Semiannual Report to Congress: October 1, 2023-March 31, 2024


Semiannual

Report to Congress:

October 1,2023-March 31, 2024

Published May 2024

OIG Report No. 24-N-0034

EPA Publication No. 350-R-24-001

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Index of Inspector General Act Semiannual Reporting Requirements

Requirement

Subject

Addressed in

Section 5(a)(1)

Description of significant problems, abuses, and deficiencies
relating to programs and operations and associated reports
and recommendations for corrective action

Section 2.1

Section 5(a)(2)

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

Section 1.4 and Appendix 3

Section 5(a)(3)

Summary of significant investigations closed during the
reporting period

Section 2.2

Section 5(a)(4)

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

Section 3.1

Section 5(a)(5)

A list identifying each audit, inspection, or evaluation report
issuing during the reporting period; along with the total value
of questioned costs (to include unsupported costs); total
value of recommendations that funds to put to better use; and
whether a management decision had been made by the end
of the reporting period

Appendix 1

Section 5(a)(6)

Information regarding any management decision made during
the reporting period with respect to an audit, inspection or
evaluation report issued during a previous reporting period

Appendix 2

Section 5(a)(7)

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

Section 1.4

Section 5(a)(8—10)

Information with respect to peer reviews conducted

Appendix 5

Section 5(a)(11—12)

Statistics on investigative reports, referrals, prosecutions, and
indictments

Section 3.1

Section 5(a)( 13)

Information with respect to substantiated investigations
involving senior government employees

Section 2.2 and Appendix 4

Section 5(a)( 14)

Information with respect to instances of whistleblower
retaliation

Section 2.3

Section 5(a)( 15)

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

Section 2.3

Section 5(a)( 16)

Detailed description of closed audits, inspections, and
evaluations, as well as of closed investigations involving
senior employees, not disclosed to the public

Section 2.1 and Appendix 4

Source: Inspector General Act of 1978, as amended.

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Abbreviations

C.F.R.	Code of Federal Regulations

CSB	U.S. Chemical Safety and Hazard Investigation Board

EPA	U.S. Environmental Protection Agency

FY	Fiscal Year

GS	General Schedule

IIJA	Infrastructure Investment and Jobs Act

OIG	Office of Inspector General

Pub. L.	Public Law

U.S.C.	United States Code

Cover Image

From top to bottom: Drinking water from a faucet,
(EPA OIG, EPA OIG, and EPA images, respectively)

business email compromise graphics, and pets.

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

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Washington, D.C. 20460
(888) 546-8740
OIG.Hotline@epa.gov

Learn more about our OIG Hotline.

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1200 Pennsylvania Avenue, NW (241OT)
Washington, D.C. 20460
(202) 566-2391
www.epaoiq.gov

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Message to Congress

For more than a dozen years, the Office of Inspector General's oversight professionals have
faced one seemingly inexorable fact: year after year, our budget has diminished while our
responsibilities increase. Our fiscal year 2024 budget is now lower than it was in fiscal year
2011, while personnel costs have increased by approximately 24 percent and the cost of
goods has increased by an estimated 35 percent. Similarly, the annual assessments from
the Council of Inspectors General on Integrity and Efficiency have more than doubled since
fiscal year 2016. As a result, we are now funded for 128 fewer oversight professionals in
2024 as compared to 2011, a decrease of over 35 percent.

While the OIG decreases, the EPA has increased, seeing its budget effectively increased by nearly 13 percent over
the same time. The Agency's overall topline level in fiscal year 2024 is lower than last year; however, most of the
reduction was to its Superfund program, where new tax collections are intended to help offset the loss. Other
areas of regular EPA activity that require our oversight have shown even greater growth, such as the market for
Renewable Identification Numbers, or RINs, which has seen a nearly 77-percent increase in trading volume
between 2011 and 2023. Practically, this means that we are now asked to oversight more core work with fewer
resources than we had over a decade ago. And this has consequences.

The hallmark of an independent OIG is the ability to exercise discretion in our oversight of the Agency. Diminishing
resources, coupled with a growing portfolio of mandated work, has significantly constrained this exercise of
independence. For example, in fiscal year 2023, approximately half of our audit work was done in response to
statutory or regulatory mandates, congressional requests, or hotline contacts. As another example, our portfolio
of whistleblower retaliation cases is growing at the same time as we are being asked to do more administrative
investigations of senior officials. Not to put too fine a point on it, but smaller OIG appropriations necessarily mean
less oversight of EPA's growing operations.

The irony of an increasingly diminished OIG is that Congress, the Agency, and the American taxpayers are relying
on us now more than ever. For example, last fiscal year, we issued a report on residential wood heaters, which
identified more than $80 million in potential waste and increased potential health risks because the EPA failed to
provide reasonable assurance that wood heaters are properly tested and certified before reaching consumers.
After our report's issuance, a bipartisan coalition of state attorneys general sued the EPA, alleging that it failed to
revise standards for air pollution from wood heaters. And in Senate Report 118-83, the Senate specifically cited
our report in directing the EPA to increase its staffing and other required efforts to support the wood stove
certification and testing program. But most striking of all is that, as illustrated in the figure below, the OIG is a
sound investment of American tax dollars. During the first half of this fiscal year, we have already identified $120.1
million in total monetary benefits.

The benefit of our work extends beyond the dollars and cents of fraud, waste, and abuse. Because the EPA's
mission is to protect human health and the environment, it is our mission to help the EPA do this more efficiently
and effectively. For example, in response to multiple hotline complaints alleging that Seresto pet collars harmed
family pets, we conducted an evaluation that concluded that the Agency's response to these reported incidents
has not provided assurance that Seresto collars can be used without unreasonable risk to pet health. As another

W'xM

Sean W. O'Donnell

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example, we initiated an audit in response to a hotline complaint alleging that New York City has failed to construct
two combined sewer overflow tanks at the Gowanus Canal Superfund site in a timely manner and that the EPA
has failed to enforce administrative orders requiring the city to do so. We identified several factors that led to a
1,300-percent cost increase and 6.5-year schedule delay in the construction of the tanks, prolonging community
exposure to pollutants that may cause cancer and other health effects.

During the semiannual

reporting period,
OIG work resulted in:

fe)

21
reports*

recommendations
for improvement*

\ 5,440 hotline
contacts handled

OIG investigative work
resulted in:

25 indictments, informations,
and complaints

©



3 criminal convictions

3 civil actions, including
2 settlements and
1 restitution/
reimbursement / recovery

22 administrative actions,
including suspensions and
disbarment actions

* This includes reports that were conducted in compliance with Quality Standards for
Inspection and Evaluation or generally accepted government auditing standards, as well
as reports that did not follow either standard. This excludes peer review reports,
management implication reports, IIJA progress reports, management challenges reports,
oversight and priority plans, and the semiannual report.

Based on OIG work,
the EPA and the CSB:

Identified $120.07 million
in potential monetary benefits

Conducted investigations that
resulted in $1.29 million in fines,
penalties, and restitutions

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

I&lll Implemented 74 policy, practice,
or process changes or decisions

| Avoided $149,469 in costs
based on the implementation
of recommendations or
on investigative results

Our robust efforts to oversee the EPA's more than $60 billion in funds from the Infrastructure Investment and
Jobs Act, or IIJA, demonstrate the level of oversight we can provide when properly funded. During this semiannual
period, we published six IIJA-related reports, including an evaluation of the Drinking Water State Revolving Fund
Program that could help the EPA ensure efficient stewardship of tens of billions of taxpayer dollars. We also issued
two reports related to the EPA's $5 billion Clean School Bus Program, an audit describing how potential utility
delays could impact the program and a management implication report sharing our concerns that the EPA's lack
of verification mechanisms within the program's rebate and grant application process increases risk for fraud,
waste, and abuse. Another audit found that the EPA did not include any of its IIJA outlays in the fiscal year 2022
obligations and outlays it reported on USAspending.gov. Moreover, our agents and auditors have provided more
than 350 fraud awareness briefings, reaching thousands of EPA staff members, potential grant recipients, and
state environmental agencies, among other stakeholders.

Unfortunately, the OIG was not funded to conduct similar oversight of the $45 billion that the EPA received from
the Inflation Reduction Act. Through the Greenhouse Gas Reduction Fund, one of the IRA's signature programs,
the EPA will award $20 billion to eight nonprofit organizations known as "green banks," many of which were
formed after the IRA was enacted. These recipients will use IRA funds to provide, among other things, an array of
complex financial products, such as loan guarantees, credit enhancements, and equity investments. The
potentially dire consequences of the lack of IRA oversight cannot be overstated. As I have stated in testimony
before Congress, the EPA is directing billions of new dollars through novel programs to newly created recipients.

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To oversight the ambitious effort to mobilize financing and private capital to slash greenhouse gas emissions, the
OIG would need professionals focused on oversighting financial institutions, underwriting and risk management
standards, and consumer financial protection.

The EPA has made clear in testimony before Congress that it sees the OIG as an indispensable partner in ensuring
that IRA funds are spent appropriately and that IRA-funded programs meet statutory and regulatory
requirements. The Agency's reliance on unfunded oversight is especially concerning here because the EPA has
described the office responsible for managing the Greenhouse Gas Reduction Fund as having minimal viable
organizational staffing. While the OIG has risen—and will continue to rise—to fulfill our mission, we have reached
the limits of our funding just as the EPA has entered its period of greatest risk. We have a long-standing body of
work identifying issues with how the Agency manages its annual appropriations effectively and efficiently. The
danger of fraud, waste, and abuse in EPA programs and operations is greater now than ever.

As we move forward in fiscal year 2024, our goal remains to accomplish as much as possible with every oversight
dollar we receive. I am immensely proud of the dedicated staff of the EPA OIG for their relentless efforts to
continue doing more with less, accomplishing vital work that safeguards Americans and preserves their hard-
earned taxpayer dollars. Their work has been recognized by Congress, featured in the public square, and relied
upon by the Agency and others to improve human health and safety. However, we anticipate more challenges
ahead, given the growing need for independent oversight and languishing funds for doing it. I implore Congress
to increase the OIG's core funding in future budgets to ensure effective and independent oversight at this most
crucial of times and enable us to scale our oversight with the EPA's expanded programs and operations. I also ask
Congress to provide the OIG with supplemental funding to perform desperately needed oversight of the EPA's IRA
work. As I testified before Congress in 2023, over the past 10 years, the funding for oversight represented
approximately one-half of a penny for every dollar the EPA spent. In return, over that same period, the OIG yielded
a return of over 300 percent to American taxpayers. Imagine the return on investment we could provide with
funding proportionate to the enormous task before us.

Sean W. O'Donnell
Inspector General

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Table of Contents

Section 1: Overview	1

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

1.2	OIG Strategic Planning	4

1.3	The OIG's "Year of Fighting Fraud"	6

1.4	Analysis of Unimplemented Recommendations	8

1.5	The OIG Hotline	10

1.6	Scientific Integrity and Misconduct	13

1.7	Oversight Overtures: Working Together to Detect and Prevent Fraud, Waste, and Abuse.... 16
Section 2: Work Accomplished During the Semiannual Period	18

2.1	Oversight Work	19

2.2	Investigative Work	37

2.3	Instances of Whistleblower Retaliation and Interference with Independence	44

Section 3: Statistical Data	45

3.1 Summary of Investigative Results	46

Appendixes	49

1	Reports Issued	50

2	Management Decisions Relating to Reports Issued During Previous Reporting Periods	54

3	Reports with Corrective Action Not Completed	57

4	Closed Investigations Involving Senior Employees	75

5	Peer Reviews Conducted	76

6	OIG Contact Information	77

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Section 1: Overview

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

1.1 About the EPA, the CSB, and the OIG

The U.S. Environmental Protection Agency

The mission of the U.S. Environmental Protection Agency is to protect human health and the
environment. To carry out this mission, the EPA develops and enforces regulations, provides grants,
researches environmental issues, sponsors partnerships, educates people about the environment, and
publishes information about its activities.

The U.S. Chemical Safety and Hazard Investigation Board

The U.S. Chemical Safety and Hazard Investigation Board is an independent federal agency that investigates
chemical incidents to determine the cause or probable cause. The CSB's mission is "to drive chemical safety
excellence through independent investigations to protect communities, workers, and the environment."

The EPA Office of Inspector General

The Office of Inspector General is an independent office in the EPA that detects and prevents fraud,
waste, and abuse to help the Agency protect human health and the environment in a more efficient and
cost-effective manner. The office was created pursuant to the Inspector General Act of 1978, as
amended, 5 U.S.C. §§ 401-424. Since 2004, Congress has designated the EPA inspector general to also
serve as the CSB inspector general. The EPA OIG has the responsibility to audit, evaluate, inspect, and
investigate EPA and CSB programs and operations, as well as to review proposed laws and regulations to
determine their potential impact on these programs and operations.

Our Vision

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

Our Mission

Conduct independent audits, evaluations, and investigations; make evidence-based recommendations
to promote economy, efficiency, and effectiveness; and prevent and detect fraud, waste, abuse,
mismanagement, and misconduct for the EPA and the CSB.

Our Goals

1. Contribute to improved EPA and CSB programs and operations protecting human health and the
environment and enhancing safety.

2. Conduct audits, evaluations, and investigations that enable the EPA and the CSB to improve
business practices and accountability.

3. Improve OIG processes, resource allocation, and accountability to meet stakeholder needs.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Our People

Our staff consists of auditors, program analysts, investigators, social scientists, and other professionals.
We are based in Washington, D.C., and in a dozen other cities across the country, as shown in Figure 1.
With staff throughout the United States, we can quickly begin oversight in response to environmental
emergencies and can ensure continuity of operations.

Figure 1: OIG office locations

Seattle

Chicago

San Francisco

°Denver

o

Cincinnati

0 Boston
oNYC
"Philadelphia

Kansas City

®RTP

°Atlanta

Dallas

Note: DC = District of Columbia; NYC = New York City; RTP = Research Triangle Park.
Source: OIG office data. (EPA OIG image)

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

1.2 01G Strategic Plannin

The OIG's strategic planning documents guide us as we design and execute audits, evaluations, and
investigations. When determining which audits, evaluations, and investigations to undertake, we
consider the top management and performance challenges facing the EPA and the CSB. We also consider
how our oversight work supports the EPA's and the CSB's mission-related efforts. Some of our work is
required by law, some is discretionary, and some follows up on the corrective actions that the EPA and
CSB have implemented to verify their responsiveness to prior OIG recommendations. In this semiannual
report, we identify which top management challenges our audits and evaluations address, as applicable,
next to the following symbol: @. We also identify what aspect of the Agency's mission each report
addresses (£* ); whether the work was statutorily mandated (1&) or a follow-up project (ft) ; and
whether we provide supplemental materials for each report, such as a video or podcast ((¥)).

Top Management Challenges

The Reports Consolidation Act of 2000 requires each inspector general to prepare an annual statement
summarizing what the inspector general considers to be "the most serious management and performance
challenges facing the agency" and to briefly assess the agency's progress in addressing those challenges.

EPA Top Management Challenges

Report No. 24-N-0008 | Issued November 15, 2023 |

For FY 2024, we identified seven top management challenges facing the EPA. We retained five of the
eight challenges we identified in FY 2023, albeit with some modifications, while we revised and
combined the three other FY 2023 challenges to create two new challenges.

The EPA's FY 2024 Top Management Challenges

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

2. Integrating and implementing environmental justice.

3. Safeguarding the use and disposal of chemicals.

4. Promoting ethical conduct and protecting scientific integrity.

5. Managing grants, contracts, and data systems.

6. Maximizing compliance with environmental laws and regulations.

7. Overseeing, protecting, and investing in water and wastewater systems.

CSB Top Management Challenges

Report No. 24-N-0010 | Issued December 6, 2023 | J^(4)

For the management challenges facing the CSB in FY 2024, we retained the three that we identified in
FY 2023 and added a fourth: promoting ethical conduct.

The CSB's FY 2024 Top Management Challenges

1. Operating effectively without a full board.

2. Minimizing mission-critical staff vacancies and attrition rates.

3. Improving cybersecurity.

4. Promoting ethical conduct.

Statutorily Required. (I) Podcast.
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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Fiscal Year 2024 Oversight Plan

Report No. 24-N-0015 | Issued January 17, 2024

The Fiscal Year 2024 Oversight Plan describes the planned and ongoing oversight projects we intend to
conduct during the fiscal year to achieve our mission, as of December 31, 2023. We outline 71 projects
for oversight of the EPA and five projects for oversight of the CSB; however, our plan is subject to
change based on our identification of emerging risks and new priorities. We typically accomplish our
oversight mission through audits, evaluations, and investigations related to EPA and CSB programs and
operations, as required by law or as we deem necessary through our planning processes.

Office of Investigations Overview and Investigative Priorities

Report No. 24-N-0016 | Issued January 17, 2024 | (1)

Our Investigative Priorities document describes the primary areas of focus for our Office of Investigations.
We identified four investigative priorities for FY 2024: environmental infrastructure, grant fraud, program
fraud, and laboratory fraud. These priorities are subject to change as new challenges and risks evolve and
emerge. To identify these investigative priorities, we considered the top management and performance
challenges facing the EPA and the CSB; the missions of these two agencies; the budgetary priorities set
forth by Congress; observations from previous investigative work; emerging vulnerabilities in the drinking
and wastewater sectors; and projects being planned or funded through the American Rescue Plan Act, the
Infrastructure Investment and Jobs Act, and the Inflation Reduction Act.

