U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Early Warning Report: 

Main EPA Headquarters 

Warehouse in Landover, 

Maryland, Requires 

Immediate EPA Attention 

Report No. 13-P-0272 May 31, 2013 

Scan this mobile 

code to learn more 

about the EPA OIG. 
 

 

	 

Report Contributors: Robert Adachi 

 Angela Bennett 

 Safiya Chambers 

 Debra Coffel

 Kevin Collins 

 Teren Crawford 

 Nancy Dao 

Michael D. Davis 

Kevin Haas 

 Iantha Maness 

 John Trefry 

Abbreviations 

EPA U.S. Environmental Protection Agency 

OIG Office of Inspector General 

Cover photo:	 Various photos at the EPA warehouse operated by a contractor in Landover, 

Maryland. Clockwise, from left: an outside view of the warehouse; a cubicle 

space at the warehouse for personal use; an exercise area at the warehouse; and 

passports stored at the warehouse in unprotected space. (EPA OIG photos) 

Hotline 

To report fraud, waste, or abuse, contact us through one of the following methods: 

email: OIG_Hotline@epa.gov write: EPA Inspector General Hotline 

phone: 1-888-546-8740 1200 Pennsylvania Avenue, NW 

fax: 202-566-2599 Mailcode 2431T 

online: http://www.epa.gov/oig/hotline.htm Washington, DC 20460 
 

 

 


 

	 

	 


 


 

U.S. Environmental Protection Agency 13-P-0272 

May 31, 2013 Office of Inspector General 

At a Glance
 

Why We Did This Review 

The U.S. Environmental 

Protection Agency leases a 

warehouse in Landover, 

Maryland, to store inventory for 

its headquarters locations. 

The inventory ranges from 

sensitive items such as 

personally identifiable 

information, including 

passports, to computers and 

other electronic equipment to 

basic personal property such 

as paper and office furniture. 

We are conducting an audit to 

determine the extent to which 

the EPA’s personal property 

stored in select warehouse 

spaces is effectively utilized, 

accounted for and disposed of 

by the EPA. As a result of our 

warehouse visits, we are 

issuing this early warning report 

on our concerns at the 

Landover warehouse because 

they require immediate 

attention. 

This report addresses the 

following EPA Goals or 

Cross-Cutting Strategies: 

 Strengthening EPA’s 

workforce and capabilities. 

For further information, contact 

our Office of Congressional and 

Public Affairs at (202) 566-2391. 

The full report is at: 

www.epa.gov/oig/reports/2013/ 

20130531-13-P-0272.pdf 

Early Warning Report: Main EPA Headquarters Warehouse 

in Landover, Maryland, Requires Immediate EPA Attention 

What We Found 

Our initial research at the EPA’s Landover warehouse raised significant concerns 

with the lack of agency oversight of personal property and warehouse space at 

the facility. In particular: 

 The warehouse recordkeeping system was incomplete and inaccurate. 

 The warehouse was filled with considerable valuable amounts of unusable, 

inoperable and obsolete furniture and other items. 

 The warehouse contained multiple unauthorized and hidden personal 

spaces that included such items as televisions and exercise equipment. 

	 Numerous potential security and safety hazards existed at the warehouse, 

including unsecured personally identifiable information (such as 

passports). 

	 Deplorable conditions existed at the warehouse; corrosion, vermin feces, 

mold and other problems were pervasive. 

As a result of the conditions noted, EPA property at the warehouse was 

vulnerable to theft and abuse (including personally identifiable information), 

EPA property was not properly maintained, the EPA may not have received 

sufficient value for the funds it paid for the warehouse’s operation, and 

warehouse workers were subjected to unsafe conditions for which the EPA could 

be held liable.

 Agency Corrective Actions 

Subsequent to our briefing to the agency on the conditions noted at the 

warehouse, the agency issued a stop work order to the contractor, ensuring there 

will be no further access to the site by contractor personnel and that no further 

costs will be incurred under the contract. Further, the agency has taken the 

following additional actions: 

 Completed an inventory of the warehouse and is seeking an appraisal of 

inventoried items.
 

