal year 2023 inspector general Federal Information
Security Modernization Act reporting metrics.

Ongoing Projects

Audit of the EPA's Central Data Exchange Access Security Controls

To determine whether the EPA has established sufficient controls to prevent unauthorized
access to the EPA's Central Data Exchange system.

Evaluation of the EPA's Compliance with the Federal Information Security
Modernization Act for FY 2022

To assess EPA's compliance with the U.S. Department of Homeland Security's fiscal year 2022
inspector general Federal Information Security Modernization Act reporting metrics.

Audit of Integrated Risk Information System Security Access Controls

To determine whether the EPA's Integrated Risk Information System database adheres to
federal and Agency access control requirements.

Audit - Addressing Cybersecurity Risks to Community Water Systems under the
America's Water Infrastructure Act of2018n

To assess (1) the adequacy of the cybersecurity baseline information that the EPA developed to
meet the requirements of section 2013 of the America's Water Infrastructure Act of 2018 and
how community water systems used this information, and (2) the adequacy of EPA oversight to
ensure that community water systems comply with section 2013 of the America's Water
Infrastructure Act of 2018.

11 This report was published on November 21, 2022, as Report No. 23-P-0003, The EPA Met 2018 Water Security
Requirements but Needs to Improve Oversight to Support Water System Compliance.

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Audit of EPA Internal Controls to Account for and Secure Laptops

To determine whether the EPA headquarters and select regional locations have sufficient
internal controls to properly account for and secure laptops within their possession from theft
and misplacement.

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Challenge 6: Managing Business
Operations and Resources

	. E

The sixth challenge, Managing Business Operations and
Resources, focuses on the Agency's ability to create and maintain effective business operations
for distributing billions of dollars in grants and contracts to states, tribes, and nongovernmental
organizations for infrastructure and Superfund projects. Congress annually provides the Agency
with billions of dollars for its mission to protect human health and the environment. In annual
appropriations for FY 2022, Congress provided the EPA over $850 million to fund nearly
500 earmarked projects, in addition to the significant funding the Agency received under the
Infrastructure Investment and Jobs Act of 2021 and the Inflation Reduction Act of 2022.
Receiving this unprecedented amount of funding in such a short period of time introduces a
significant challenge to the Agency's ability to effectively manage its business operations,
significantly adding to the workload of adequately overseeing the distribution and
implementation of the funding.

Planned Projects A

Audit of EPA Oversight of State Drinking Water System Operator Certification
Programs

To assess whether the EPA annually determines that states have operator certification
programs that meet the Safe Drinking Water Act requirements and, if the EPA determines a
state program is deficient, whether it takes appropriate action to hold the state accountable.

Audit of Unliquidated Obligations in Programs Receiving IIJA Funding

To determine the amount of existing unliquidated obligations from annual appropriations for
programs that are expected to receive supplemental funding from the IIJA.

Audit of the EPA's Clean School Bus Program

To determine whether applications for the Clean School Bus Program rebates funded by the IIJA
meet prioritization criteria and eligibility requirements and to what extent the EPA has assessed
the likelihood and impact of fraud risks as it pertains to implementation of the rebate program.

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Audit of Drinking Water Capacity Development Impacts on DWSRF Loans and
Drinking Water Compliance

To determine whether state capacity development programs are ensuring that drinking water
systems receiving DWSRF loans are maintaining financial capacity and compliance with drinking
water regulations.

Audit of the EPA's Agencywide Management of Grant Workforce

To determine whether the EPA has prepared for and established a grants workforce to
effectively administer annual and supplemental-appropriated programs in accordance with
federal guidance.

Audit of EPA Payment Integrity Information Act Reporting for FY 2022

The objectives are to (1) review the payment integrity section of the Fiscal Year 2022 Agency
Financial Report to determine whether the EPA follows the Payment Integrity Information Act
of 2019, and (2) evaluate the Agency's corrective action plan(s) and efforts to prevent and
reduce improper payments.

Audit of State Subrecipient Monitoring Responsibilities in the State Revolving
Fund Programs

To determine (1) whether states are performing clean and drinking water State Revolving Fund
subrecipient monitoring, as required by the Uniform Guidance, and (2) actions taken by the EPA
if state subrecipient monitoring is deficient.