Infrastructure Investment and Jobs Act Oversight Plan—Year Two

Issued April 2023 | Year Three underdevelopment

The Infrastructure Investment and Jobs Act, or IIJA, Pub. L. 117-58 (2021), provides the EPA with
approximately $60 billion for infrastructure-related purposes, including geographic programs, state and
tribal assistance grants targeting clean-water initiatives, brownfields, Superfund, pollution prevention,
and recycling. The EPA OIG has received IIJA funds that will allow us to perform dedicated oversight of
the EPA's execution of IIJA programming for over ten years. In our IIJA Oversight Plan—Year Two, we
built upon our inaugural IIJA Oversight Plan to guide our audits, evaluations, and oversight engagements
in this semiannual reporting period, so that we provide effective oversight of EPA programs receiving or
impacted by IIJA funds.

In this semiannual reporting period, as detailed in Section 2 of this report, we produced an IIJA Progress
Report that highlights our efforts to implement the IIJA Oversight Plan. We will continue to revise our
IIJA Oversight Plan in response to emerging challenges, crises, and priorities.

The OIG's Fiscal Year 2024-2028 Strategic Plan

Under development

This semiannual period, we continued work on our next Strategic Plan. Our previous Strategic Plan
covered FY 2019 through FY 2023. The new Strategic Plan will document our inspector general's
five-year vision and the OIG's mission.

Statutorily Required. (I/Podcast.
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Semiannual Report to Congress

October 1, 2023-March 31, 2024

1.3 The OIG's "Year of Fighting Fraud"

With the January 2024 issuance of our Fiscal Year 2024 Oversight Plan and Investigative Priorities
document, we kicked off the new year with an oversight campaign dubbed the "Year of Fighting Fraud."
By partnering our annual oversight plan with a set of robust investigative priorities, we set the stage for
the EPA OIG to be the premier fraud-fighting organization in the environmental and chemical safety
space. Guided by the top management challenges that we identified for the EPA and CSB in FY 2024,
these documents work in harmony to emphasize oversight of specific areas where American taxpayer
funds are at greatest risk or where the integrity of EPA or CSB programs is significantly endangered.

In FY 2024, we continued our efforts to oversee the influx of approximately $60 billion in supplemental
appropriations under the IIJA, much of which will be distributed as grants. Inspector General Sean W.
O'Donnell explained that our new campaign will be a significant driver of our IIJA oversight work:

"Having spent these last two years focusing on preventing fraud, waste, and abuse in EPA programs
receiving IIJA funds, it is now time for us to turn toward detecting fraud, waste, and abuse. This is why I
declared 2024 our 'Year of Fighting Fraud.' In the next year, and beyond, we expect to dedicate
significant effort to ensuring that the EPA uses its infrastructure funds efficiently and effectively."

Beyond the environmental infrastructure realm, we are focusing our fraud-fighting capabilities on
three other priorities: grant fraud, program fraud, and laboratory fraud. A significant element of our
efforts to fight fraud in these areas is educating EPA stakeholders—from employees to contractors, from
state and local governments to U.S. citizens—on how to detect fraud and what to do when they believe
they have identified potential wrongdoing.

Fraud Alert and "Fraudcast"

In February 2024, we issued a Fraud Alert and an associated podcast, which we refer to as a "Fraudcast,"
to highlight an increasingly common and costly form of cybercrime known as business email
compromise. In this sophisticated scheme, criminals use fraudulent emails that appear to come from
known and trusted sources to target employees of organizations, like the EPA and the CSB, that make or
receive financial transactions. By impersonating representatives of trusted sources, criminals deceive
employees into providing access to funds or sensitive information.

In the Fraud Alert and Fraudcast, we provide several suggestions to protect organizations from a
business email compromise, including creating organizational policies for receiving new payments,
employing security systems that can detect compromise attempts, using two-factor authentication to
combat account compromise, and regularly training staff on cybersecurity best practices. We also refer
people to the proper points of contact if they believe they have been a victim of business email
compromise.

To ensure that we reached as many EPA and CSB stakeholders who may be affected by this scheme as
possible, we shared this alert directly with state revolving fund managers, who serve as pass-through
vehicles for EPA funds for local water improvement projects and thus oversee frequent financial

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

transactions. We also collaborated with the EPA Office of Grants and Debarment, which distributed the
fraud alert via its public listserv that many grant recipients and applicants subscribe to.

We are committed to keeping EPA and CSB stakeholders informed concerning cyberattacks or schemes
that could affect them. As we identify possible fraud mechanisms, we will continue to issue alerts and
Fraudcasts as part of our fraud-fighting posture.

Fraud Awareness Briefings

During this semiannual reporting period, we also continued our proactive outreach efforts by providing
49 fraud awareness briefings to more than 3,000 attendees across the country. Specifically, our
Investigations staff provided fraud awareness briefings to the Bureau of Indian Affairs 2023 Provider's
Conference; the Tampa Bay Environmental Crimes Task Force; the EPA Office of Research and
Development and Office of Water's Small Drinking Water Systems Webinar Series; the Iowa Water
Environmental Association; the EPA's On-Scene Coordinator Readiness Training; the Oklahoma
Department of Environmental Quality's Division of Water and State Revolving Fund Program; the Council
of Inspectors General on Integrity and Efficiency's IIJA Working Group Data Summit; the Chicago Area
Environmental Task Force; the Alaska Police Chiefs Quarterly Meeting; and the Mobile, Alabama,
Environmental Crimes Task Force.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

1.4 Analysis of Unimplemented Recommendations

OIG audits and evaluations provide recommendations to improve EPA or CSB programs and operations.
The EPA, the CSB, and the public benefit from the implementation of these recommendations, which
address a range of human health, environmental, and business issues. This semiannual period, we
issued a compendium that provided an in-depth analysis of all open and unresolved recommendations
issued by the OIG to the EPA. The compendium also identified high-priority open and unresolved
recommendations. These critical recommendations have a high dollar value, are high visibility or high
impact, or have been open and unresolved for a long time and should be addressed promptly.

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

• Unresolved. The EPA or the CSB disagrees with the recommendation or did not provide a
formal, complete written response to the recommendation, or the OIG disagrees that the
Agency's proposed corrective actions are responsive to the recommendation.

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

• Completed. The EPA or the CSB and the OIG agree upon the recommendation and proposed
corrective actions, and the EPA or the CSB has fully completed them. These recommendations
are also called closed recommendations.

Section 5(a)(2) of the Inspector General Act, 5 U.S.C. § 405, as amended by the James M. Inhofe National
Defense Authorization Act for Fiscal Year 2023, requires that we identify each recommendation described
in previous semiannual reports for which corrective action has not been completed, including the
potential cost savings associated with the recommendation.1 We interpret potential cost savings to be the
total of questioned costs plus funds to be put to better use. For this semiannual report, we analyzed
actions taken by the EPA and the CSB regarding recommendations described in past reports, and we
identified those that remained unimplemented as of March 31, 2024: 81 for the EPA and zero for the CSB.
Figure 2 shows when these unimplemented recommendations were originally issued to the EPA. As shown in

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

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Table 1, the potential cost savings of the 81 recommendations issued to the EPA are approximately
$74.5 million.

Figure 2: Number of unimplemented recommendations by fiscal year issued

28	28

5



















1

2

2

n

¦ l



l ¦





2008-2016 2017 2018 2019 2020 2021 2022 2023

Source: OIG analysis of OIG reports issued before the current reporting period. (EPA OIG image)

Table 1: EPA and CSB unimplemented recommendations

Agency

Number of unimplemented
recommendations

Potential cost savings associated with
unimplemented recommendations ($)

EPA

81

74,507,000

CSB

0

0

Total

81

74,507,000

Source: OIG analysis of OIG reports issued before the current reporting period. (EPA OIG table)

Table 2 breaks down the 81 unimplemented recommendations issued to the EPA according to their
potential health, environmental, and business benefits and their associated potential cost savings if the
EPA implements the recommendations. Appendix 3 includes the full text of the unimplemented
recommendations, including the potential cost savings for each recommendation.

Table 2: EPA unimplemented recommendations

Category

Number of
unimplemented
recommendations

Potential cost savings
associated with unimplemented
recommendations ($)

Administrative and Business Operations

16

46,707,000

Human Health and Environmental Issues

65

27,800,000

Total

81

74,507,000

Source: OIG analysis of OIG reports. (EPA OIG table)

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

9

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

1.5 The OIG Hotline

The Inspector General Act, 5 U.S.C. § 420, requires each OIG to maintain a direct link on the homepage of
its website for individuals to report fraud, waste, and abuse. Individuals may also report complaints to
the EPA OIG via telephone, email, and postal mail. We refer to these means of receiving information
collectively as the "OIG Hotline." The purpose of the hotline is to receive complaints, including
whistleblower disclosures, of fraud, waste, or abuse in EPA and CSB programs and operations, including
mismanagement or violations of laws, rules, or regulations by Agency employees or program participants.
The OIG also encourages people to use the hotline to submit suggestions for assessing the efficiency and
effectiveness of Agency programs. Anyone may submit complaints and suggestions, including EPA and
CSB employees, participants in EPA and CSB programs, Congress, organizations, and the public. As a
result of these contacts, the OIG may conduct audits, evaluations, and investigations. In Section 2.1, we
summarize the work based on hotline contacts concluded during this semiannual reporting period.

Hotline Statistics

The figures below detail the number and types of contacts that the hotline received and referred for
review by OIG investigation, audit, and evaluation staff; EPA program offices; and other government
agencies during this semiannual period and this fiscal year. In this semiannual period, of 5,440 contacts
received, the OIG made 667 referrals. A contact can be referred to more than one entity. We refer
contacts unrelated to potential fraud, waste, abuse, misconduct, or mismanagement but related to an
Agency program or operation to the appropriate EPA or CSB office. As applicable, we attempt to refer
contacts unrelated to the EPA or the CSB to another government agency. More information about our
hotline operations can be found on our website.

Figure 3: Hotline contacts received from October 1, 2023, through March 31, 2024

IS]

4,875

565

1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000

Source: OIG Hotline data. (EPA OIG image)

Figure 4: Hotline contacts referred from October 1, 2023, through March 31, 2024

17 to other fed, state, local offices

351 to EPA program offices

^ 1

299 to OIG offices

50 100 150 200

250

300 350 400 450

Source: OIG Hotline data. (EPA OIG image)

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Figure 5: Hotline referrals to OIG offices by category from October 1, 2023, through March 31, 2024

Individuals who contact the hotline are not required to identify themselves and may request anonymity
or confidentiality when submitting allegations. However, the OIG encourages those who report
allegations to identify themselves so that they can be contacted if the OIG has additional questions.
Pursuant to the Inspector General Act, 5 U.S.C. § 407, the OIG will not disclose the identity of an EPA or
CSB employee who provides information, including whistleblower disclosures, unless that employee
consents or the inspector general determines that such disclosure is unavoidable during the course of an
investigation. As a matter of policy, the OIG will provide comparable protection to employees of
contractors, grantees, and others who make a complaint or provide information to the OIG and request
confidentiality. Also pursuant to the Inspector General Act, 5 U.S.C. § 420, the OIG will not disclose the
identity of an individual who provides information via the OIG's online complaint form unless the
individual consents or the inspector general determines that such disclosure is unavoidable during the
course of an investigation. This protection applies to anyone submitting information via the online
complaint form, regardless of whether the individual is an EPA or CSB employee. Individuals concerned
about confidentiality or anonymity with regard to electronic communication may submit allegations by
telephone or regular mail.

Source: OIG Hotline data. (EPA OIG image)

Hotline Confidentiality

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

To report potential fraud, waste, abuse,
misconduct, or mismanagement,
contact the OIG Hotline:

Online

Hotline complaint form

Email

OIG.Hotline@epa.gov

Phone

(888) 546-8740

Mai!

Environmental Protection Agency
Office of Inspector General
1200 Pennsylvania Avenue, NW
Mail Code: 2410T
Washington, D.C. 20460

WHISTLE

BLOWING "v ^

Want to talk about it?

To reach the EPA whistleblower protection coordinator, contact:

Email

whistleblower protection(5)epa.gov

Phone

(202)566-1513

12

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

1.6 Scientific Integrity and Misconduct

Scientific integrity at the EPA helps ensure that the science conducted, communicated, and used across
the Agency is of the highest quality. Scientific integrity is crucial because it safeguards science to ensure
that it is objective and rigorous. In November 2021, the OIG identified scientific integrity as a top
management challenge for the EPA, and it continues to be a top management challenge for the Agency
in FY 2024.

The EPA issued its Scientific Integrity Policy in February 2012. The policy sets the expectation for all EPA
employees to represent the Agency's scientific activities clearly, accurately, honestly, objectively,
thoroughly, without political or other interference, and in a timely manner, consistent with their official
responsibilities. It also sets the expectation that all EPA employees will report policy breaches. The EPA's
Scientific Integrity Program consists of the EPA's scientific integrity official, deputy scientific integrity
officials from each of the EPA's program and regional offices, and program staff who support
implementing the Scientific Integrity Policy.

"Science is the backbone of the EPA's decision-making. The Agency's ability to pursue its mission to
protect human health and the environment depends upon the integrity of the science on which it
relies. The environmental policies, decisions, guidance, and regulations that impact the lives of all
Americans every day must be grounded, at a most fundamental level, in sound, high quality science."

—Scientific Integrity Policy. Section II

The OIG has a critical role in protecting the Agency's scientific integrity. As an independent office, the
OIG can receive complaints of mismanagement, misconduct, abuse of authority, or censorship, including
those related to "scientific misconduct" or "research misconduct." Such misconduct includes fabrication,
falsification, or plagiarism in proposing, performing, or reviewing research or reporting research results.
Through its statutory mandate, the OIG can investigate these allegations. Also, the OIG may refer
scientific integrity allegations that it receives to the scientific integrity official. The scientific integrity
official and OIG staff meet every two weeks to discuss the status of cases, as appropriate, as well as
other scientific integrity-related issues.

To facilitate transparency, we continue our practice, started in our Semiannual Report to Congress in the
fall of 2020, of providing a summary of scientific integrity oversight at the Agency. The following
subsections report the status of scientific integrity allegations received by the scientific integrity official
and scientific misconduct allegations received by the OIG.

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

The EPA's Scientific Integrity Program engages with Agency staff who raise potential scientific integrity
concerns through two mechanisms: (1) advice and assistance to provide early intervention for the
purpose of preventing lapses in scientific integrity and (2) a procedure for reporting and adjudicating
allegations.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

This semiannual period, the scientific integrity official reported that the Scientific Integrity Program
received one new allegation and 20 new advice queries. Also, during this semiannual period, no
allegations were closed or resolved. As of March 31, 2024, there was one open allegation from this
semiannual reporting period and 26 open allegations from prior reporting periods.

Scientific Misconduct Allegations Received and Investigated
by the OIG

At the beginning of the semiannual period, the OIG had eight open cases involving potential scientific
misconduct. The OIG received four complaints with allegations involving potential scientific misconduct
from Agency employees and other sources during this semiannual period and opened two new
investigations. As of March 31, 2024, two investigations were closed. The OIG had one relevant result of
investigation that it conducted or oversaw to report to the Agency for a determination of appropriate
action. We detail this result in Section 2.2 in the "Lab Co-Owner Debarred for Reporting False Test
Results" writeup in the "Open Significant Investigations" subsection.

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

• Public health or safety being at risk.

• Agency resources or interests being threatened.

• Circumstances in which research activities should be suspended.

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

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

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

• Circumstances in which the research community or public should be informed.

Additionally, EPA Manual 6500, Functions and Activities of the Office of Inspector General, states, "[e]ach
employee is responsible for promptly reporting indications of wrongdoing or irregularity to the OIG and
for cooperating and providing assistance during any audit or investigation." Coordination procedures
between the scientific integrity official and the OIG, which specify how the OIG and the Agency will work
together to share information and investigate research misconduct, state that upon receiving a research
misconduct allegation, the scientific integrity official will refer the allegation to the OIG Hotline.

Likewise, if the OIG receives an allegation of research misconduct, OIG staff will contact the scientific
integrity official to discuss the allegation, as appropriate. As noted above, the scientific integrity official
and OIG staff also meet every two weeks to discuss the status of cases, as appropriate, as well as other
scientific integrity-related issues.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

In FY 2022, the OIG initiated discussions with the Agency to revise the coordination procedures between
the OIG and the Agency's Scientific Integrity Program related to information sharing on scientific
integrity. In June 2022, the OIG presented revised coordination procedures to the Agency that would
ensure that complaints involving scientific integrity, as well as other misconduct, were promptly
disclosed to the OIG. In August 2023, the Agency provided revisions to the OIG's revised coordination
procedures. In January 2024, the OIG met with the Agency to discuss its concerns with the Agency's
revisions, including the removal of language addressing allegations of interference and censorship by
senior Agency employees, as well as allegations of other employee misconduct. The OIG has agreed to
provide a written overview of its concerns to the Agency.

Since the beginning of FY 2023, the OIG has had to issue monthly information requests to the Agency's
Scientific Integrity Program to ensure that the OIG is receiving all relevant information on potential
scientific integrity concerns. In January 2024, the Agency agreed to provide this information to the OIG
without the need for a formal information request for a period of six months while the OIG and the
Agency work to finalize the revised coordination procedures. Revised coordination procedures are
essential to clarify the OIG's access rights and to ensure that scientific integrity concerns, as well as
allegations of other wrongdoing, are routed to the proper office and addressed in the most efficient and
effective manner.

15

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

1.7 Oversight Overtures: Working Together to Detect
and Prevent Fraud, Waste, and Abuse

Our office aims to help the EPA achieve its mission as efficiently and effectively as possible and to
prevent and detect waste, fraud, and abuse of taxpayer dollars. While independence is the cornerstone
of our work, we rely upon the EPA to provide transparency and access to enable effective oversight. To
that end, it is paramount that our organizations work collegially to facilitate open and honest
communication. In this semiannual reporting period, the EPA OIG and the EPA took great strides to
jointly foster a positive working relationship, both hosting and participating in each other's educational
events intended to amplify understanding and dialogue.