 Identified and segregated all surplus furniture. 

 Reviewed background investigations on warehouse employees.
 

 Removed flammable materials from the warehouse. 

 Performed a health and safety review. 

 Reviewed security footage. 

The agency also agreed to initiate action addressing personally identifiable 

information, completing standard operating procedures for the warehouse, 

developing security plans, and conducting an agencywide review of all 

warehouse and storage facility operations. 
 

 

 

 

	 

	 

	 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

May 31, 2013 

MEMORANDUM 

SUBJECT:	 Early Warning Report: 

Main EPA Headquarters Warehouse in Landover, Maryland, 

Requires Immediate EPA Attention 

 Report No. 13-P-0272 

FROM:	 Arthur A. Elkins Jr. 

TO:	 Craig Hooks, Assistant Administrator 

 Office of Administration and Resources Management 

The Office of Inspector General is conducting an audit to determine the extent to which the 

U.S. Environmental Protection Agency’s personal property stored in select warehouse spaces is 

effectively utilized, accounted for and disposed of by the agency (Project No. OA-FY13-0248). This 

early warning report provides information obtained during our review at the Landover facility. While we 

continue our ongoing audit of select warehouse spaces, we believe the agency should immediately 

address the issues at the Landover facility discussed in this early warning report. 

In accordance with EPA Manual 2750, you are required to provide a written response to this report 

within 60 calendar days. Your response will be posted on the OIG’s public website, along with our 

comments on your response. Your response should be provided in an Adobe PDF file that complies with 

the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended. If your 

response contains data that you do not want to be released to the public, you should identify the data for 

redaction. You should include a corrective actions plan for agreed-upon actions, including milestone 

dates. We have no objections to the further release of this report to the public. This report will be 

available at http://www.epa.gov/oig. 

If you have any questions, please contact Richard Eyermann, acting assistant inspector general for the 

Office of Audit, at (202) 566-0565 or eyermann.richard@epa.gov; or Mike Davis, director for efficiency 

audits, at (513) 487-2363 or davis.michaeld@epa.gov. 
 

 

 

Introduction 

The U.S. Environmental Protection Agency leases a warehouse in Landover, 

Maryland, to store inventory for its headquarters locations. The warehouse is 

owned by the U.S. General Services Administration but is operated by a 

contractor under a contract awarded May 3, 2007. The inventory ranges from 

sensitive items such as computers and other electronic equipment to basic 

personal property such as letterhead paper and office furniture. The facility has a 

lease cost of approximately $750,000 per year. The 70,000-square-foot leased 

facility represents one of the agency’s largest warehouses. This early warning 

report conveys significant, time-critical issues to the EPA management regarding 

the Landover warehouse found during our initial research at the facility that we 

believe require immediate attention. 

Conclusion 

Our initial research at the EPA’s Landover warehouse raised significant concerns 

with the lack of agency oversight of personal property and warehouse space at the 

facility. EPA management confirmed they had not visited the warehouse before 

the Office of Inspector General briefed the agency over concerns with poor 

oversight of the storage facility. According to Office of Management and Budget 

Circular A-123, Management’s Responsibility for Internal Control, internal 

controls should be designed to provide reasonable assurance regarding prevention 

and prompt detection of unauthorized use or disposition of assets. However, we 

noted the following issues regarding the warehouse: 

 The warehouse recordkeeping system was incomplete and inaccurate. 

 The warehouse was filled with considerable amounts of unusable, 

inoperable and obsolete furniture and other items. 

 The warehouse contained multiple unauthorized and hidden personal 

spaces that included such items as televisions and exercise equipment. 

 Numerous potential security and safety hazards existed at the warehouse, 

including unsecured personally identifiable information (such as passports). 

 Deplorable conditions existed at the warehouse; corrosion, vermin feces, 

mold and other problems were pervasive. 