Audit of the California State Water Resources Control Board's Grant Financial
Management System

To determine whether the California State Water Resources Control Board's financial
management system meets federal standards for oversight of grants.

Audit of Jackson, Mississippi Drinking Water Funding and Spending Decisions12

To identify award and expenditure decisions at the state and local level related to the drinking
water incident in Jackson, Mississippi.

12 This project was announced on November 14, 2022, as Project No. OA-FY23-OQ35, Jackson. Mississippi Drinking
Water Funding and Spending Decisions Project.

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Audit of Single Audit Quality Control Review

To determine whether the single audit conducted by an independent nonfederal entity was
performed in accordance with federal requirements and applicable auditing standards.

Audit of the EPA's Effectiveness of its Use of Special Account Funds

To determine whether the EPA is managing its Superfund special accounts in accordance with
applicable regulations and guidance to increase the funds available for future Superfund
activities.

Audit of the EPA's Management of Small and Rural Wastewater Treatment
Programs

To determine whether the EPA's oversight of state administration of Clean Water State
Revolving Fund loans ensures that small and medium size rural communities have access to
Clean Water State Revolving Fund loans that include provisions to build technical, managerial,
and financial capacity.

Audit of IIJ A Funds Used for Superfund Sites Awaiting Funding

To determine whether the EPA is using funds from the IIJA to begin construction projects at
Superfund sites awaiting funding as required by the Act.

Audit of Statutorily Required vs. Nonstatutorily Required Work

To determine how the EPA's Office of Land and Emergency Management is (1) allocating
funding and staffing resources to accomplish work required by statute or executive order
versus work that is not statutorily required, and (2) considering the costs, benefits, and risks of
conducting nonstatutorily required work.

Audit of EPA FY 2023 and 2022 Consolidated Financial Statements

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

Audit of EPA FY 2022 and 2021 Financial Statements: Hazardous Waste
Electronic Manifest System Fund

To determine whether the EPA's (1) Hazardous Waste Electronic Manifest System Fund
financial statements are fairly presented in all material respects in accordance with generally
accepted accounting principles, (2) internal controls over financial reporting are in place, and

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(3) management has complied with applicable laws, regulations, contracts, and grant
agreements

Audit of EPA FY 2020 and 2019 Financial Statements: Frank R. Lautenberg
Chemical Safety for the 21st Century Act, which amended the Toxic Substances
Control Act

To determine whether the EPA's (1) Toxic Substances Control Act Service Fee Fund financial
statements are fairly presented in all material respects, (2) internal controls over financial
reporting are in place, and (3) management has complied with applicable laws regulations,
contracts, and grant agreements.

Audit of EPA FY 2021 and 2020 Financial Statements: Frank R. Lautenberg
Chemical Safety for the 21st Century Act, which amended the Toxic Substances
Control Act

To determine whether the EPA's (1) Toxic Substances Control Act Service Fee Fund financial
statements are fairly presented in all material respects, (2) internal controls over financial
reporting are in place, and (3) management has complied with applicable laws, regulations,
contracts, and grant agreements.

Audit of EPA FY 2022 and 2021 Financial Statements: Pesticides Registration
Fund

To determine whether the EPA's (1) Pesticide Registration Fund financial statements are fairly
presented in all material respects in accordance with generally accepted accounting principles;
(2) internal controls over financial reporting are in place; (3) management has complied with
applicable laws, regulations, contracts, and grant agreements; (4) the information and manner
of presentation contained in the Management's Discussion and Analysis, and any other
accompanying information, are materially consistent with the information contained in the
principal statements; and (5) the EPA complied with specific provisions of the Pesticides
Registration Improvement Act including the decision time review period requirement.

Audit of EPA FY 2022 and 2021 Financial Statements: Pesticides Reregistration
and Expedited Processing Fund, pursuant to the, Federal Insecticide, Fungicide,
and Rodenticide Act

To determine whether the EPA's (1) Pesticides Reregistration and Expedited Processing Fund
financial statements are fairly presented in all material respects in accordance with generally
accepted accounting principles; (2) the EPA's internal controls over financial reporting are in
place; (3) the EPA's management has complied with applicable laws, regulations, contracts, and
grant agreements; (4) the EPA accurately reported accomplishments under applicable

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performance measured and goals for the Federal Insecticide, Fungicide, and Rodenticide Act;
(5) the EPA complied with specific provisions of Federal Insecticide, Fungicide, and Rodenticide
Act; and (6) the information and manner of presentation contained in the Management's
Discussion and Analysis, and any other accompanying information, are materially consistent
with the information contained in the principal statements.