OIG Participation in the EPA's Audit Summit

On October 17, 2023, the OIG participated in the EPA's first-ever Audit Summit, which was hosted by the
EPA Office of the Chief Financial Officer to provide EPA management a chance to engage with and learn
more about the OIG and its oversight processes.

"There are always opportunities for improvement in communication, for improvement in understanding
of how we work, how our work impacts you all," then-Acting Deputy Inspector General Nicole N. Murley
said in her opening remarks to the nearly 200 attendees. "Exchanges like today help us improve our
products in terms of accuracy, effectiveness, relevancy, and timeliness."

As part of the event, a panel comprising two assistant inspectors general and the EPA controller
answered questions about the OIG's process for audits and evaluations. The discussion emphasized the
importance of communication, coordination, and transparency throughout the duration of each
oversight project. The panel also helped clarify key differences between the types of reports the OIG
produces, including audit reports, evaluation reports, management alerts, and lessons-learned reports.

EPA Participation in the OIG's Winter Symposium

For the OIG's second annual symposium, which was held from December 4 through December 6, 2023,
at OIG headquarters with virtual participation by the OIG regions, we invited EPA officials from across
the organization to provide their insight into not only the Agency's past, present, and future initiatives
but also how it is structured to carry out its responsibilities. The vision was for OIG staff to become more
familiar with the organization we are tasked with overseeing and to then use that knowledge to effect
meaningful change via our audits, evaluations, and investigations.

From the EPA chief of staff to representatives from various Agency program offices, the OIG learned
about the EPA's history up through its most recent program priorities, including its IIJA- and IRA-funded
initiatives. In breakout sessions held over the course of the symposium, EPA staff delved into specific
topics related to our oversight projects. For example, we learned about the preaward and postaward
oversight work the Office of Grants and Debarment conducts to administer grants, as well as the
Pesticide Program's initiatives to comply with the Endangered Species Act, implement the Endocrine

16

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Disruptor Screening Program, and regulate pet collars. The Office of Water provided unique insights into
requirements in the American Iron and Steel Act and Buy America, Build America Act. We learned about
the Environmental Justice program's comprehensive community support program, while the Office of
Land and Emergency Management discussed the various environmental laws and regulations related to
Superfund, and the Office of Homeland Security detailed the cybersecurity and physical-security
landscapes of the water and wastewater sectors.

Both of these events—the EPA's Audit Summit and the OIG's Winter Symposium—helped strengthen
the foundation for meaningful and effective professional relationships and information sharing to aid
our fight against fraud, waste, and abuse.

17

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Section 2: Work Accomplished During the

Semiannual Period

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

2.1 Oversight Work

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

Infrastructure Investment and Jobs Act

The IIJA was signed into law on November 15, 2021. Overall, the ILIA appropriates approximately
$60 billion to the EPA for FY 2022 through 2026, most of which is available until expended. The I IJ A also
provides for OIG oversight of these funds. To keep the public apprised of our I IJ A oversight work, we
maintain a webpage. "EPA OIG Infrastructure Investment and Jobs Act Oversight." The webpage
features our EPA IIJA spending dashboard, links to our IIJA Oversight Plan and IIJA Progress Reports,
and lists our ongoing and completed infrastructure oversight work.

Infrastructure Investment and Jobs Act Progress Report—Year Two

Report No. 24-N-0026 | Issued March 7, 2024

Our Year Two progress report provides an overview of the IIJA oversight work that we completed from
early 2023 through January 31, 2024, which focused on grants management, clean school bus funding,
and unspent obligations for programs receiving IIJA funds. As of January 31, 2024, we had 19 IIJA
projects ongoing and ten in the planning phase. Also, we updated our IIJA oversight webpage in
August 2023 to allow users to view IIJA funding by program and location receiving the funds, as well as
the status of our planned, ongoing, and completed IIJA oversight projects.

Fisol Year 2024 Agency Breakdown

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£*,Mission-Related Effort.

Top Management Challenge.
19

Statutorily Required. (J) Podcast,

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

IIJA Investigative Work

Table 3 highlights the IIJA investigative work that we undertook this semiannual reporting period.

Table 3: IIJA-related investigative activity

Investigative activity

Number of cases

Cases open as of October 1, 2023

Cases opened during period

Cases closed during period

Cases open as of March 31, 2024

Source: OIG investigations. (EPA OIG table)

Management Implication Report: Preventing Fraud, Waste, and Abuse Within the
EPA's Clean School Bus Program

Report No. 24-N-0013 | Issued December 27, 2023

The EPA did not have robust verification mechanisms within the Clean School Bus rebate and grant
application process, which led to third parties submitting applications on behalf of unwitting school
districts, applicants not being forthright or transparent, entities self-certifying applications without
corroborating documentation, and entities being awarded funds despite violating program
requirements. We did not issue any recommendations in this report, but we provided several measures
for improvement for the Agency's consideration, including requiring applicants to provide supporting
documentation, establishing an application-validation regimen, requiring rebate and grant recipients to
maintain a documentation archive, highlighting criminal penalties in the application process, requiring
signed and notarized attestations and certifications, and increasing oversight of third-party vendors.

IIJA Audit and Evaluation Work

The EPA Clean School Bus Program Could Be Impacted by Utility Delays

Report No. 24-P-0012 | Issued December 27, 2023 | |

Improving air quality; Operating efficiently and effectively.

There were no significant supply chain issues or production delays that
impacted the EPA's efforts to disburse funds through the first round of the
Clean School Bus Program's funding in 2022. However, local utility
companies may have trouble meeting increasing power demands for
electric school buses. For example, there could be delays in constructing
charging stations to make the buses fully operational. The EPA suggested,
but did not require, that applicants to the funding program coordinate with
their local utility provider regarding power supply demands. We did not
issue any recommendations in this report.

Clean school bus at charging
station. (EPA photo)

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

The EPA Needs to Improve the Completeness and Accuracy of the Obligation and
Outlay Information That It Reports in USAspending.gov

Report No. 24-P-0014 | Issued January 9, 2024 | (I)

L\ Compliance with the law; Operating efficiently and effectively.

@ Managing grants, contracts, and data systems.

The EPA's initial reporting of its FY 2022 spending in USAspending.gov was not complete or accurate.
Spending encompasses both obligations, which are promises made by the government to spend money,
and outlays, which are money actually paid. Because the Office of the Chief Financial Officer did not
follow its information technology configuration management procedures and did not have procedures
to detect errors in the reported data for FY 2022, the EPA underreported its award-level obligations by
$1.2 billion, underreported its award-level outlays by $5.8 billion, did not report any of its IIJA outlays,
and underreported its coronavirus pandemic-related outlays. Taxpayers were thus initially misinformed
about the EPA's spending, and policy-makers may have been unable to effectively track federal
spending. As a result of our audit, the EPA corrected its FY 2022 reporting in May 2023 and made the
necessary configuration changes in June 2023.

The EPA's reported and corrected FY 2022 award-level outlays in USAspending.gov. Source: OIG
analysis of the EPA's USAspending.gov reporting. (EPA OIG image)

Recommendations issued to the chief financial officer

No.

Recommendation

Update, circulate, and implement the Office of the Chief Financial Officer's standard operating procedures related to
configuration management to describe the process and frequency of configuration audits related to its systems.

Conduct periodic configuration audits of the DATA Act Evaluation and Approval Repository, as well as any other Office of
the Chief Financial Officer systems that have not had periodic configuration audits, to determine whether all configuration
changes were properly implemented, documented, and approved.

Update, circulate, and implement the Office of the Chief Financial Officer's standard operating procedures to include
procedures to prevent and detect errors and confirm the accuracy and completeness of the EPA's Digital Accountability and
Transparency Act of 2014 reporting.

Develop and conduct training on the requirements of the Office of the Chief Financial Officer's standard operating
procedures for configuration management and Digital Accountability and Transparency Act of 2014 reporting.

Evaluate the manual process used to transfer data from the DATA Act Evaluation and Approval Repository to the DATA Act
Broker and determine how to reduce vulnerabilities by streamlining or automating the process. Based on the results of the
evaluation, update the standard operating procedures.

ir,Mission-Related Effort. ©Top Management Challenge. ^Statutorily Required. (i)Podcast.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

The EPA Should Improve Annual Reviews to Protect Infrastructure Investment
and Jobs Act Grants to Clean Water State Revolving Funds

Report No. 54-P-0028 I Issued March 14, 2024

Ensuring clean and safe water.

Although the Clean Water Act requires the EPA to conduct an annual oversight review of each state's
Clean Water State Revolving Fund, the Office of Water did not consistently monitor the performance or
results of the annual reviews for any of the three states that we reviewed—New York, which is in EPA
Region 2; Pennsylvania, which is in EPA Region 3; and Texas, which is in EPA Region 6—in the time period
we examined. Furthermore, the Office of Water did not ensure that Regions 2, 3, and 6 followed the
annual review guidance; did not review all supporting checklists and program evaluation reports; and did
not act in a timely manner to address the risk of a substantial and potentially excessive fee account
balance that Region 6 identified during the annual review process. In addition, of the three states that we
reviewed, we concluded that none had audits conducted for their Clean Water State Revolving Funds in
state FYs 2019 through 2021 that met regulatory requirements.

The Regions:

Review of slate CWSRF
documents, including:
» Intended use plan.
• Annual Report.

¦ Independenfsingle
audit

¦ SRF Data System
reports.

¦ Grant Agreement.

On-Site Review

Interview CWSRF staff and complete the
annual review checklist.

Conduct project He reviews and complete
the project tile review checklists.

Conduct transaction testing and complete
the transaction testing worksheets.

• fnctudes any

recommendations to

the slale

• Creales a

permanent record of

the annual review.

Program Evaluation Report

Planning and Preparation

The Office of Water:

Develops the annual review guidance
and provides training to the regions on
the annua] review process.

Develops the annual review checklist,
project file checklists, and Iransaction
testing worksheets used by the regions.

Provides training to the regions on
CWSRF laws, regulations, and policies.

Collects the annual review documents
from the regions and provides support
if needed.

The EPA's annual review process. Notes: CWSRF = Clean Water State Revolving Fund; SRF = State
Revolving Fund. Source: OIG depiction based on the SRF Annual Review Guidance. (EPA OIG figure)

Recommendations issued to the assistant administrator for Water

No.

Recommendation

Implement procedures to ensure consistent Office of Water oversight of the annual review process in all regions and states,
including reviewing checklists and all program evaluation reports and tracking recommendations made by the regions

Create a program evaluation report template and implement procedures to ensure that regions present results in a
consistent format.

Coordinate with Region 6 to implement a resolution plan for the Texas Water Development Board's $106 million in its
origination fees account and ensure that the water board is evaluating its need for Clean Water State Revolving Fund fees
appropriately.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

No.

Recommendation

Clarify annual review guidance regarding fee accounts and collect data on states' fee account balances through the annual
review process.

In coordination with the associate administrator for Policy, update EPA regulations implementing the Clean Water State
Revolving Fund audit requirement at 33 U.S.C. § 1386(b) to clearly articulate requirements and current EPA expectations
regarding audits of state revolving funds.

Ensure annual review guidance regarding implementation of audit requirements is consistent with 33 U.S.C. § 1386(b) and
40 C.F.R. § 35.3165.

Perspectives on Capacity: Managing Drinking Water State Revolving Fund
Infrastructure Investment and Jobs Act Funding

Report No. 24-E-0022 | Issued February 27, 2024
Ensuring clean and safe water.

® Overseeing, protecting, and investing in water and wastewater systems; Managing grants, contracts, and data systems.

In response to an OIG survey, most state Drinking Water State
Revolving Fund, or DWSRF, administrators agreed that their
agencies had the organizational capacity necessary to manage the
DWSRF Infrastructure Investment and Jobs Act funds awarded to
their states. However, a few state DWSRF administrators expressed
concerns related to financial capacity, workforce management, and
insufficient federal guidance. State DWSRF agency capacity to
effectively manage federal DWSRF grants is crucial to the success
of the DWSRF Program. Obstacles that affect state DWSRF agency
capacity may result in decreased investment in critical water
infrastructure projects. While we did not issue any
recommendations in this report, the EPA has an opportunity to
work with state DWSRF agencies to address the obstacles
documented in the report.

98%

of state DWSRF
administrators agreed
their agency had the
operating procedures
necessary to manage
DWSRF IIJA funds.

Neither agree nor disagree

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

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Human Health and Environmental Issues

The EPA's Pollution Prevention Grant Results Aligned with Program Goals, but a
Supervisory Verification Process Is Needed

Report No. 24-P-0004 | Issued October 19, 2023

Operating efficiently and effectively.

The EPA environmental results and monetary benefits of all 20 pollution prevention grants that we
reviewed aligned with the goals of the pollution prevention program: conserve natural resources,
decrease releases of toxics to the environment, and increase cost savings for businesses and others. The
EPA accurately reported results for 18 of the 20 grants but did not include the results or inaccurately
reported the results for the other two. Without a process for supervisors to verify the reported grant
results, the program may report inaccurate pollution prevention grant results to the public.

Grantees
submit results
to regions

Regions
review results

and submit
regional totals
to OPPT

OPPT reviews
and compiles
P2 grant
results

OPPT publicly

reports P2
grant results

8 Grant results
accurately reported^

2 Grant results inaccurately reported
or not included

Above: The grant results quality assurance review process steps. Below: The number of grant results the EPA did or
did not accurately report in sample.

Notes: OPPT = Office of Office of Pollution Prevention and Toxics; P2 = Pollution Prevention.

Source: OIG depiction of grant results review and results reported in sample. (EPA OIG images)

Recommendation issued to the assistant administrator for the Office of Chemical Safety and Pollution
Prevention

No.

Recommendation

1 Establish guidance for a process in which the supervisors in the Office of Pollution Prevention and Toxics verify the
accuracy of their staffs quality assurance review work prior to publishing pollution prevention grant results.

ir,Mission-Related Effort. ©Top Management Challenge. ^Statutorily Required. (i)Podcast.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Business Practices and Accountabilit

The EPA's Enhanced Personnel Security Program Is on Track, but Challenges to
Full Implementation Remain

Report No. 24-E-0020 | Issued February 8, 2024

Compliance with the law; Operating efficiently and effectively.

As of October 2023, the EPA's Personnel Security Branch had successfully met all milestones and
requirements to date and was on track to meet the March 2026 deadline to fully implement the director
of National Intelligence's enhanced personnel security program. This program provides a continuous
vetting environment that allows risks to personnel security to be tracked in real time. The Personnel
Security Branch must ensure, however, that it has sufficient capacity by March 2026 to provide the
required level of continuous vetting services for all EPA employees and applicable contractor
personnel—nearly 22,000 individuals, or 20 times the number being vetted under the program as of
October 2023. If the Personnel Security Branch plans now to achieve the needed capacity, it will prevent
delays in full implementation and reduce national security risks.

25,000

3 20,000

3
Q.

« 15,000

UJ
>
UJ
>
H
<
_l
3

3
O

10,000

5,000

Type of
Continous Vetting
Services Required

TW 1.25

¦ TW 1.5

¦ TW 2.0

Solid green line
shows trend line
of entire population
requiring continuous
vetting services.

9/30/22

9/30/24

9/30/25

3/30/26

TW 2.0 MILESTONE DATES

The EPA's anticipated continuous vetting population growth by milestone date. Note: TW= Trusted
Workforce Program. Source: Anticipated TW2.0 enrollment milestones, based on EPA employee data
provided by the Personnel Security Branch on August 25, 2023. (EPA OIG image)

Recommendation issued to the assistant administrator for Mission Support

No.

Recommendation

1 Develop a plan for how the Personnel Security Branch will achieve the capacity necessary to meet the requirements of full
Trusted Workforce 2.0 implementation.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

The Office of Criminal Enforcement, Forensics and Training Incorporated
Essential Discovery Elements into Its Policies and Procedures, but Additional
Training Could Improve Awareness

Report No. 24-E-0021 | Issued February 15, 2024

Compliance with law; Operating efficiently and effectively.

We did not identify any specific circumstances where the EPA Office of Criminal Enforcement, Forensics
and Training did not adhere to criminal discovery requirements regarding the collection, retention, and
production of material. The office has incorporated essential elements of discovery obligations, such as
the Brady Doctrine, the Jencks Act, and the Federal Rules of Criminal Procedure, into its criminal
investigations policies and procedures to facilitate required discovery disclosures. Some special agents
employed investigative procedures that deviated from the office's procedures, but they did not violate
discovery requirements. Strengthening adherence to EPA discovery policies and procedures can
promote efficient and effective criminal prosecution.

Recommendations issued to the assistant administrator for Enforcement and Compliance Assurance

No.

Recommendation

Review Office of Criminal Enforcement, Forensics and Training policies and procedures to determine whether updates are
needed to improve processes, including best practices.

Provide periodic training to EPA employees that may serve on a prosecution team to promote awareness and adherence to
discovery requirements and investigative policies and procedures.