As a result of the conditions noted, EPA property at the warehouse was vulnerable 

to theft and abuse (including personally identifiable information), EPA property 

was not properly maintained, the EPA may not have received sufficient value for 

the funds it paid for the warehouse’s operation, and warehouse workers were 

subjected to unsafe conditions for which the EPA could be held liable. 

The conditions described required immediate attention. 

On May 16, 2013, we briefed the agency on the warehouse conditions 

(http://www.epa.gov/oig/reports/2013/20130531-13-P-0272_briefing.pdf). 

Subsequent to our briefing, the agency took or initiated a number of corrective 

13-P-0272 1 
 

 

 

   

	 

	 

	 

	 

	 

	 

	 

actions. This included issuing a stop work order to the contractor. The agency’s 

response is in appendix A. Details on what we found follow. 

1. Inventory Record System 

The warehouse recordkeeping system is incomplete and inaccurate. The system 

does not accurately reflect the contents, condition, location or dollar value of the 

new or surplus items stored in the warehouse. The OIG tested 11 items from the 

inventory system identified as located in the cage (the secured area for sensitive 

items), and found the following for six of the 11 items: 

●	 Four items in the inventory system were not located in the cage. 

●	 One item had an incorrect quantity. 

●	 One item had an incorrect serial number. 

We also noted many additional items stored in the cage that were not on the 

inventory report, such as new desktop computers purchased in 2005 and boxes of 

archived records. Further, we found high value items outside the cage that should 

have been secured, such as portable refrigeration units. 

From left: a photo of the cage; items recorded with incorrect serial numbers; and 

high value items (portable refrigeration units) outside the cage. (EPA OIG photos) 

2. Warehouse Contents 

The warehouse is operating as a long-term storage facility filled with considerable 

amounts of unusable, inoperable and obsolete furniture and other miscellaneous 

items. There is not efficient rotation of paper stock, resulting in outdated, 

damaged and unusable paper and print shop materials. In addition, most of the 

warehouse space did not appear to be efficiently used. Our observations raised 

concerns about the efficiency of EPA’s policy for obtaining and storing property. 

In particular, we observed: 

●	 New appliances received in 2007 still in the original packaging that had 

never been opened. 

●	 New, unused furniture received in 2008. 

●	 Large amounts of carpet and ceiling tiles. 

●	 Large amounts of stationery and office supplies. 

13-P-0272 2 
 

 

   

 

Other miscellaneous items stored in the warehouse that call in to question the 

effectiveness of the EPA’s personal property and warehouse management policies 

and processes include musical instruments, boxes of gold embossed EPA mugs, 

and archive files from the 1990s. 

 From left: refrigerators received in 2007; pianos; and boxes of letterhead. (EPA OIG photos) 

3. Personal Use Items 

The warehouse contained multiple unauthorized and hidden personal spaces created 

by and for the workers that included televisions, refrigerators, radios, microwaves, 

chairs and couches. These spaces contained personal items, including photos, pin ups, 

calendars, clothing, books, magazines and videos. The unauthorized personal spaces 

were arranged so that they were out of sight of security cameras through the use of 

screens, partitions and piled-up boxes. 

Photos showing examples of unauthorized personal spaces. (EPA OIG photos) 

13-P-0272 3 
 

 

 

The warehouse contained surplus gym equipment arranged to create exercise 

space for warehouse employees. The weights, machines, exercise equipment, and 

overall exercise area appeared to be well maintained. The exercise space was in 

excess of 30 by 45 feet. Carpet tiles from EPA inventory were placed on the floor 

in the gym area. This area has electrical power through an EPA power strip and 

provides music through other agency inventory items. Agency steno pads were 

used for recording workouts. These conditions raise questions about time charges 

made by warehouse employees under the contract. These conditions also present 

potential fire and insurance hazards if warehouse employees or others get hurt. 

An example of a gym area in the warehouse. (EPA OIG photo) 

4. Security and Safety Issues 

The warehouse was not adequately maintained. Potential security and safety 

hazards existed in the warehouse. The current conditions left warehouse contents 

vulnerable to theft and abuse and can jeopardize the health and safety of workers. 