Ongoing Projects

American Recovery and Reinvestment Act Lessons Learned13

To highlight findings from prior OIG reports of EPA's management of American Recovery and
Reinvestment Act funding to identify lessons that could help inform the EPA's management of
programs funded by the IIJA.

Audit of Pollution Prevention Grants Reporting

To determine whether the EPA accurately reports the environmental results achieved from
pollution prevention grants, and whether those results demonstrate alignment with the goals
established for the program.

Evaluation of Efficiency and Effectiveness of the Great Lakes Restoration
Initiative

To determine whether the EPA's Great Lakes National Program Office is using Great Lakes
Restoration Initiative funds efficiently to accomplish its goals and is effective in protecting and
restoring the Great Lakes in the focus areas included in the Great Lakes Restoration Initiative
Action Plan.

Audit of the EPA's Fiscal Years 2022 and 2021 Consolidated Financial
Statements14

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

13	This project was published on December 7, 2022, as Project No. OA-FY23-OQ35, American Recovery and
Reinvestment Act Findings for Consideration in the Implementation of the Infrastructure Investment and Jobs Act.

14	This report was published on November 15, 2022, as Report No. 23-F-0002, The EPA's Fiscal Years 2022 and 2021
Consolidated Financial Statements.

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Challenge 7: Enforcing Compliance
with Environmental Laws and
Regulations

The seventh challenge, Enforcing Environmental Laws and Regulations, addresses a robust
enforcement program that is vital to deterring regulated entities from violating environmental
laws and regulations and to protecting human health and the environment. From FY 2007
through FY 2022, EPA compliance-monitoring activities, enforcement actions, and most
enforcement results generally declined. Considering its limited resources, the EPA is challenged
to assess its resource requirements for enforcement programs and to identify innovative and
cost-effective means of detecting and deterring noncompliance in the future.

Primary purpose of the enforcement process is to ensure compliance with environmental laws.

v © £ © Ai © © $$ ©

Through guidance and A regulated entity

training, the EPA and

states provide
compliance assistance
to regulated entities.
Compliance assistance

can be provided
throughout the entire
enforcement process.

is required to
follow applicable
environmental
laws and
regulations.

EPA or states
monitor a
regulated entity's
compliance with
environmental laws
and regulations.

Enforcement results

When noncompliance is
found, the EPA or states
can offer compliance
assistance to or pursue
informal or formal

administrative
enforcement actions
against the regulated
entity. The EPA may also
refer cases of
noncompliance to the
U.S. Department of
Justice,

Enforcement actions
produce outcomes, such

as injunctive relief to
compel regulated entities'
return to compliance,
penalties to punish
noncompliance and deter
future noncompliance,
and supplemental
environmental projects to
mitigate the effects of
noncompliance. These
outcomes have monetary
values.

Enforcement actions
also result in the
regulated entity's
return to compliance
and improvements or
benefits to human
health and the
environment.

Source: OIG summary of EPA information. (EPA OIG image)

Planned Projects

4£&

Evaluation of the EPA's Oversight of State Water Monitoring and Assessment
Programs

To determine how effective selected states have been at establishing and executing water
monitoring and assessment programs.

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Evaluation of EPA Oversight of State and Tribal Drinking Water Laboratory
Certification

To determine whether the EPA's oversight has ensured that drinking water laboratory
certification programs meet Safe Drinking Water Act requirements.

Evaluation of the EPA's Oversight of Title V Permit Review and Revisions

To determine whether the EPA efficiently responds to citizen objections to Clean Air Act Title V
permits and ensures states implement any subsequent federally mandated revisions to permits.

Evaluation of Land Use Controls at Resource Conservation and Recovery Act
Corrective Action Sites

To determine the extent to which the EPA verifies that Resource Conservation and Recovery Act
corrective action land use controls remain in place to prevent human exposure and
groundwater contamination at sites where contamination remains in place.

Audit of Implementation of the Clean Air Act Emissions Offset Requirements

To determine how states are implementing emissions offset requirements in accordance with
the Clean Air Act and regulatory requirements for selected sites, and how effective EPA
oversight is in monitoring state compliance for selected sites.