Management Implication Report: The EPA Has Insufficient Internal Controls for
Detection and Prevention of Procurement Collusion

Report No. 24-N-0027 | Issued March 12, 2024

The Agency does not store and organize procurement data in the EPA Acquisition System in a manner
that would allow for proactive oversight and program management that could detect and prevent
fraudulent, collusive behavior, such as bid rigging, price fixing, or other anticompetitive practices. Over
3,500 competitively bid, negotiated contracts worth over $2 billion for goods and services that the
Office of Acquisition Solutions has awarded since FY 2017 could have been susceptible to procurement
collusion because of a lack of internal controls within the EPA Acquisition System. Billions more in future
procurement awards, including from IIJA and IRA funding, could also be susceptible if the Agency does
not take action to improve its internal controls. We did not issue any recommendations in this report,
but provided considerations for strengthening the EPA's internal controls, such as more robust training
and using settings in the EPA Acquisition System to gather structured bid data from vendor proposals.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

The EPA Needs to Better Implement Internal Access Control Procedures for Its
Integrated Risk Information System Database

Report No. 24-P-0005 | Issued October 31, 2023

Compliance with the law; operating efficiently and effectively.

® Protecting EPA systems and other critical infrastructure against cyberthreats.

Information technology access management for the EPA's Integrated Risk Information System database
did not adhere to federal and Agency IT access control requirements because the Agency did not
regularly review or monitor privileged or application user accounts. It also did not ensure compliance
with federal security documentation requirements. Without enforcing established access control
requirements, the EPA puts the chemical data, which Integrated Risk Information System users rely upon
to inform scientifically sound environmental regulations and policies, at risk of unauthorized changes.

System security plan

A formal document that provides an overview of the security requirements for an information
system and describes the security controls in place or planned for meeting those requirements.

Recommendations issued to the assistant administrator for Research and Development

No.

Recommendation

Develop a process and assign responsibility for periodic review of application user information technology access for the
Integrated Risk Information System database and perform the necessary updates to adhere to federal and Agency
information technology access controls requirements including identifying and deactivating any unused accounts.

Develop a process and assign responsibility for application user information technology access approval to the Integrated
Risk Information System database.

Instruct staff responsible for Integrated Risk Information System account management of the federal and Agency
information technology access control requirements related to access approval, review, monitoring, and removal.

Discontinue use of Integrated Risk Information System Database Application accounts for database administration activities
without a business justification or develop a process to track privileged user activity on these accounts.

Work with the Office of Mission Support to incorporate the Integrated Risk Information System database into the National
Computer Center's Hosting System's security plan.

Recommendations issued to the assistant administrator for Mission Support

No.

Recommendation

Configure password settings to comply with Agency access control requirements for the password expiration, password
reuse maximum, and inactive account time password settings.

Document the Integrated Risk Information System database's security controls, including password configuration settings, in
a system security plan and work with the Office of Information Technology Operations to confirm those settings are
reviewed as part of its annual security plan review process.

Mission-Related Effort. ® Top Management Challenge. Statutorily Required. (i :Podcast.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Lack of Vulnerability Remediation for Weaknesses Identified Within the Central
Data Exchange System Increases the Risk of Cyberattacks

Report No. 24-N-0024 | Issued March 5, 2024
d® Operating efficiently and effectively.

During our ongoing audit of the EPA's Central Data Exchange Access security controls, we identified that
the EPA did not mitigate significant vulnerabilities found in the Central Data Exchange system, which
could increase the risk of threat actors gaining unauthorized access to CDX and other connected program
services. As of August 2023, two high-risk and 12 moderate-risk vulnerabilities remain unresolved. The
EPA also did not follow its own procedures by not reviewing and updating plans of actions and milestones
regularly; making sure all planned, in-process, and completed actions are recorded; and providing
support that it had implemented adequate mitigating or compensating controls. The Agency also closed,
without having appropriate supporting security documentation, a Plan of Action and Milestones that
documented a vulnerability and did not review security documentation submitted for closure. We did not
issue any recommendations in this report.

Central Data Exchange System Identity Data Are Unreliable

Report No. 24-N-0025 | Issued March 5, 2024

Operating efficiently and effectively.

During our ongoing audit of the EPA's Central Data Exchange Access security controls, we identified
instances of unreliable data in Central Data Exchange files that met neither the EPA quality and integrity
requirements in effect during our project scope nor the National Institute of Standards and Technology's
quality and integrity guidance. We issued this management alert while our overall audit work continued
to immediately inform the EPA of these issues. If the EPA does not mitigate these issues, it cannot
provide assurance that its environmental data are accurate and reliable, and its ability to fulfill its mission
and carry out its regulatory obligations may be impacted. We did not issue any recommendations in this
management alert.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Audit of the EPA's Fiscal Years 2021 and 2020 Toxic Substances Control Act
Service Fee Fund Financial Statements

Report No. 24-F-0002 | Issued October 12, 2023 | j^(4)

Operating efficiently and effectively.

We rendered a qualified opinion on the EPA's FYs 2021 and 2020 Toxic Substances Control Act Service
Fee Fund financial statements, meaning that the statements were fairly presented except for material
errors in expenses and income from other appropriations. The EPA materially overstated the FY 2021
"Expenses from Other Appropriations" line item by $2.36 million and did not implement controls to
properly record accounts receivable and ensure segregation of duties between payment processing and
payment approval.

Recommendations issued to the chief financial officer

No.

Recommendation

Correct the calculation in the Toxic Substances Control Act 21-09A on-top adjustment to accurately capture the amounts for
financial statement line items "Income from Other Appropriations" and "Expenses from Other Appropriations."

Implement procedures to establish an allowance for doubtful accounts for the Toxic Substances Control Act Service Fee
Fund to reduce that fund's accounts receivable to its net realizable value.

Implement procedures to prevent or detect potential violations of the segregation of duties policy in the Small Purchase
Information Tracking System software.

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

No.

Recommendation

Update the Toxic Substances Control Act standard operating procedures to align with the Resource Management Directive
System requirement to forward documentation that establishes a receivable to the Office of the Controller within five
business days.

Audit of the EPA's Fiscal Years 2023 and 2022 (Restated) Consolidated Financial
Statements

Report No. 24-F-0009 | Issued November 15, 2023 | ^
d® Operating efficiently and effectively.

We rendered an unmodified opinion on the EPA's consolidated financial statements for FYs 2023 and
2022 (restated), meaning that they were fairly presented and free of material misstatement. We noted
four significant deficiencies, including that the EPA did not provide accurate information for its revenue
accruals; did not deobligate unneeded funds in a timely manner; operated under an expired
interconnection Security Agreement and Memorandum of Agreement, which could hamper invoice
processing; and did not review user accounts for EPA contracting personnel every 60 days, as required
by its information security procedure. We did not note any significant noncompliance with laws,
regulations, contracts, and grant agreements.

Recommendations issued to the chief financial officer

No.

Recommendation

Instruct the regions to perform an analysis of financially closed Superfund State Contracts to reclassify appropriated and
reimbursable disbursements and financially close lines on the accrual.

Instruct the regions to provide current Superfund State Contract information quarterly to the Cincinnati Finance Center.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

No.

Recommendation

Develop a plan to improve the Office of the Chief Financial Officer processes for headquarters program offices and regional
offices to deobligate unneeded funds in a timely manner by the end of the fiscal year, as required.

Develop and implement a plan with milestones to ensure that future Interconnection Security Agreement and Memorandum
of Agreement documents for each external connection with Office of the Chief Financial Officer systems are reauthorized
before the current agreements expire.

In consultation with the Office of Mission Support's chief information officer, determine how the Office of the Chief Financial
Officer will conduct reviews of active Invoice Processing Platform user accounts to comply with Chief Information Officer
Directive No. CIO 2150-P-01.3, Information Security - Access Control Procedure.

Develop and implement a strategy to ensure that future reviews of active Invoice Processing Platform user accounts comply
with Chief Information Officer Directive No. CIO 2150-P-01.3, Information Security - Access Control Procedure.

Recommendation issued to the director of the Great Lakes National Program Office

No.

Recommendation

Review the Great Lakes Legacy Act accrual project information prior to its submission to the Cincinnati Finance Center to
ensure its accuracy.

Audit of the EPA's Fiscal Years 2022 and 2021 (Restated) Pesticides
Reregistration and Expedited Processing Fund Financial Statements

Report No. 24-F-0003 | Issued October 17, 2023 |

Operating efficiently and effectively.

We rendered an unmodified opinion on the EPA's FYs 2022 and 2021 (restated) Pesticides Reregistration
and Expedited Processing Fund, also known as the Federal Insecticide, Fungicide, and Rodenticide Act
Fund, financial statements, meaning that the statements were fairly presented and free of material
misstatement. However, we noted one material weakness: the EPA did not allocate expenses totaling
approximately $1.2 million to the fund that it paid to the U.S. General Services Administration and the
U.S. Department of Homeland Security. We noted one significant deficiency, which is an internal control
deficiency that is less severe than a material weakness but still important enough to merit attention: the
EPA miscalculated the restatement balances for Software in Development for the financial statements
note 15, "Restatements," overstating the balance by $66,622. We did not identify any noncompliance
with applicable laws, regulations, contracts, and grant agreements that would result in a material
misstatement to the audited financial statements. In addition, the Agency was in compliance with the
statutory performance measures.

Recommendations issued to the chief financial officer

No.

Recommendation

Record an adjustment to recognize rent and federal protective services expenses for the fiscal year 2022 Federal
Insecticide, Fungicide, and Rodenticide Act Fund financial statements.

Correct the restatement amount for the Software in Development to accurately capture the amounts for note 15,
"Restatements."

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Audit of the EPA's Fiscal Years 2022 and 2021 (Restated) Pesticide Registration
Fund Financial Statements

Report No. 24-F-0017 | Issued January 18, 2024 | ^

Operating efficiently and effectively.

We rendered an unmodified opinion on the EPA's FYs 2022 and 2021 (restated) Pesticide Registration
Fund—also known as the Pesticide Registration Improvement Act Fund—financial statements, meaning
that the statements were fairly presented and free of material misstatement. We noted the following
significant deficiency: the EPA miscalculated the restatement balances for Software in Development
Fund financial statements note 13, "Restatement," overstating the balance by $938,948.35. We did not
identify any noncompliance that would result in a material misstatement to the audited financial
statements. In addition, the Agency was in compliance with the statutory decision time review periods.

Recommendation issued to the chief financial officer

No.

Recommendation

Correct the restatement amount for Software in Development to accurately capture the amounts for note 13, "Restatement."

OIG Report to the Office of Management and Budget on the EPA's and CSB's
Implementation of Recommendations Related to Purchase and Travel Card
Programs

Report No. 24-N-0018 | Issued January 31, 2024 |

We report to the director of the Office of Management and Budget on Agency implementation of
recommendations that address audit findings related to purchase and travel card programs. In this letter
to the Office of Management and Budget regarding FY 2023 purchase and travel card audits and
recommendations, we reported that we did not perform purchase or travel card program audits,
reviews, or assessments for the EPA; that we did not perform a travel card program audit or review for
the CSB; that we did perform a purchase card program audit for the CSB and the CSB addressed those
findings and recommendations; and that the EPA completed a corrective action that addressed the one
outstanding OIG recommendation from our prior travel card program audits, reviews, or assessments.

OIG Report to the Office of Management and Budget on the EPA's Semi-Annual
Report on Purchase Charge Card Violations

Report No. 24-N-0019 | Issued January 31, 2024 | ^

The EPA and the inspector general are required to submit to the director of the Office of Management
and Budget, on a semiannual basis, a joint report on Agency purchase card violations. The EPA reported
no purchase card violations from April 1, 2023, to September 30, 2023. For this reporting period, no
information inconsistent with the EPA's violation report came to our attention, and we received no
allegations of misuse of the government purchase card.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Hotline Complaints

The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable
Risk to Pet Health

Report No. 24-E-0023 | Issued February 29, 2024 | (4)

Ensuring the safety of chemicals.

The EPA's response to reported pesticide incidents involving Seresto pet collars has not provided
assurance that they can be used without posing unreasonable adverse effects to the environment,
including pets. While the EPA adhered to the toxicological data requirements in 40 C.F.R. part 158 in its
initial approval of Seresto pet collars, it has not adhered to the pesticide registration review process for
the active ingredients flumethrin and imidacloprid in the Seresto pet collars. Additionally, it did not
conduct or publish domestic animal risk assessments, which it had committed to doing in the work plans
for these two pesticides; continues to use an inadequate 1998 companion animal safety study
(Guideline 870.7200); and lacks standard operating procedures and a measurable standard to help
determine when domestic animal pesticide products pose unreasonable adverse effects to the
environment, as required by the Federal Insecticide, Fungicide, and Rodenticide Act. Additionally, the
EPA's Pesticide Incident Reporting System and reporting process do not capture adequate data that the
EPA needs to assess unreasonable adverse effects of pet products.

Initial registration for Seresto pet collar.

Emails show EPA officials raised concerns
about Seresto but were rebuffed by supervisors.

March: The EPA staff raised concerns to
management through prepared briefings. No
action was taken by management.

June: The House subcommittee held a i
hearing called "Seresto Flea and Tick Collars:
Examining Why a Product Linked to More than
2,500 Pet Deaths Remains on the Market."

The EPA's independent analysis of Health
Canada Pest Managements Regulatory Agency
study concludes that 45 percent of reported pet
deaths "probably or possibly" caused by collar.

July: The EPA met with the registrant to discuss
improved product safety measures; the registrant
did not agree to make the changes.

March: The House Subcommittee on Economic
and Consumer Policy launched investigation in|o
the collar.

June: The House subcommittee publicly issues
its investigative staff report.

July: The EPA completed a review of Seresto collar incidents and identified the need for more detailed incident
reporting. The EPA adjusted the regulatory requirements for the registration of Seresto pet collars to incorporate
additional necessary mitigation that will aid in the Agency's continued review of this product. This registration will
be a time-limited registration of five years.

Seresto pet collar timeline. Source: OIG analysis of EPA information. (EPA OIG image)

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

No.

Recommendation

Issue amended proposed interim registration review decisions for both flumethrin and imidacloprid that include domestic
animal risk assessments for the two pesticides, written determinations on whether the Seresto pet collar poses
unreasonable adverse effects in pets, and an explanation of how the Office of Pesticide Programs came to its
determinations. Allow for public comment by placing these documents in the applicable registration review dockets.

Implement standard operating procedures on how to conduct domestic animal risk assessments for the active ingredients in
pet products to support pesticide registration review decisions.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

No.

Recommendation

Implement a measurable standard to determine when a pet product poses unreasonable adverse effects in pets to support
the pesticide registration review decision.

Update the EPA's Guideline 870.7200, Companion Animal Safety, as necessary, to be consistent with the Veterinary
International Conference on Harmonization Guideline GL43, Target Animal Safety for Veterinary Pharmaceutical Products.

Establish and implement an additional data requirement for the premarket clinical testing of pet products that is consistent
with the Veterinary International Conference on Harmonization Guideline GL9, Good Clinical Practice.

Assess what incident information is needed from registrants of pet products to determine when the EPA should take
mitigation measures or other actions. Require pet product registrants to report that information to the EPA.

Establish policies and procedures that result in consistent implementation of mitigation measures to address unreasonable
adverse effects or conduct additional analysis to determine whether a pet product is causing unreasonable adverse effects.

Update the EPA's Incident Data System to capture the additional data that the EPA identifies from the recommendations
above to allow the EPA to adequately assess incident reports and make timely decisions on when to take action.

The EPA Took Additional Actions to Strengthen Controls to Account for and
Secure Laptops

Report No. 24-P-0011 I Issued December 14, 2023
£», Operating efficiently and effectively.

EPA Regions 4 arid 6 and the Desktop Support Services
Division in EPA headquarters took actions to comply
with the Agency's Personal Property Manual and have
sufficient controls to account for and secure laptops to
prevent theft and misplacement. Region 6's business
practices had a flaw which could have made it difficult
to account for new laptops received. However, the
region took immediate action to fix this issue because of
our audit. Also, Region 6 and the Desktop Support
Services Division updated their operating procedures
for personal property management once we found that
their procedures were not fully developed or approved
by the agency property management officer. We did not
issue any recommendations in this report.

Source: OIG analysis of laptops from the
Agency asset management system. (EPA
OIG image)

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Multiple Factors Contributed to the Delay in Constructing Combined Sewer
Overflow Tanks at the Gowanus Canal Superfund Site in New York City

Report No. 24-P-0029 | Issued March 21, 2024 | (i)
d* Cleaning up and revitalizing land.

Maximizing compliance with environmental laws and regulations.

Construction of the two combined sewer overflow tanks for the Gowanus Canal Superfund site in New
York City is approximately six-and-a-half years behind Region 2's original schedule and is estimated to
cost more than $1 billion—a more than 1,300-percent increase from Region 2's original estimate. A
2021 administrative order adjusted the project schedule so that the Owls Head tank will be completed
by May 1, 2028, and the Red Hook tank will be completed by March 31, 2029. Continued delays can
prolong exposure to contaminants in the canal and lead to further cost increases.

Red Hook tank construction site viewed from the Gowanus Canal (at left) and Red Hooktank construction site viewed
from Nevins Street (at right). Source: EPA OIG site visit. (EPA OIG images)

Recommendations issued to the assistant administrator for Water

No.

Recommendation

Closely monitor combined sewer overflow tank construction progress at the Gowanus Canal Superfund site and take
immediate action, including enforcement actions if appropriate, if New York City misses any future tank project milestones
from the 2021 administrative order.

Post on the EPA's public website the milestones from the 2021 administrative order regarding the Gowanus Canal
Superfund site, New York City's progress towards completing these milestones, and any actions taken to ensure the city
stays on schedule.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

U.S. Chemical Safety and Hazard Investigation Board

The CSB Needs to Improve Controls over Its Charge Card Program and Comply
with Federal Requirements

Report No. 24-P-0001 | Issued October 4, 2023 |

Creating and maintaining an engaged, high-performing workforce.

We determined that the CSB's risk for illegal, improper, or erroneous purchases and payments is low.
However, even though the CSB is ultimately responsible for overseeing its charge card program and for
following the requirements of Appendix B to OMB Circular A-123, it relied on its interagency agreement
with the U.S. Department of the Treasury's Bureau of the Fiscal Service to manage various aspects of its
charge card program. Additionally, the CSB used verbal communication and institutional knowledge to
manage other aspects of its charge card program. We identified that in FY 2022, the CSB did not
adequately address the required elements in its charge card management plan and risk profile; did not
have guidance regarding third-party payment providers; did not monitor whether staff completed all
required training in a timely manner; and did not provide staff with written guidance addressing charge
card sales tax. As a result, if the CSB does not improve its efforts to meet the requirements outlined in
Appendix B to OMB Circular A-123, deficiencies in its charge card program could increase its risk for
unauthorized purchases and improper payments.

Summary of the OIG's risk assessment results for the CSB charge card program

Assessment risk factors Risk rating

Program size: Percentage of agency's budgetary resources Low

Unauthorized and erroneous purchases Low

Noncompliance with charge card requirements Medium

Training certificate issues Medium
Improper delegation of authority Low

Incomplete or insufficient charge card management plan and risk profile Medium

Summary risk assessment (average) Low*

Source: OIG analysis of risk assessment factors. (EPA OIG table)

* We did not identify any unauthorized purchases in our sample testing, which supports our conclusion
that the CSB is at low risk of illegal, improper, or erroneous purchases and payments.

Recommendations issued to the CSB chairperson

No.

Recommendation

Update the CSB's charge card management plan to include the required elements listed in Office of Management and
Budget Circular A-123, Management's Responsibility for Enterprise Risk Management and Internal Control, Appendix B, "A
Risk Management Framework for Government Charge Card Programs," dated August 27, 2019. At a minimum, the charge
card management plan should include narratives for each element, be clear and fully explained, and be available to all
charge cardholders and program officials.

Update the CSB's risk profile to include all required components listed in Office of Management and Budget Circular A-123,
Management's Responsibility for Enterprise Risk Management and Internal Control, dated July 15, 2016, as it relates to the
charge card program.

Update the CSB Government Purchase Card Guidance, dated October 2022, to include:

a. Instructions for and controls over charge cardholders' use of third-party payment providers for authorized
transactions.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

No.

Recommendation

b. Requirements for monitoring the completion of all required charge card training courses in accordance with the
schedule in Appendix B to Office of Management and Budget Circular A-123.

c. References to revisions of the charge card management plan and risk profile as detailed in Recommendations 1
and 2.

Require training of and compliance with the updated CSB Government Purchase Card Guidance, to help ensure that the
CSB is compliant with Appendix B to Office of Management and Budget Circular A-123.

U.S. Chemical Safety and Hazard Investigation Board Fiscal Years 2023 and 2022
Financial Statement Audit

Report No. 24-F-0030 | Issued March 28, 2024 |

Creating and maintaining an engaged, high-performing workforce.

Allmond & Company rendered a qualified opinion on the CSB's FYs 2023 and 2022 financial statements,
meaning that except for material errors in unrecorded lease obligations, the statements were fairly
presented. The CSB's budgetary accounting for recording lease obligations in prior years was not in
accordance with U.S. generally accepted accounting principles. Allmond & Company advised the CSB
that all prior-period financial statements audited from FY 2016 through 2022 contain material errors and
should no longer be relied upon. Additionally, Allmond & Company identified one deficiency in internal
control over financial reporting that would be considered a material weakness and one instance of
potential noncompliance with the Antideficiency Act in FY 2023.

Recommendations issued to CSB management

No.

Recommendation

Update its accounting policies on the accounting for lease obligations to be consistent with the guidance in OMB A-11,
Appendix B.

CSB management complete the investigation into the potential ADA violation noted and report to the appropriate parties, as
necessary.

Develop and implement adequate internal controls to ensure lease obligations are recorded in compliance with OMB A-11,
Appendix B requirements.

Restate the FY 2022 Statement of Budgetary Resources and related note disclosure.

Record the remaining obligation for the Washington, DC lease and properly state the FY 2023 Statement of Budgetary
Resources and related note disclosure.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

2.2 Investigative Work

Section 5(a)(3) of the Inspector General Act, 5 U.S.C. § 405, requires a summary of significant investigations
that were closed during the reporting period. We also report investigations that have not yet been officially
closed but in which there has been significant activity, including convictions or guilty pleas, during the
reporting period. Section 5(a)(13) of the Inspector General Act requires that we report on each investigation
involving a senior government employee in which allegations of misconduct were substantiated.

Closed Significant Investigations

Individual Debarred for Misleading Authorities about Lead Contamination in a
Missouri Park

On June 1, 2023, a former project manager for an environmental remediation company was sentenced
to five years of probation and ordered to pay a $40,000 fine after pleading guilty on July 28, 2022, in
U.S. District Court, Western District of Missouri, to misleading federal authorities about lead
contamination in a city park in Granby, Missouri. On January 16, 2024, the EPA debarred the former
project manager from participating in federal procurement and nonprocurement programs for eight
years. The debarment will terminate on August 29, 2030. In addition, the project manager's former
employer paid more than $2 million in restitution in two federal civil settlements, which were executed
on April 24, 2023, and which fully compensated the government, including the EPA, for the costs to
remove lead contamination from the city park. Specifically, the employer paid $1,708,748 in a federal
civil settlement agreement related to violations of the Comprehensive Environmental Response,
Compensation, and Liability Act and paid $338,119 in a federal civil settlement agreement related to
violations of the False Claims Act. In 2015, the U.S. Army Corps of Engineers and the EPA awarded the
environmental remediation company a contract, which totaled nearly $12 million, to perform
mine-waste remediation at the Newton County Mine Waste Remediation Superfund Site in and around
Granby. This area had been contaminated by lead in the surface soil that was deposited through
historical mining and smelting operations. The investigation determined that the project manager
deliberately made false statements and provided false information to regulators regarding the level of
lead contamination that continued to exist at the park. Because of the project manager's actions, the
EPA had to hire another contractor to remediate the city park, resulting in additional costs to the EPA.

This was a joint investigation with the EPA Criminal Investigation Division, U.S. Department of Defense OIG Defense Criminal
Investigative Service, and U.S. Army Criminal Investigative Division Major Procurement Fraud Unit.

Businesspeople Debarred for Falsely Claiming Cleaning Product Was EPA-
Approved

On December 1, 2022, two San Diego businesspeople pleaded guilty in the U.S. District Court, Southern
District of California, to defrauding customers by falsely claiming that the EPA tested and approved their
company's antimicrobial cleaning product to eliminate bacteria and viruses, including the SARS-CoV-2
virus, which causes the COVID-19 disease, on treated surfaces for one year with a single application. On

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

June 2, 2023, the two businesspeople were each sentenced to five years of probation, and each was
ordered to pay $823,669.31 in restitution. In addition, on December 5, 2023, the two businesspeople
and the company were debarred from participating in federal procurement and nonprocurement
programs for five years. The debarment will terminate on August 6, 2028. The investigation determined
that none of the products sold under the company's name were registered as pesticides by the EPA, as
required by law. Unregistered pesticides may not be sold or distributed in the United States. As part of
pleading guilty, the businesspeople and their company admitted that they sold over $800,000 worth of
the unregistered pesticides.

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

Former Treatment Plant Superintendent Sentenced for Violating Clean Water Act

On April 1, 2021, a former superintendent of the Sioux City Wastewater Treatment Plant in Iowa was
sentenced in the U.S. District Court, Northern District of Iowa, to three months' imprisonment with two
years of supervised release and fined $6,000 for violating the Clean Water Act. The Sioux City
Wastewater Treatment Plant, which receives funding through EPA state revolving fund grants, is a large
regional sewage treatment plant for wastewater from industrial, commercial, and residential sources
throughout the region. Under its Clean Water Act permit, the plant must treat wastewater before
discharging it into the Missouri River and test the wastewater to verify proper treatment. However, the
former superintendent conspired to employ a fraudulent water testing procedure. On October 6, 2020,
the former superintendent pleaded guilty to one count of conspiracy and one count of knowingly
falsifying, tampering with, and rendering inaccurate a monitoring device or method required to be
maintained under the Clean Water Act. This case had remained open until November 2023 to determine
whether further investigative activity was warranted.

This was a joint investigation with the EPA Criminal Investigation Division and Federal Bureau of Investigation.

Global Firm Agreed to Pay Nearly $500,000 for Alleged Violations of the Civil
False Claims Act

On October 5, 2023, the United States Attorney's Offices for the District of Rhode Island and the
Southern District of Texas entered into a civil settlement with a global professional services firm to pay
over $465,000 to the federal government for alleged violations of the civil False Claims Act. The federal
government alleged that the firm, which held several contracts with the federal government, including
with the EPA, improperly moved recorded labor hours between government projects with different
funding sources and submitted invoices for work that was not performed. The federal government also
alleged that the firm falsely inflated employee billing rates, which resulted in the submission of false
invoices to multiple government agencies.

This was a joint investigation with the U.S. Department of Commerce OIG, Army Criminal Investigation Division, U.S. Coast
Guard Investigative Service, U.S. General Services Administration OIG, National Aeronautics and Space Administration OIG,
Department of Defense OIG Defense Criminal Investigative Service, U.S. Department of Interior OIG, and Naval Criminal
Investigative Service.

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October 1, 2023-March 31, 2024

Texas Company Paid Civil Penalty for Allegedly Selling Unregistered Pesticides

On November 13, 2023, a Texas company agreed to pay a civil penalty of $2,429 to settle allegations
that it violated the Federal Insecticide, Fungicide, and Rodenticide Act by distributing and selling
unregistered pesticides from December 10, 2020, through August 25, 2021. The company also certified
that it is presently in compliance with the requirements of the Act, which requires all pesticides sold in
the United States to be registered with the EPA.

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

Nebraska Company Paid Civil Penalty for Allegedly Submitting False Rebate
Submissions

On November 21, 2023, a Nebraska company agreed to pay a civil penalty of $41,000 to settle
allegations that it submitted false statements to the Nebraska Department of Environment and Energy
to obtain rebates in FY 2019 to replace two diesel trucks. The rebates were funded by the EPA's Diesel
Emissions Reduction Act Program. Contrary to program requirements that the vehicle, engine, or
equipment to be replaced must be fully operational and in current, regular service, the company
allegedly requested rebates for one vehicle that was not in regular use by falsifying mileage and for
another vehicle that was neither operational nor in regular use by welding together parts from other
various trucks to appear functional.

EPA Region 4 Updates Procedures to Prevent Future Equipment Theft

In June 2023, a mercury vapor analyzer was stolen from an EPA facility in Georgia. The investigation
found that Region 4 did not have a required procedure for securing and sufficiently monitoring
equipment outdoors during decontamination or recalibration. The OIG served EPA Region 4 with a
referral letter summarizing the findings, and in February 2024, Region 4 updated its standard operating
procedures to require that its Emergency Response Technical Equipment Management personnel
maintain visual contact with the equipment during the entire decontamination process to ensure that
the equipment is not removed from its physical location.

Open Significant Investigations

Lab Co-Owner Debarred for Reporting False Test Results

On January 30, 2023, the co-owner of a water testing laboratory company in Bridgeport, West Virginia,
pleaded guilty in the U.S. District Court, Northern District of West Virginia, to one count of making a
false representation within the jurisdiction of the EPA, in violation of 18 U.S.C. § 1001. On July 25, 2023,
the co-owner was sentenced to one year of federal probation. On March 6, 2024, the EPA debarred the
co-owner from participating in federal procurement and nonprocurement programs for one year. In
May 2021, the City of Martinsburg, West Virginia, sent water samples to the laboratory company for
testing pursuant to the Safe Drinking Water Act, and the co-owner reported that the samples were
tested and found to be safe. The investigation determined that the co-owner of the company did not

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October 1, 2023-March 31, 2024

test the water samples because the laboratory equipment was not operational. As a result, when the
City of Martinsburg reported the test results to the State of West Virginia as required by EPA
regulations, the city unwittingly reported false test results.

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

Individual Pleaded Guilty to Wire Fraud and Money Laundering

On January 24, 2023, two individuals were indicted in the U.S. District Court, District of New Mexico, for
conspiracy to commit wire fraud and money laundering. One individual was a program director for a
501(c)(3) nonprofit organization headquartered in Santa Fe, New Mexico, while the other was a
Colorado-based environmental contractor for the nonprofit organization. On July 17, 2023, the
contractor pleaded guilty to one count of conspiracy to commit wire fraud. On November 9, 2023, the
former program director pleaded guilty to conspiracy to commit wire fraud and money laundering. Both
individuals face up to 20 years in prison. The nonprofit organization received federal funding from the
EPA and the Department of the Interior for projects to restore wildlife, natural resources, and
ecosystems in the American West. From February 2015 through April 2019, the former program director
and the contractor conspired to inflate hours billed to the nonprofit organization and diverted more
than $240,000 from the organization.

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

Arrests Made in Maryland for $9.5 Million Money-Laundering Conspiracy

On February 7, 2024, ten defendants were arrested at locations throughout Maryland and three search
warrants were executed related to an alleged money laundering conspiracy involving more than
$9.5 million in proceeds from fraud schemes. A federal grand jury in the U.S. District Court, District of
Maryland, returned two indictments in 2023 that were unsealed upon the arrests of the defendants.
According to the indictments, the defendants allegedly created and used limited liability companies and
other shell businesses to open bank accounts for the purpose of receiving money that they fraudulently
obtained from government agencies, organizations, and companies, including an environmental trust
overseen by the EPA, an urban redevelopment program, a medical center, a transportation-and-logistics
company, a school district, a college, a county government, and other victims. The defendants deceived
the victims into sending money to them by, for example, providing the victims with false bank account
information for legitimate vendor payments or with false wire transfer information for legitimate
transactions. The defendants and their coconspirators then allegedly concealed and disguised the nature
and source of the money through cash withdrawals, the purchase of cashier's checks, debit card
transactions, and transfers to other bank accounts controlled by the coconspirators. In addition, some
coconspirators obtained and used forged and counterfeited identification documents, including some
with the names of individual identity-theft victims. As of March 2024, two other defendants were
arrested on charges related to this money-laundering conspiracy, for a total of 12 arrests.

This was a joint investigation with the U.S. Department of Homeland Security Homeland Security Investigations, the Internal
Revenue Service Criminal Investigation Division, and the Department of Defense OIG Defense Criminal Investigative Service.

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Illinois-Based Environmental Services Company President Indicted for
Obstructing Federal Investigation

On October 19, 2023, the president of an environmental services company based in Lansing, Illinois, was
indicted in the U.S. District Court, Northern District of Illinois, for allegedly obstructing a federal
investigation into a hotel demolition project in Harvey, Illinois. The company was hired in 2017 by the
Chicago-based Cook County Land Bank Authority to conduct an asbestos survey of the hotel, which the
Land Bank Authority had acquired and intended to demolish and repurpose the property using a
Community Development Block Grant from the U.S. Department of Housing and Urban Development.
The company's asbestos survey stated that asbestos was present, and the company was hired as a
subcontractor to remove the asbestos. The EPA regulates reporting and recordkeeping requirements for
asbestos under the Toxic Substances Control Act. As such, the investigation probed whether the
company had accurately described the amount of asbestos in its survey to ensure the integrity of the
EPA program. The indictment alleged that the president intended to impede, obstruct, and influence an
investigation into whether the company accurately described the amount of asbestos present by
providing asbestos waste manifests that were altered to falsely reflect the amount of asbestos removed
from the hotel site and delivered to the landfill. Before the company president was indicted, another
individual involved in the case pleaded guilty on March 8, 2023, to wire fraud and was sentenced on
December 21, 2023, to 12 months' imprisonment and ordered to pay $172,706.81. Pursuant to another
aspect of the overall case, on November 1, 2023, an Illinois mayor was indicted on one count of
obstruction and one count of perjury after being deposed in a civil lawsuit filed by a waste management
company based in Riverdale, Illinois. Allegedly, the mayor's answers were intended to conceal his
relationship with a recycling company's owner, including the owner's extensive involvement in the
operations of a trucking company that the mayor and his wife owned on paper, but which was
effectively operated by the recycling company's owner for the mayor and his wife's benefit.

This was a joint investigation with the Federal Bureau of Investigation, Department of Housing and Urban Development OIG,
and EPA Criminal Investigation Division.

Three Individuals Pleaded Guilty to Falsely Claiming Hours Worked for
Residential Lead Inspections in New Jersey

On November 28, 2023, a resident of New Jersey and a resident of Pennsylvania pleaded guilty in the
U.S. District Court, District of New Jersey, to participating in a conspiracy to obtain overtime payments
from the City of Trenton, New Jersey, for work they did not perform. They did this by fraudulently
inflating the overtime hours they claimed to have worked in Trenton conducting residential lead
inspections in homes of children affected by lead poisoning. New Jersey receives EPA grants to help fund
the state's lead remediation efforts, lead accreditation training, and the New Jersey Department of
Health Lead Program. The two residents also admitted to inflating claims for overtime hours worked in
connection with a City of Trenton meal delivery program. The New Jersey resident admitted to receiving
$22,144 and the Pennsylvania resident admitted to receiving $32,806 in overtime payments to which
they were not entitled. On February 26, 2024, a second resident of New Jersey pleaded guilty in the
U.S. District Court, District of New Jersey, to participating in a conspiracy to obtain overtime payments

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

from the City of Trenton for work not performed. This second New Jersey resident did this by
fraudulently inflating the overtime hours claimed; submitting false claims for conducting residential lead
inspections in New Jersey environmental justice communities; and submitting false claims for overtime
work not performed in connection with a City of Trenton meal delivery program. This second New Jersey
resident admitted to receiving $32,524.12 in overtime payments to which the resident was not entitled.