Audit of the EPA's Distribution of American Rescue Plan Funds for Air Quality
Monitoring

To determine whether the EPA's American Rescue Plan grants complied with requirements for
community air pollution monitoring projects that increase the collection of data on air toxics
emissions and access to low-cost air sensors in accordance with the law.

Evaluation of the EPA Response and Oversight Related to Drinking Water
Contamination in Jackson, Mississippi15

To determine the circumstances of, and the EPA's response to, noncompliance with the Safe
Drinking Water Act at the City of Jackson's community water system.

15 This project was announced on November 14, 2022, as Project No. OSRE-FY23-OQ33, Review of EPA Response
and Oversight Related to Drinking Water Contamination in Jackson, Mississippi.

Office of Inspector General FY 2023 Oversight Plan 24


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Audit of Agency Use of Safe Drinking Water Act Section 1431 Emergency Orders

To determine whether the EPA's 2018 Safe Drinking Water Act, section 1431 emergency orders
are being properly invoked in accordance with guidance to protect public health.

Ongoing Projects

Evaluation of EPA Oversight of State Progress to Meet Chesapeake Bay Nutrient-
and Sediment-Reduction Goals

To determine whether the EPA effectively uses the Accountability Framework for overseeing
the Chesapeake Bay Total Maximum Daily Load pollution reduction goals.

Evaluation of Oversight of Hazardous Waste at EPA Laboratories

To determine whether the EPA has verified that its own laboratories are complying with the
Resource Conservation and Recovery Act requirements for the management of hazardous
waste.

Evaluation of EPA Oversight of Drinking Water Contamination at Red Hill,

Hawaii

To determine, by analyzing the sequence of events that led to drinking water contamination at
the Red Hill site on Joint Base Pearl Harbor-Hickam, whether the EPA's oversight of relevant
authorized state programs effectively has addressed the potential for contamination at the site.

Evaluation of Effectiveness of the EPA's Oversight of Testing and Certification
Program for Residential Wood Heaters

To determine whether the EPA effectively uses its oversight and enforcement authority to
ensure that all residential wood heaters reaching consumers are properly tested and certified in
accordance with established standards.

Audit of the EPA's Oversight of State and Local Air Agencies Identification of
SM-80 Facilities

To determine whether EPA's oversight of state and local agencies with large compliance
monitoring programs that identify high-emitting synthetic minor facilities, known as SM-80s, is
in accordance with the EPA's Clean Air Act Compliance Monitoring Strategy.

Office of Inspector General FY 2023 Oversight Plan 25


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Evaluation of the EPA's Handling of Criminal Discovery

To determine whether the EPA's collection, retention, and production of mandatory criminal
discovery material adhered to requirements.

Office of Inspector General FY 2023 Oversight Plan 26


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Challenge 8: Managing Increased
Investment in Infrastructure

Finally, the eighth challenge, Managing Increased Investment

in Infrastructure, addresses the largest infrastructure appropriation in the EPA's history. The
Infrastructure Investment and Jobs Act provided the EPA with an unprecedented $61 billion in
funding to invest in environmental infrastructure improvements. In addition, the Inflation
Reduction Act appropriated another $41.5 billion to fund a range of EPA activities and awards
programs, to include air quality, enforcement, greenhouse gas emissions reduction and
reporting, and environmental justice. With these funds, the EPA will help lead the nation in one
of the largest infrastructure investment programs in our history. This challenge includes
delegating funds to the EPA's partners to improve drinking water, wastewater, and stormwater
infrastructure. The Agency will retain some IIJA funds to increase its workforce and to improve
geographic, Superfund, and recycling programs. The majority of the IIJA funds are available until
they are expended, although the Agency will receive most of the funds over five years (from
FY 2022 through FY 2026). Congress made the Inflation Reduction Act funds immediately
available to the EPA. The appropriation represents a significant increase in the EPA's funding,
and the Agency must effectively manage these funds to achieve the intended results.

Planned Projects ^

Audit of Fiscal Year 2022 Earmarks for Drinking and Clean Water Projects

To determine whether the EPA has adequate procedures, policies, and capacity in place to
administer FY 2022 congressionally directed drinking and clean water projects, also known as
earmarks.

Audit of the EPA's FY 2022 Public Reporting of IIJA Financial and Award Data

To determine whether the EPA's reporting of FY 2022 IIJA obligations and outlays in USA
Spending is complete and accurate.