This was a joint investigation with the Federal Bureau of Investigation, the Department of Housing and Urban Development OIG,
and the EPA Criminal Investigation Division.

EPA Employee Indicted for Paycheck Protection Program Fraud

On December 12, 2023, seven individuals were indicted in the U.S. District Court, Northern District of
Texas, on one count of conspiracy to commit wire fraud, 18 U.S.C. § 1349, and six counts of wire fraud,
18 U.S.C. § 1343, for alleged fraudulent participation in the Paycheck Protection Loan Program. One of
the individuals indicted is a General Schedule 12, or GS-12, EPA employee. According to the indictment,
the individuals conspired to unlawfully enrich themselves by submitting and causing the submission of
false and fraudulent applications for Paycheck Protection Program loans and to use and share in the
proceeds of the fraud for the personal use of the defendants and their coconspirators.

This was a joint investigation with the U.S. Small Business Administration OIG.

Senior Employee Investigations

The Administrative Investigations Directorate conducts administrative investigations of allegations of
misconduct by senior Agency employees. Senior Agency employees include an officer or employee in
the executive branch, including a special government employee as defined in 18 U.S.C. § 202, who
occupies a position classified at or above the GS-15 level or, in the case of positions not under the
General Schedule, for which the rate of basic pay is equal to or greater than 120 percent of the
minimum rate of basic pay payable for a GS-15 employee. Senior government employees include
members of the senior executive service; political appointees; and scientific, professional, and senior-
level positions.

Allegation Regarding OIG Official's Breach of Complainant Confidentiality
Is Substantiated

The Administrative Investigations Directorate initiated an investigation into an allegation that a former
senior OIG official improperly disclosed the identity of an EPA employee who had submitted a complaint
to the OIG Hotline. The investigation found that the former senior official disclosed the employee's
status as a hotline complainant during a meeting with EPA personnel, in violation of OIG procedure and
the confidentiality protections afforded under section 7(b) of the Inspector General Act of 1978, 5 U.S.C.
§ 407(b). The investigation did not find evidence that the disclosure was intentional. The former senior
official had announced plans to retire before the OIG investigation began and subsequently retired, as
planned, during the pendency of the investigation. The Administrative Investigations Directorate

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October 1, 2023-March 31, 2024

provided its report of investigation to the former senior official's former component office for
appropriate action.

As a result of this investigation, the inspector general will be issuing an annual message to all OIG staff
reminding them of their responsibilities to protect complainant confidentiality. Additionally, the OIG will
be creating a standalone directive consolidating requirements and procedures covering complainant and
whistleblower confidentiality.

Report of Investigation—Employee Integrity

A Report of Investigation documents the facts and findings of an OIG investigation and generally
involves an employee integrity matter. When either the OIG Office of Investigations or the OIG
Administrative Investigations Directorate issues a Report of Investigation that has at least one supported
allegation, it will generally request that the entity receiving the report—whether it is an office within the
EPA, the CSB, or the OIG—notify the OIG within 60 days regarding the administrative action taken or
proposed to be taken in the matter. When the Administrative Investigations Directorate issues a Report
of Investigation pursuant to 41 U.S.C. § 4712, the entity receiving the report is statutorily required to
take a specified action or deny relief within 30 days. This section provides information on how many
Reports of Investigation with at least one supported allegation were issued to the EPA, the CSB, or the
OIG, as well as how many of those Reports of Investigation did not receive a response within the 60- or
30-day period.

For this reporting period, we issued four Reports of Investigation—three to the EPA and one to the
OIG—and received zero responses outside the 60-day or 30-day response period, as applicable.

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2.3 Instances of Whistleblower Retaliation and
	Interference with Independence	

Whistleblower Retaliation

Section 5(a)(14) of the Inspector General Act, 5 U.S.C. § 405, requires a detailed description of any
instances of whistleblower retaliation noted by the OIG. This requirement includes reporting
information about any officials found to have engaged in retaliation and the consequences the EPA or
the CSB imposed to hold such officials accountable. We did not have any reportable instances of
whistleblower retaliation this semiannual period.

Interference with Independence

Section 5(a)(15) of the Inspector General Act, 5 U.S.C. § 405, requires a detailed description of any
attempt by the EPA or the CSB to interfere with the independence of the OIG, including "budget
constraints designed to limit the capabilities" of the OIG and incidents in which the EPA or the CSB "has
resisted or objected to oversight activities of the [OIG] or restricted or significantly delayed access to
information." We did not have any reportable instances of interference with independence this
semiannual period.

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Section 3: Statistical Data

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

3.1 Summary of Investigative Results

Section 5(a)(4) of the Inspector General Act, 5 U.S.C. § 405, requires a listing of the total convictions for
the reporting period that resulted from investigations, and section 5(a)(ll) of the Act requires statistical
tables identifying the total number of investigative reports, the total number of people referred for
criminal prosecution during the reporting period, and the total number of indictments and criminal
informations during the reporting period that resulted from prior referrals to prosecuting authorities.
Section 5(a)(12) of the Act requires a description of the metrics used for developing the data for the
statistical tables required by section 5(a)(ll). We also provide additional statistical information relating
to the results of our investigative work, including cases and complaints opened, and the results of
criminal, civil, and administrative actions.

Table 4: Summary of investigative activity

Investigative activity

Number

Cases open as of September 30, 2023*

179

Cases opened during period

76

Cases closed during period

69

Cases open as of March 31, 2024*

186

Preliminary inquiries open as of September 30, 2023

69

Preliminary inquiries opened during period

76

Preliminary inquiries closed during period

57

Preliminary inquiries open as of March 31, 2024

88

Source: OIG analysis of OIG investigative activity. (EPA OIG table)

* These cases include data from the Office of Investigations and the Administrative Investigations Directorate.

Table 5: Results of criminal and civil actions

Criminal and civil actions

EPA OIG only

Joint*

Total

Criminal indictments, informations, or complaints1"

0

25

25

Convictions*

0

3

3

Civil judgments, settlements, or filings

0

3

3

Criminal fines and recoveries

0

$778,916

$778,916

Civil recoveries

0

$508,429

$508,429

Prison time

0

27 Months

27 Months

Prison time suspended

0

0

0

Home detention

0

5 months

5 months

Probation

0

6 years

6 years

Community service

0

0

0

Source: OIG analysis of OIG investigative activity. (EPA OIG table)

*	With one or more other federal agencies.

f Sealed indictments are not included in this category; however, previously sealed indictments that were unsealed
during this reporting period are included, regardless of when the indictment occurred.

*	The "convictions" category comprises finalized convictions with completed sentencings that were filed during the
reporting period.

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Semiannual Report to Congress October 1, 2023-March 31, 2024

Table 6: Administrative actions

Administrative actions

EPA OIG only

Joint*

Total

Suspensions

Debarments

Other administrative actions*

Total

Note: This table includes data from the Office of Investigations and the Administrative Investigations Directorate.
Source: OIG analysis of OIG investigative activity. (EPA OIG table)

* With one or more other federal agencies.

Table 7: Administrative recoveries and cost savings

Administrative recoveries or cost savings

EPA OIG only

Joint*

Total

Administrative recoveries1"

Cost savings

$149,469

Note: This table includes data from the Office of Investigations and the Administrative Investigations Directorate.

Source: OIG analysis of OIG investigative activity. (EPA OIG table)

* With one or more other federal agencies.

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

Table 8: Summary of investigative reports issued and referrals for prosecution

Investigative activity

Number

Number of investigative reports issued

Number of persons referred to Department of Justice for criminal prosecution

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

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

Note: Investigative reports comprise final, interim, and supplemental Reports of Investigation and referral
memorandums. To calculate the number of referrals, we counted corporate entities as persons.

Source: OIG analysis of OIG investigative activity. (EPA OIG table)

* This number includes reports from the Office of Investigations and the Administrative Investigations Directorate
and may differ from the numbers reported in the Reports of Investigation section.

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Semiannual Report to Congress	October 1, 2023-March 31, 2024

Table 9: Subjects of employee integrity investigations

Investigation status

Political
appointee*

SES*

GS-15*

GS-14 and
below**

Total*t

Pending as of September 30, 2023

4

11

11

17

43

Open

0

0

1

12

13

Closed

0

1

1

8

10

Pending as of March 31, 2024

4

10

11

21

46

Notes: This table includes data from the Office of Investigations and the Administrative Investigations Directorate.
SES stands for Senior Executive Service. Employee integrity investigations involve allegations of criminal activity or
serious misconduct by Agency employees that could threaten the credibility of the Agency; the validity of executive
decisions; the security of personnel or business information entrusted to the Agency; or financial loss to the Agency,
such as abuse of government bank cards or theft of Agency funds.

Source: OIG analysis of OIG investigative activity. (EPA OIG table)

* Includes investigations for cases related to individuals who may also be former employees.

"t" Includes investigations for cases related to individuals who are compensated under other federal pay plans.

Figure 6: Subjects of employee integrity investigations by grade

Political
appointee

iu	—

GS-15 GS-14 and below Total

Note: Numbers of pending investigations as of March 31, 2024. Includes investigations for cases related to
individuals who may also be former employees and to individuals who are compensated under other federal
pay plans.

Source: OIG analysis of OIG investigative activity. (EPA OIG image)

Table 10: No-knock warrant statistics

No-knock entry statistics

Number of occurrences

Number of no-knock entries that occurred pursuant to judicial authorization

0

Number of no-knock entries that occurred pursuant to exigent circumstances

0

Circumstances for no-knock entries in which a law enforcement officer or other person
was injured in the course of a no-knock entry

0

Note: Section 10(c) of Executive Order 14074, Advancing Effective, Accountable Policing and Criminal Justice
Practices To Enhance Public Trust and Public Safety, requires federal law enforcement agencies to publicly post data
regarding use of no-knock entries.

Source: OIG analysis of OIG investigative activity. (EPA OIG table)

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 1

Reports Issued

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

Table A.1: Overview of evaluations, financial audits, performance audits, and projects

Evaluation or audit type

Number of reports
issued

Questioned costs
($)

Unsupported costs
($)

Funds put to better
use ($)

Evaluations in accordance with the quality standards for inspection
and evaluation. See Table A.2.

0.00

Financial audits in accordance with the generally accepted
government auditing standards. See Table A.3.

0.00

9,995,934.00

Performance audits in accordance with the generally accepted
government auditing standards. See Table A.4.

0.00

Project conducted in accordance with guidance other than the
generally accepted government auditing standards or the quality
standards for inspection and evaluation. See Table A.5.

0.00

Total

0.00

9,995,934.00

Source: OIG analysis of OIG reports. (EPA OIG table)

Table A.2: Evaluations in accordance with the quality standards for inspection and evaluation

Report
number

Report title

Report
issuance date

Questioned
costs ($)

Unsupported
costs ($)

Funds put to
better use ($)

Management
decision*

24-E-0020

The EPA's Enhanced Personnel Security Program Is on
Track, but Challenges to Full Implementation Remain

2/8/24

0.00

Yes

24-E-0021

The Office of Criminal Enforcement, Forensics and
Training Incorporated Essential Discovery Elements into
Its Policies and Procedures, but Additional Training
Could Improve Awareness

2/15/24

0.00

Yes

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October 1, 2023-March 31, 2024

Appendix 1

Report
number

Report title

Report
issuance date

Questioned
costs ($)

Unsupported
costs ($)

Funds put to
better use ($)

Management
decision*

24-E-0022

Perspectives on Capacity: Managing Drinking Water
State Revolving Fund Infrastructure Investment and Jobs
Act Funding

2/27/24

0.00

0.00

0.00

N/A

24-E-0023

The EPA Needs to Determine Whether Seresto Pet
Collars Pose an Unreasonable Risk to Pet Health

2/29/24

0.00

0.00

0.00

Some

Total

4 Reports Issued

—

0.00

0.00

0.00

—

Source: OIG analysis of OIG reports that are in accordance with the quality standards for inspection and evaluation. (EPA OIG table)

* "Yes" indicates that there was a management decision made regarding all recommendations in the report. "Some" indicates that a management decision was
made for some but not all recommendations in the report. "N/A" indicates that the report did not have any recommendations requiring a management decision.

Table A.3: Financial audits in accordance with the generally accepted government auditing standards

Report
number

Report title

Report
issuance date

Questioned
costs ($)

Unsupported
costs ($)

Funds put to
better use ($)

Management
decision*

24-F-0002

Audit of the EPA's Fiscal Years 2021 and 2020 Toxic
Substances Control Act Service Fee Fund Financial
Statements

10/12/23

0.00

0.00

0.00

Yes

24-F-0003

Audit of the EPA's Fiscal Years 2022 and 2021
(Restated) Pesticides Reregistration and Expedited
Processing Fund Financial Statements

10/17/23

0.00

0.00

0.00

Yes

24-F-0009

Audit of the EPA's Fiscal Years 2023 and 2022
(Restated) Consolidated Financial Statements

11/15/23

0.00

0.00

9,995,934.00

Yes

24-F-0017

Audit of the EPA's Fiscal Years 2022 and 2021
(Restated) Pesticide Registration Fund Financial
Statements

1/18/24

0.00

0.00

0.00

Yes

24-F-0030

U. S. Chemical Safety and Hazard Investigation Board
Fiscal Years 2023 and 2022 Financial Statement Audit

3/28/24

0.00

0.00

0.00

No

Total

5 Reports Issued

—

0.00

0.00

9,995,934.00

—

Source: OIG analysis of OIG reports that are in accordance with the generally accepted government auditing standards. (EPA OIG table)

* "Yes" indicates that there was a management decision made regarding all recommendations in the report. "No" indicates that a management decision was
not made regarding the recommendations in the report.

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Semiannual Report to Congress	October 1, 2023-March 31, 2024

Appendix 1

Table A.4: Performance audits in accordance with the generally accepted government auditing standards

Report
number

Report title

Report
issuance date

Questioned
costs ($)

Unsupported
costs ($)

Funds put to
better use ($)

Management
decision*

24-P-0001

The CSB Needs to Improve Controls over Its Charge
Card Program and Comply with Federal Requirements

10/4/23

0.00

0.00

0.00

Yes

24-P-0004

The EPA's Pollution Prevention Grant Results Aligned
with Program Goals, but a Supervisory Verification
Process Is Needed

10/19/23

0.00

0.00

0.00

Yes

24-P-0005

The EPA Needs to Better Implement Internal Access
Control Procedures for Its Integrated Risk Information
System Database

10/31/23

0.00

0.00

0.00

Yes

24-P-0011

The EPA Took Additional Actions to Strengthen Controls
to Account for and Secure Laptops

12/14/23

0.00

0.00

0.00

N/A

24-P-0012

The EPA Clean School Bus Program Could Be Impacted
by Utility Delays

12/27/23

0.00

0.00

0.00

N/A

24-P-0014

The EPA Needs to Improve the Completeness and
Accuracy of the Obligation and Outlay Information That It
Reports in USAspending.gov

1/9/24

0.00

0.00

0.00

Yes

24-P-0028

The EPA Should Improve Annual Reviews to Protect
Infrastructure Investment and Jobs Act Grants to Clean
Water State Revolving Funds

3/14/24

0.00

0.00

0.00

Yes

24-P-0029

Multiple Factors Contributed to the Delay in Constructing
Combined Sewer Overflow Tanks at the Gowanus Canal
Superfund Site in New York City

3/21/24

0.00

0.00

0.00

Yes

Total

8 Reports Issued

—

0.00

0.00

0.00

—

Source: OIG analysis of OIG reports that are in accordance with the generally accepted government auditing standards. (EPA OIG table)

* "Yes" indicates that there was a management decision made regarding all recommendations in the report. "N/A" indicates that the report did not have any
recommendations requiring a management decision.

52

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Semiannual Report to Congress	October 1, 2023-March 31, 2024

Appendix 1

Table A.5: Projects in accordance with guidance other than the generally accepted government auditing standards or the quality
standards for inspection and evaluation

Report
number

Report title

Report
issuance date

Questioned
costs ($)

Unsupported
costs ($)

Funds put to
better use ($)

Management
decision*

24-N-0018

OIG Report to the Office of Management and Budget on
the EPA's and CSB's Implementation of
Recommendations Related to Purchase and Travel Card
Programs

1/31/24

0.00

0.00

0.00

N/A

24-N-0019

OIG Report to the Office of Management and Budget on
the EPA's Semi-Annual Report on Purchase Charge
Card Violations

1/31/24

0.00

0.00

0.00

N/A

24-N-0024

Lack of Vulnerability Remediation for Weaknesses
Identified Within the Central Data Exchange System
Increases the Risk of Cyberattacks

3/5/24

0.00

0.00

0.00

N/A

24-N-0025

Central Data Exchange System Identity Data Are
Unreliable

3/5/24

0.00

0.00

0.00

N/A

Total

4 Reports Issued

—

0.00

0.00

0.00

—

Source: OIG analysis of OIG reports that are not in accordance with generally accepted government auditing standards or the quality standards for inspection and
evaluation. (EPA OIG table)

* "N/A" indicates that the report did not have any recommendations requiring a management decision.

53

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 2

Management Decisions Relating to Reports Issued During

Previous Reporting Periods

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

Table A.6: Management decisions on prior unresolved recommendations in this semiannual period

Report

Prior unresolved recommendations

Action office
or official

Management decision

Decision
date

Report No. 23-P-0022,

The EPA Could Improve Its
Review of Drinking Water State
Revolving Fund Programs to Help
States Assist Disadvantaged
Communities,
issued July 11, 2023

3. Require states to assign executed loans to
the appropriate capitalization grant in the EPA
Office of Water state revolving fund database.

Assistant
Administrator
for Water

The Agency provided a response on October 2,
2023, which outlined the EPA's planned
corrective actions for Recommendation 3.
Based on the information provided, the OIG
believes the corrective actions meet the intent
of the recommendation and, as of November 6,
2023, considers all recommendations for this
report to be resolved.

10/2/23

Report No. 23-E-0027,

The EPA Has Not Verified that Its
Laboratories Comply with
Hazardous Waste Requirements,
issued August 14, 2023

1. Implement mechanisms to verify EPA lab
compliance with hazardous waste
requirements, including small quantity
generator status renotification and large
quantity generator biennial reporting.

Assistant
Administrator
for

Enforcement

and
Compliance
Assurance

The Agency provided a response on
October 13, 2023, which outlined the EPA's
planned corrective actions for
Recommendation 1.b. Based on the information
and supporting documentation provided, the
OIG believes the corrective actions meet the
intent of the recommendation and, as of
November 9, 2023, considers all
recommendations for this report to be resolved.

10/13/23

Report No. 23-P-0003,

The EPA Met 2018 Water
Security Requirements but Needs
to Improve Oversight to Support
Water System Compliance,
issued November 21, 2022

1. In consultation with the assistant
administrator for Enforcement and
Compliance Assurance, as appropriate,
update and implement a plan for supporting
community water systems so that all water
systems comply with all certification

Assistant
Administrator
for Water

The Agency provided a response on
November 15, 2023, which outlined the EPA's
planned corrective actions for
Recommendations 1-4. Based on the
information and supporting documentation
provided, the OIG believes the corrective

11/15/23

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Semiannual Report to Congress

Report	Prior unresolved recommendations

requirements included in section 2013 of the
America's Water Infrastructure Act, for past
and future deadlines related to risk and
resilience assessments and emergency
response plans.

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

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

4.	In consultation with the assistant
administrator for Enforcement and
Compliance Assurance, as appropriate,
develop formal guidance for community water

55

October 1, 2023-March 31, 2024

Appendix 2

Action office	Decision

or official	Management decision	date

actions meet the intent of the recommendations
and, as of December 6, 2023, considers all
recommendations for this report to be resolved.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 2

Report

Prior unresolved recommendations

Action office
or official

Management decision

Decision
date

systems that clearly describes the America's
Water Infrastructure Act section 2013
requirements, including certification
deadlines, enforcement steps, and the
improvements identified as a result of
Recommendation 3. Incorporate this
guidance into the EPA's Water Supply
Guidance Manual.

Report No. 23-E-0033,

The EPA Needs to Address
Increasing Air Pollution at Ports,
issued September 21, 2023

2. Set quantifiable performance measures for
the Ports Initiative, including a plan for
identifying the measures' baselines.

Assistant
Administrator
for Air and
Radiation

The Agency provided a response on
November 16, 2023, which outlined the EPA's
planned corrective actions for
Recommendation 2. Based on the information
and supporting documentation provided, the
OIG believes the corrective actions meet the
intent of the recommendation and, as of
December 26, 2023, considers all
recommendations for this report to be resolved.

11/16/23

Report No. 23-P-0031,

The EPA Should Determine
How Its Elevation Policy Can
More Effectively Address Risks to
the Public,

issued September 7, 2023

1. Determine how the Policy on Elevation of
Critical Public Health Issues can more
effectively achieve its purpose of elevating
public health and environmental risks that
require higher levels of attention than the
Agency's usual processes could address.

Deputy
Administrator

The Agency provided a response on
January 12, 2024, which outlined the EPA's
planned corrective actions for
Recommendation 1. Based on the information
and supporting documentation provided, the
OIG believes the corrective actions meet the
intent of the recommendation and, as of
February 4, 2024, considers all
recommendations for this report to be resolved.

1/12/24

Report No. 22-E-0053,

The EPA Needs to Improve the

Transparency of Its Cancer-

Assessment Process for

Pesticides,

issued July 20, 2022

8. Conduct an external peer review on the
1,3-Dichloropropene cancer-risk assessment.

Assistant
Administrator
for Chemical
Safety and
Pollution
Prevention

The Agency provided a response on
February 17, 2024, which outlined the EPA's
planned corrective actions for
Recommendation 8. As of March 31, 2024, the
OIG was deliberating as to whether the
corrective actions meet the intent of the
recommendation.

2/17/24

Source: OIG summary of the Agency's responses regarding unresolved recommendations and the OIG's evaluation of these responses. (EPA OIG table)

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3

Reports with Corrective Action Not Completed

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

This appendix contains tables with unimplemented recommendations that the OIG issued to the EPA in
38 reports from 2008 to September 30, 2023. There are 81 unimplemented recommendations for the
EPA, with potential cost savings of $74.5 million. There are no unimplemented recommendations for the
CSB.

Below is a list of the EPA offices and regions responsible for the recommendations in the following
tables. While a recommendation may be listed as unimplemented, the Agency may be on track to
complete agreed upon corrective actions by the planned due date.

Responsible EPA Offices and Officials

DA	Deputy Administrator (within the Office of the Administrator)

OAR	Office of Air and Radiation

OCFO	Office of the Chief Financial Officer

OCSPP	Office of Chemical Safety and Pollution Prevention

OECA	Office of Enforcement and Compliance Assurance

OEJECR	Office of Environmental Justice and External Civil Rights

OLEM	Office of Land and Emergency Management

OMS	Office of Mission Support

ORD	Office of Research and Development

OW	Office of Water

Region 2
Region 3
Region 5
Region 6
Region 9
Science Advisor

57

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3

EPA Reports with Unimplemented Recommendations

Table A.7: EPA reports with unimplemented recommendations by report category

Report category

Number of unimplemented recommendations

Potential cost savings in thousands ($)

Administrative and business operations. See Table A.8.

46,707.00

Human health and environmental issues. See Table A.9.

27,800.00

Total

74,507.00

Source: OIG analysis of OIG final reports, EPA response memorandums, and inspector general responses, as well as the Agency's Enterprise Audit Management
System. (EPA OIG table)

Table A.8 provides the full text of recommendations issued to the EPA prior to this semiannual period that remain unimplemented. The table
also includes the EPA's planned corrective action completion dates as of the report issuance date and any subsequent revisions the EPA made to
those planned completion dates. The table reflects the status of recommendations as of March 31, 2024. For more information on a report,
please visit our website.

Table A.8: EPA administrative and business operations reports with unimplemented recommendations

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*

Report No. 22-P-0033,
Brownfields Program-Income
Monitoring Deficiencies Persist
Because the EPA Did Not
Complete All Certified
Corrective Actions, issued
March 31, 2022

OLEM

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

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

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

Rec. 1: Unresolved
Rec. 5: Unresolved
Rec. 6: Unresolved

Rec. 1: 9/30/27
Rec. 5: 9/30/27
Rec. 6: 9/30/24

Rec 6:
46,578.00

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*

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

OECA

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

Unresolved

11/30/22, 4/28/23,

11/30/23,

11/29/24



Report No. 22-P-0001, EPA's
Fiscal Year 2020 Fourth-
Quarter Compliance with the
Digital Accountability and
Transparency Act of 2014,
issued November 8, 2021

OMS

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

9/30/23

4/30/24



Report No. 21-P-0042, EPA
Needs to Substantially Improve
Oversight of Its Military Leave
Processes to Prevent Improper
Payments, issued December
28, 2020

OMS and
OCFO

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

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

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

5.	OMS and OCFO: Recover the approximately $11,000
in military pay related to unsupported 5 U.S.C. § 6323(a)
military leave charges, unless the Agency can obtain

Rec. 2: 4/30/22
Rec. 3: 6/30/22
Rec. 4: 9/30/21
Rec. 5: 8/31/21
Rec. 6: 8/31/21
Rec. 7: 2/28/22
Rec. 8: 2/28/22
Rec. 9: 12/1/21

Rec. 2: 7/29/22,
10/1/22,
6/30/25,
10/15/23,t
10/1/24

Rec. 3: 7/29/22,
6/3/27,
10/1/24,t
7/31/25

Rec. 4: 3/31/22,
7/29/22,
9/3/26

Rec. 5: 12/15/21,
12/30/22,
8/31/26

Rec. 6: 12/15/21,
12/30/22,
8/31/26

Rec. 5:
11.00

Rec. 6:
118.00

59

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*





documentation to substantiate the validity of the
reservists' military leave.

6.	OMS and OCFO: Submit documentation for the
reservists' military leave related to the approximately
$118,000 charged under 5 U.S.C. § 6323(b) to the
EPA's payroll provider so that it may perform payroll
audit calculations and recover any military offsets that
may be due.

7.	OMS and OCFO: Identify the population of reservists
who took unpaid military leave pursuant to 5 U.S.C. §



Rec. 7: 9/30/22,
12/31/26

Rec. 8: 12/30/22,
2/28/27

Rec. 9: 12/1/22,
12/1/24



5538 and determine whether those reservists are
entitled to receive a reservist differential. Based on the
results of this determination, take appropriate steps to
request that the EPA's payroll provider perform payroll
audit calculations to identify and pay the amounts that
may be due to reservists.

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

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

60

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*

Report No. 19-P-0195,
Pesticide Registration Fee,
Vulnerability Mitigation and
Database Security Controls for
EPA's FIFRA and PRIA
Systems Need Improvement,
issued June 21, 2019

OCSPP

2. Complete the actions and milestones identified in the
Office of Pesticide Programs' PRIA Maintenance Fee
Risk Assessment document and associated plan
regarding the fee payment and refund posting
processes.

12/31/20

12/31/22, 6/30/23,
1/31/24, 12/31/25

Report No. 17-P-0368,
Improved Management of the
Brownfields Revolving Loan
Fund Program Is Required to
Maximize Cleanups, issued
August 23, 2017

OLEM

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

3/19/19*

12/31/23, 9/30/24

Report No. 14-P-0109, Internal
Controls Needed to Control
Costs of Emergency and Rapid
Response Services Contracts,
as Exemplified in Region 6,
issued February 4, 2014

Region 6

3. Direct contracting officers to require that the
contractor adjust all its billings to reflect the application
of the correct rate to team subcontract other direct costs.

Unresolved

9/30/24

Note: An em dash (—) indicates that the column header does not apply to the report. For example, an em dash in the "revised planned completion dates" column
means that there have been no revisions to the planned completion date as of March 31, 2024, and an em dash in the "potential cost savings" column means that
no potential cost savings were identified. Unresolved means that at the time a recommendation was issued in an OIG final report, the OIG and the Agency had not
agreed on corrective actions or a planned completion date, but a date in the "revised planned completion dates" column means the matter was later resolved.

Source: OIG analysis of OIG final reports, EPA response memorandum, and inspector general responses as well as the Agency's Enterprise Audit Management
System. (EPA OIG)

* Potential cost savings is defined as questioned costs plus funds to be put to better use.

"•"The Agency revised the planned completion date; the new date is earlier than the previous revised planned completion date.

* The EPA closed out the recommendation, but the OIG determined that the corrective action was not completed. The planned completion date is the date the
Agency initially certified the recommendation was completed.

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Semiannual Report to Congress October 1, 2023-March 31, 2024

Appendix 3

Table A.9: EPA human health and environmental issues reports with unimplemented recommendations

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*

Report No. 23-P-0034, The
EPA Should Improve
Management of Great Lakes
Restoration Initiative Grants,
issued September 26, 2023

Region 5

3. In consultation with the Acquisition and Assistance
Branch, develop a records-management program for the
Great Lakes National Program Office.

4. Require periodic training and provide learning
resources on grants management to all project officers
and grant specialists, with an emphasis on
recordkeeping; cost reviews; timely, accurate, and
comprehensive baseline-monitoring reports; and other
topics determined by the results of the routine internal
review process established in Recommendation 1c.

Rec. 3: 6/30/24
Rec. 4: 6/30/24

Report No. 23-E-0033, The
EPA Needs to Address
Increasing Air Pollution at
Ports, issued September 21,
2023

OAR

1. Assess the air-monitoring network around ports and in
near-port communities and create a plan to enhance the
air-monitoring network where any gaps are identified.

2. Set quantifiable performance measures for the Ports
Initiative, including a plan for identifying the measures'
baselines.

Rec. 1: 9/30/25
Rec. 2: Unresolved

Rec. 2: 9/30/25

Report No. 23-P-0032, The
EPA Must Improve Controls
and Integrate Its Information
System to Manage Fraud
Potential in the Renewable
Fuel Standard Program, issued
September 19, 2023

OAR

3. Develop a risk-based selection process to verify
Renewable Identification Number transactions entered in
the EPA Moderated Transaction System.

4. Develop a process to reduce the likelihood of Quality
Assurance Program auditor conflicts of interest during
Quality Assurance Program reviews.

7. Integrate key applications to reduce staff burden and
to allow better oversight of Renewable Identification
Number and Renewable Fuel Standard program
requirements and engage the Office of Enforcement and
Compliance Assurance in the integration process to
ensure all inspection and enforcement data needs are
addressed in the integrated system.

Rec. 3: 12/31/24
Rec. 4: 6/30/24
Rec. 7: 9/30/28
Rec. 8: 12/31/25

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3







The EPA's planned

The EPA's









completion date at

revised planned

Potential cost



Action



the time of report

completion

savings in

Report

office

Unimplemented recommendations

issuance

dates

thousands ($)*

8. Enhance or replace the Data Analysis and Reporting
Tool to facilitate external information requests and Office
of Enforcement and Compliance Assurance inspections.

Report No. 23-P-0031, The
EPA Should Determine How Its
Elevation Policy Can More
Effectively Address Risks to the
Public, issued September 7,
2023

DA

1.	Determine how the Policy on Elevation of Critical
Public Health Issues can more effectively achieve its
purpose of elevating public health and environmental
risks that require higher levels of attention than the
Agency's usual processes could address.

2.	As necessary, develop and implement a strategy to
enhance EPA staff understanding of the circumstances
and process for implementing the Policy on Elevation of
Critical Public Health Issues.

Rec. 1: Unresolved
Rec. 2: 6/30/24

Rec. 1: 9/30/24

Report No. 23-P-0030, The
EPA Should Enhance
Oversight to Ensure that All
Refineries Comply with the
Benzene Fenceline Monitoring
Regulations, issued
September 6, 2023

OECA 1. Provide guidance to delegated authorities on what
constitutes a violation of the benzene fenceline
monitoring regulations to assist the delegated authorities
in taking action when a violation may have occurred.

2. Develop an internal strategy to address refineries that
fail to reduce their benzene concentrations to 9
micrograms per cubic meter or below after initially
exceeding the action level. The strategy should include
best practices for: a. Monitoring benzene concentrations
to determine whether a refinery has exceeded the action
level and continues to exceed 9 micrograms per cubic
meter in subsequent two-week sampling periods, b.
Verifying that the refinery submits an appropriate
corrective action plan that addresses the root cause and
actions, c. Taking action at refineries that fail to
undertake root cause analyses or implement appropriate
corrective actions—such as Clean Air Act section 114
information requests, inspections, and enforcement
actions—to reduce benzene concentrations to 9
micrograms per cubic meter, d. Coordinating between

Rec. 1: 4/1/24

Rec. 1: 10/1/24

Rec. 2: 4/1/24

Rec. 2: 10/1/24

Rec. 4: 4/1/24

Rec. 4: 10/1/24

Rec. 5: 4/1/24

Rec. 6: 10/1/24

Rec. 6: 4/1/24



63

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*





the Office of Enforcement and Compliance Assurance,
the EPA regions, and the delegated authorities.











4. Provide guidance to the EPA regions to periodically
review all reported benzene monitoring data to identify
any gaps in data for refineries.











5. In consultation with applicable EPA regions and
delegated authorities, investigate OIG-identified
benzene monitoring data gaps and ensure submission of
missing data if the data are available.











6. Provide guidance in the form of best practices to the
EPA regions for investigating missing benzene
monitoring data, securing the submission of the data if
the data are available, and evaluating enforcement
options.







Report No. 23-P-0029, The
EPA Needs to Further Refine
and Implement Guidance to
Address Cumulative Impacts
and Disproportionate Health
Effects Across Environmental
Programs, issued August 22,
2023

OEJECR

2. Develop and implement performance measures to
monitor progress in identifying and addressing
cumulative impacts and disproportionate health effects
across EPA programs.

6/30/24





Report No. 23-E-0027, The
EPA Has Not Verified that Its
Laboratories Comply with
Hazardous Waste
Requirements, issued
August 14, 2023

OECA

1.Implement mechanisms to verify EPA lab compliance
with hazardous waste requirements, including small
quantity generator status renotification and large
quantity generator biennial reporting.

Unresolved

12/31/24



Report No. 23-E-0023, The
EPA Should Update Its
Strategy, Goals, Deadlines,

Region 3

1. Lead the Chesapeake Bay Program in developing a
new strategy to specifically address nonpoint source
pollution.

Rec. 1: Unresolved
Rec. 3: Unresolved

Rec. 1: 12/31/24
Rec. 3: 12/31/24



64

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3







The EPA's planned

The EPA's









completion date at

revised planned

Potential cost



Action



the time of report

completion

savings in

Report

office

Unimplemented recommendations

issuance

dates

thousands ($)*

and Accountability Framework
to Better Lead Chesapeake
Bay Restoration Efforts, issued
July 18, 2023

Report No. 23-E-0013, The
EPA's January 2021 PFBS
Toxicity Assessment Did Not
Uphold the Agency's
Commitments to Scientific
Integrity and Information
Quality, issued on March 7,
2023

ORD,

3. Lead the Chesapeake Bay Program in developing an
effective assurance mechanism to ensure that nonpoint
source load reductions will be achieved by jurisdictions
under the Chesapeake Bay Total Maximum Daily Load.
1. ORD: Develop or update existing policies,

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

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

4.	DA: Develop or update existing policies, procedures,
or guidance to require policy-makers and decision
officials to uphold transparency through timely, formal
communication of decisions and the scientific bases to
change results or conclusions of a scientific product to
originating authors in the absence of peer review.