Audit of EPA Assistance for Drinking Water State Revolving Fund Lead Service
Line and Emerging Contaminants Funding

To determine the extent to which the EPA is collaborating with state revolving fund programs
to share models, guidance, and build capacity to assist local communities to ensure Drinking
Water State Revolving Fund lead service line and emerging contaminants funding is deployed in
accordance with the IIJA and other federal regulations and policies as applicable.

Office of Inspector General FY 2023 Oversight Plan 27


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Developing Projects

Six evaluation projects that address IIJA oversight are currently under development. The
projects will focus on capacity reviews for clean water and drinking water state revolving funds,
including a pulse survey on states' perceptions of their capacity to manage and use IIJA funds.
The OIG will also inspect Superfund sites receiving IIJA funds to ensure their compliance with
public safety-related requirements and later to ensure they are successfully using their IIJA
funds as intended.

Office of Inspector General FY 2023 Oversight Plan 28


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U.S. Chemical Safety and Hazard
Investigation Board

According to the CSB's website, its mission is to "drive chemical safety
change through independent investigations to protect people and the
environment." The CSB investigates industrial chemical accidents at
facilities, reports on the root causes to the public, and recommends
measures to prevent future occurrences. In FY 2004, Congress
designated the EPA's inspector general to serve as the CSB's inspector
general through annual appropriations legislation.

In our report. Fiscal Year 2023 U.S. Chemical Safety and Hazard Investigation Board
Management Challenges, we identify what we consider to be the top three management
challenges for the CSB:

1.	Accomplishment of the CSB's Mission Remains Impaired Until the Full Board Is
Confirmed (initially reported in FY 2019).

2.	Minimizing Mission Critical Staff Vacancies and Attrition Rates.

3.	Improving Cybersecurity Weaknesses.

Planned Projects A

Audit of CSB Payment Integrity Information Act Reporting for FY 202216

To determine whether the CSB complied with the Payment Integrity Information Act in fiscal
year 2022.

Audit of the CSB's Purchase Card Program FY 202217

To assess (1) the effectiveness of the CSB's oversight of its purchase card and convenience
check program, and (2) the risk of any illegal, improper, or erroneous purchases and payments
for fiscal year 2022.

16	This project was announced on December 15, 2022, as Project No. QA-FY23-0041, The EPA Payment Integrity
Information Act Reporting for Fiscal Year 2022.

17	This project was announced on November 21, 2022, as Project No. QA-FY23-0040, Audit of CSB Purchase Card
Prog ram for FY22.

Office of Inspector General FY 2023 Oversight Plan 29


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Audit of the CSB's Compliance with the Federal Information Security
Modernization Act for FY 2023

To determine the CSB's compliance with the fiscal year 2023 inspector general Federal
Information Security Modernization Act of 2014 reporting metrics.

Audit of the CSB FY 2023 and 2022 Financial Statements (Contracted)

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

Ongoing Projects

Evaluation of the CSB's Compliance with the Federal Information Security
Modernization Act for FY 20221S

To assess the CSB's compliance with the U.S. Department of Homeland Security's Fiscal Year
2022 Inspector General FISMA Reporting Metrics.

Audit of the CSB's FY 2022 and 2021 Financial Statements (Contracted)19

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

18	This project was announced on June 14, 2022, as Project No OA-FY22-Q136, Evaluation of CSB's Compliance with
the Federal Information Security Modernization Act of 2014.

19	This report was published on November 15, 2022, as Report No. 23-F-0001, U.S. Chemical Safety and Hazard
Investigation Board Fiscal Years 2022 and 2021 Financial Statement Audit.

Office of Inspector General FY 2023 Oversight Plan 30


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WHISTLE

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's webpage.

For more information about EPA OIG reports or activities, please contact us:
Congressional Liaison: 202.566.2391

IP Media Contact: 202.566.2391

ft© EPA OIG Hotline: OIG_Hotline@epa.gov

Web: epa.gov/oig
Follow us:

Twitter: @epaoig

Linkedln: linkedin.com/company/epa-oig
YouTube : youtube.com/epaoig

CUSTOMER SERVICE * INTEGRITY * ACCOUNTABILITY

Office of Inspector General FY 2023 Oversight Plan 31


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