Rec. 1: Unresolved
Rec. 3: Unresolved
Rec. 4: Unresolved

Rec. 1: 12/31/24
Rec. 3: 9/30/24
Rec. 4: 7/31/24

Report No. 23-E-0012,
The EPA's Residential Wood
Heater Program Does Not
Provide Reasonable Assurance
that Heaters Are Properly
Tested and Certified Before
Reaching Consumers, issued
February 28, 2023

OECA
and OAR

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

Rec. 2: Unresolved.
Rec. 4: Unresolved
Rec. 5: Unresolved
Rec. 6: Unresolved

Rec. 2: 11/1/24
Rec. 4: 11/30/27
Rec. 5: 11/30/27
Rec. 6: 11/30/27

65

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*





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

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

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







Report No. 23-E-0006,

The EPA Is Not on Track to
Reach Its National Compliance
Initiative Goals to Stop
Aftermarket Defeat Devices
and Tampered Vehicles, issued
January 25, 2023

OECA

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

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

Rec. 3: Unresolved
Rec. 5: Unresolved

Rec. 3: 11/29/24
Rec. 5: 11/30/24



Report No. 22-E-0053,
The EPA Needs to Improve
the Transparency of Its
Cancer-Assessment Process
for Pesticides, issued July 20,
2022

OCSPP

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

9. Issue specific criteria requiring external peer review of
Office of Pesticide Programs' risk assessments that use
scientifically or technically novel approaches or that are
likely to have precedent-setting influence on future risk

Rec. 1: Unresolved
Rec. 9: 6/30/24

Rec. 1: 6/30/24



66

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Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*





assessments, in accordance with the Office of
Management and Budget's Final Information Quality
Bulletin for Peer Review.







Report No. 21-E-0264, EPA
Needs an Agencywide
Strategic Action Plan to
Address Harmful Algal Blooms,
issued September 29, 2021

OW

4. Assess and evaluate the available information on
human health risks from exposure to cyanotoxins in
drinking water and recreational waters to determine
whether actions under the Safe Drinking Water Act are
warranted.

12/31/22

12/31/25



Report No. 21-E-0186, EPA's
Endocrine Disruptor Screening
Program Has Made Limited
Progress in Assessing
Pesticides, issued July 28,
2021

OCSPP

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

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

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

18 pesticides.

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

Rec. 1: 9/30/25
Rec. 2: 9/30/24
Rec. 3: 9/30/24
Rec. 4: 12/31/23

Rec. 4: 12/31/25



67

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Semiannual Report to Congress

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Appendix 3







The EPA's planned

The EPA's









completion date at

revised planned

Potential cost



Action



the time of report

completion

savings in

Report

office

Unimplemented recommendations

issuance

dates

thousands ($)*

Report No. 21-P-0175, EPA
Should Conduct More
Oversight of Synthetic-Minor-
Source Permitting to Assure
Permits Adhere to EPA
Guidance, issued July 8, 2021

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

2.	In consultation with the EPA regions, develop and
implement an oversight plan to include: (a) an initial
review of a sample of synthetic-minor-source permits in
different industries that are issued by state, local, and
tribal agencies to assess whether the permits adhere to
EPA guidance on practical enforceability, including limits
that are technically accurate, have appropriate time
periods, and include sufficient monitoring, record-
keeping, and reporting requirements; (b) a periodic
review of a sample of synthetic-minor-source permits to
occur, at a minimum, once every five years; and

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

3.	Assess recent EPA studies of enclosed combustion
device performance and compliance monitoring and
other relevant information during the next statutorily
required review of40C.F.R. Part 60 Subparts OOOO
and OOOOa to determine whether revisions are needed
to monitoring, record-keeping, and reporting
requirements for enclosed combustion devices to assure
continuous compliance with associated limits, and revise
the regulatory requirements as appropriate.

Rec. 1:
Rec. 2:
Rec. 3:
Rec. 4:
Rec. 5:

10/31/23
10/31/24
12/31/24
10/31/24
12/31/23

Rec. 1: 10/31/24
Rec. 2: 10/31/25
Rec. 5: 10/31/24

68

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*





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

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







Report No. 21-E-0146, EPA
Deviated from Typical
Procedures in Its 2018
Dicamba Pesticide Registration
Decision, issued May 24, 2021

OCSPP

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

3/31/22

3/31/26*



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

OECA

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

Unresolved

4/1/24, 10/1/24



Report No. 21-P-0131, Staffing
Constraints, Safety and Health
Concerns at EPA's National
Enforcement Investigations
Center May Compromise
Ability to Achieve Mission,
issued May 12, 2021

OECA

9.	Develop and incorporate metrics on the National
Enforcement Investigations Center work environment
and culture into Office of Criminal Enforcement,
Forensics, and Training senior management
performance standards, such as results from the annual
Federal Employee Viewpoint Survey, periodic culture
audits, or other methods to measure progress.

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

Rec. 9: Unresolved
Rec. 10: Unresolved

Rec. 9: 6/28/24
Rec. 10: 6/28/24



69

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Semiannual Report to Congress

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Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*

Report No. 21-P-0130, EPA
Helps States Reduce Trash,
Including Plastic, in U.S.
Waterways but Needs to
Identify Obstacles and Develop
Strategies for Further Progress,
issued May 11, 2021

OW

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

Rec. 1: 12/31/21

Rec. 1: 6/30/22,
2/28/23,
9/1/23,
4/22/24,
8/31/24



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

OAR

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

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

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

Rec. 2: Unresolved
Rec. 3: Unresolved
Rec. 4: 9/30/24

Rec. 2: 9/30/24
Rec. 3: 9/30/28



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Semiannual Report to Congress

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Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*

Report No. 21-P-0122,
Improved Review Processes
Could Advance EPA Regions 3
and 5 Oversight of State-
Issued National Pollutant
Discharge Elimination System
Permits, issued April 21, 2021

Region 3

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

Unresolved

12/31/22,* 1/31/25



Report No. 21-P-0032,

Region 2's Hurricanes Irma
and Maria Response Efforts in
Puerto Rico and U. S. Virgin
Islands Show the Need for
Improved Planning,
Communications, and
Assistance for Small Drinking
Water Systems, issued
December 3, 2020

Region 2

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

12/31/22

6/30/23, 6/30/24



Report No. 20-E-0333,
Improved EPA Oversight of
Funding Recipients' Title VI
Programs Could Prevent
Discrimination, issued
September 28, 2020

OEJECR§

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

Rec. 1: Unresolved
Rec. 5: Unresolved
Rec. 6: Unresolved

Rec. 1: 9/30/22,
9/30/23,
9/30/24



71

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*





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

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



Rec. 5: 3/31/23,
9/30/23,
12/31/23,
6/30/24

Rec. 6: 3/31/22,
9/30/23,
9/30/24



Report No. 20-P-0173, Further
Efforts Needed to Uphold
Scientific Integrity Policy at
EPA, issued May 20, 2020

ORD /
Science
Advisor

6.	In coordination with the assistant administrator for
Mission Support, complete the development and
implementation of the electronic clearance system for
scientific products across the Agency.

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

8.	With the assistance of the Scientific Integrity
Committee, develop and implement a process specifically
to address and resolve allegations of Scientific Integrity
Policy violations involving high profile issues or senior
officials, and specify when this process should be used.

Rec. 6: 6/30/22
Rec. 7: 9/30/20
Rec. 8: 6/30/21

Rec. 6: 6/30/24

Rec. 7: 4/30/22,
6/30/22,
3/31/23,
6/30/24

Rec. 8: 6/30/22,
3/31/23,
6/30/24



Report No. 20-P-0146, EPA's
Processing Times for New
Source Air Permits in Indian
Country Have Improved, but
Many Still Exceed Regulatory
Time Frames, issued April 22,
2020

OAR

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

Rec. 1: 9/30/21
Rec. 2: 3/31/22

Rec. 1: 9/30/22,
9/30/23,
9/30/24

Rec. 2: 9/30/22,
9/30/23,
9/30/24



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October 1, 2023-March 31, 2024

Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*





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







Report No. 19-P-0207, EPA
Effectively Screens Air
Emissions Data from
Continuous Monitoring
Systems but Could Enhance
Verification of System
Performance, issued June 27,
2019

OAR

1. Develop and implement electronic checks in the
EPA's Emissions Collection and Monitoring Plan System
or through an alternative mechanism to retroactively
evaluate emissions and quality assurance data in
instances where monitoring plan changes are submitted
after the emissions and quality assurance data have
already been accepted by the EPA.

3/31/25





Report No. 18-P-0240, EPA
Needs a Comprehensive Vision
and Strategy for Citizen
Science that Aligns with Its
Strategic Objectives on Public
Participation, issued
September 5, 2018

DA

2. Through appropriate EPA offices, direct completion of
an assessment to identify the data management
requirements for using citizen science data and an
action plan for addressing those requirements, including
those on sharing and using data, data format/standards,
and data testing/validation.

12/31/20

3/31/23, 12/31/23,
6/30/24



Report No. 18-P-0080, EPA
Needs to Evaluate the Impact
of the Revised Agricultural
Worker Protection Standard on
Pesticide Exposure Incidents,
issued February 15, 2018

OCSPP

1. In coordination with the Office of Enforcement and
Compliance Assurance, develop and implement a
methodology to evaluate the impact of the revised
Agricultural Worker Protection Standard on pesticide
exposure incidents among target populations.

Unresolved

12/31/22,
12/31/23, 6/28/24



Report No. 16-P-0275, EPA
Has Not Met Certain Statutory
Requirements to Identify
Environmental Impacts of
Renewable Fuel Standard,
issued August 18, 2016

OAR

2.	Complete the anti-backsliding study on the air quality
impacts of the Renewable Fuel Standard as required by
the Energy Independence and Security Act.

3.	Determine whether additional action is needed to
mitigate any adverse air quality impacts of the
Renewable Fuel Standard as required by the Energy
Independence and Security Act.

Rec. 2: 9/30/24
Rec. 3: 9/30/24





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Appendix 3

Report

Action
office

Unimplemented recommendations

The EPA's planned
completion date at
the time of report
issuance

The EPA's
revised planned
completion
dates

Potential cost

savings in
thousands ($)*

Report No. 10-P-0224, EPA
Should Revise Outdated or
Inconsistent EPA-State Clean
Water Memoranda of
Agreement, issued
September 14, 2010

2-2. Develop a systematic approach to identify which
states have outdated or inconsistent memorandums of
agreements; renegotiate and update those
Memorandums of Agreements using the Memorandum
of Agreements template; and secure the active
involvement and final, documented concurrence of
headquarters to ensure national consistency.

9/28/18

9/30/20, 9/30/22,
9/30/23, 4/30/25

Report No. 08-P-0196, Making
Better Use of Stringfellow
Superfund Special Accounts,
issued July 9, 2008

Region 9

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

12/31/12

9/30/23, 9/30/26

27,800.00

Note: An em dash (—) indicates that the column header does not apply to the report. For example, an em dash in the "revised planned completion dates" column
means that there have been no revisions to the planned completion date as of March 31, 2024, and an em dash in the "potential cost savings" column means that
no potential cost savings were identified. Unresolved means that at the time a recommendation that was issued in an OIG final report, the OIG and the Agency had
not agreed on corrective actions or a planned completion date, but a date in the "revised planned completion dates" column means the matter was later resolved.

Source: OIG analysis of OIG final reports, EPA response memorandum, and inspector general responses as well as the Agency's Enterprise Audit Management
System. (EPA OIG)

* Potential cost savings is defined as questioned costs plus funds to be put to better use.

"'"The OCSPP completed this corrective action on February 16, 2022. That was the date the OCSPP held its first annual training series on the office's
commitment to the Scientific Integrity Policy and principles and to promote a culture of scientific integrity. March 31, 2026, is the OCSPP's planned final training
date. The OCSPP has completed annual trainings for 2022 and 2023 on time and plans to host annual trainings until 2026 to implement this recommendation.

* This date was provided to the OIG by Region 3 in its June 17, 2021 response to the OIG's final report. The OIG accepted the proposed corrective action and
planned completion date for Recommendation 3, while Recommendations 1 and 2 remained unresolved. The OIG and Region 3 corresponded several times
about Recommendation 2, including a briefing held by Region 3 on October 25, 2021. In a memorandum dated December 13, 2021, the OIG accepted
Region 3's proposed corrective actions to address Recommendation 2 but did not receive a revised planned completion date. After the OIG accepted the
proposed corrective actions for Recommendation 2, Region 3 provided a revised planned completion date, which is reflected above.

§ These recommendations were originally made to the OGC. The Agency requested that the OEJECR take over responsibility for these recommendations.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 4

Closed Investigations Involving Senior Employees

Section 5(a)(13) of the Inspector General Act, 5 U.S.C. § 405, requires that we report on each
investigation involving a senior government employee in which allegations of misconduct were
substantiated. Section 5(a)(16) of the Act requires a detailed description of the particular circumstances
of any investigation conducted by the OIG involving a senior government employee that is closed and
was not disclosed to the public. Below are details on each investigation we conducted involving senior
employees that were not already reported in the previous sections of this document and that we closed
during this semiannual reporting period.

Case Number: OI-DC-2023-ADM-0148

An EPA Senior Executive Service employee allegedly enabled automatic forwards from the employee's
government email account to the employee's personal email account without authorization. The
investigation determined that the employee did not enable an automatic forward of emails, nor did the
employee violate any administrative privacy or rules-of-behavior policies. The allegation was not
supported.

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Semiannual Report to Congress

October 1, 2023-March 31, 2024

Appendix 5

Peer Reviews Conducted

Section 5(a)(8) of the Inspector General Act, 5 U.S.C. § 405, requires an appendix containing the results
of any peer review conducted of the EPA OIG by another OIG during the reporting period or, if no such
peer review was conducted, a statement identifying the date of the last peer review conducted of the
EPA OIG by another OIG. Section 5(a)(9) of the Act requires a list of any outstanding recommendations
from any peer review conducted of the EPA OIG by another OIG that have not been fully implemented.
Section 5(a)(10) of the Act requires a list of all peer reviews conducted by the EPA OIG of another OIG
during the reporting period, including a list of any recommendations from any previous peer review that
remain outstanding.

In this semiannual period, the EPA OIG initiated an external peer review of the investigative organization
of the Department of Transportation OIG. Our review covers the period from October 1, 2022, through
September 30, 2023. This review is being conducted in accordance with the Quality Assessment Review
Guidelines for Investigative Operations of Federal Offices of Inspector General, as set forth by the Council
of the Inspectors General on Integrity and Efficiency.

Below are details regarding the most recent peer reviews that another OIG conducted of the EPA OIG.
There are no outstanding recommendations from these peer reviews.

Audit

The Treasury Inspector General for Tax Administration OIG issued the most recent peer review report on
the EPA OIG on April 15, 2021. The peer review covered the three-year period ending September 30,
2020, and found that the EPA OIG suitably designed and complied with its system of quality control to
provide the EPA OIG with reasonable assurance that it performed and reported work in conformity with
applicable professional standards in all material respects. The EPA OIG received an external peer review
rating of "pass."

Investigation

The Amtrak OIG completed the most recent mandated Council of the Inspectors General on Integrity
and Efficiency quality assurance review of our Office of Investigations and issued its related report on
August 3, 2023. The Amtrak OIG determined that our system of internal safeguards and management
procedures for the investigative operations complied with the Council of the Inspectors General on
Integrity and Efficiency quality standards and other applicable guidelines and statutes. The Amtrak OIG
determined that our safeguards and procedures provided reasonable assurance that we conformed to
professional standards in planning, executing, and reporting EPA OIG investigations and using law
enforcement powers.

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Semiannual Report to Congress	October 1, 2023-March 31, 2024

Appendix 6

OIG Contact Information

To report potential fraud, waste, abuse, misconduct, or mismanagement,
contact the OIG Hotline:

Online	Phone

Hotline complaint form	(888)546-8740

Email

OIG.Hotline@epa.gov

For congressional and media inquiries, contact the Office of Congressional and
Public Affairs using the information below:

Phone	Email

(202) 566-2391	OIG.PublicAffairs@epa.gov

To submit a general comment or question about the EPA Office of Inspector
General, contact us via one of the following methods:

Online	Mail

Contact form	Environmental Protection Agency

Office of Inspector General
Phone	1200 Pennsylvania Avenue, N.W.

(202) 250-8800	Mail Code: 2410T

Washington, D.C. 20460

To suggest projects or provide input
us via one of the following methods:

Email

OIG WEBCOMMENTS@epa.gov (Use the
subject "Suggestions for Projects")

Phone

(202)566-2391

to our project notifications, contact

Mail

Environmental Protection Agency
Office of Inspector General
1200 Pennsylvania Avenue, N.W.
Mail Code: 2431T
Washington, D.C. 20460

77

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Whistleblower Protection

U.S. Environmental Protection Agency
The whistleblower protection coordinator's role
is to educate Agency employees about
prohibitions against retaliation for protected
disclosures and the rights and remedies against
retaliation. For more information, please visit
the OlG's whistleblower protection webpaqe.

Contact us:

Congressional Inquiries: OIG.CongressionalAffairs(5)epa.gov

Media Inquiries: QIG.PublicAffairs@epa.gov
line EPAOIG Hotline: OIG.Hotline@epa,gov

w Web: epaoig.gov

Follow us:

X (formerly Twitter): ffiepaoig

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

0] Instagram: 5)epa.ig.on.ig

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