There were unsecured racks (shelves) and poorly balanced inventory items that 

hung over the upper edges of the racks. Many items were unsecured on pallets with 

their bindings removed, and many boxes on pallets were open. Personal spaces 

were powered by multiple electrical cords that may cause overloads, resulting in 

potential fire hazards. Propane was stored and trucks were parked inside the 

building. Other vehicles containing gasoline were being stored in an enclosed area. 

Surplus computers stored at the warehouse represent potential concerns with the 

disposal procedures for such electronic items. Limited camera coverage 

throughout the facility could allow employees to avoid monitoring. There was a 

locked office inside the facility for which we could not determine a purpose. 

Personally identifiable information and agency sensitive files – such as passports 

and legal files – were located in unsecured open boxes throughout the warehouse. 

Old archived files located in the warehouse dated back to 1992 and raise concerns 

with the EPA’s processes and controls for personal property and warehouse space. 

13-P-0272 4 
 

 

 

 

 

From left: safety risks posed to personnel in the warehouse include wooden pallets with boxes hanging 

over the edge of shelves, and unbound and opened boxes still on pallets that are beginning to collapse; 

security risks include improper handling of passports. (EPA OIG photos) 

5. General Warehouse Conditions 

Deplorable conditions existed in the warehouse. Door jambs were corroded; 

dirt, dust and vermin feces were pervasive; and several items were rotting and 

potentially hazardous. We observed refrigerators with mold, and old computer 

bags molding and rotting. The warehouse contained large amounts of surplus 

items and copy paper stored in different places throughout the warehouse. 

From left: an example of corrosion; dusty and opened boxes; and moldy computer bags. 

(EPA OIG photos) 

13-P-0272 5 
 

 

	 

	 

	 

Agency Corrective Actions 

Subsequent to our briefing to the agency on the conditions noted at the 

warehouse, the agency issued a stop work order to the contractor, ensuring 

there will be no further access to the site by contractor personnel and that no 

further costs will be incurred under the contract. Further, the agency has taken 

the following additional actions: 

	 Completed an inventory on the contents of the warehouse and is 

working on getting the inventory appraised. 

 Identified and segregated all surplus furniture. 

 Reviewed background investigations on warehouse employees. 

 Removed flammable materials, including propane tanks, from the 

warehouse. 

 Performed a health and safety review, and began to develop a 

remediation plan to eliminate security and safety issues. 

 Reviewed security footage for May 17, 2013, and the 7 preceding days. 

The agency has also committed to completing the following tasks: 

	 Identify any potential breaches of personally identifiable information 

located in the warehouse. 

	 Complete standard operating procedures in various areas of warehouse 

operations, including the identification or designation and safeguarding 

of records and personally identifiable information. 

 Develop security plans on both internal and external measures. 

 Conduct an agencywide review of all warehouse and storage facility 

operations. 

We are encouraged by the speed and depth of the actions taken by the agency 

to address the conditions at the warehouse. We believe that the agency should 

evaluate their warehouse needs to determine the correct space and resource 

requirements. The agency should also implement procedures to ensure that the 

conditions are not repeated in the future. In particular, agency personnel, 

including senior management, should conduct periodic inspections of 

warehouse operations to ensure propriety. 

13-P-0272 6 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 2046 0 

MAY 2 3 2013 

OFFICE OF THE 

ADMINISTRATOR 

MEMORANDUM 

SUBJECT: Conditions at the U.S. Environmental Protection Agency's Warehouse in Landover, 

Maryland 	 A~ . A.~1 11 ~ 

FROM: Bob Perciasepe, Acting Administrator {!;;{J 

TO: Arthur A. Elkins, Jr., Inspector General 

I wish to thank you and your staff for bringing to my attention the conditions at the U.S. Environmental 

Protection Agency 's warehouse in Landover, Maryland. Given the significance ofthe issues raised by 

the Office ofinspector General in a preliminary briefing to me on May 15,2013, and in a second 

briefing to Nanci Gelb, principal deputy assistant administrator for the Office of Administration and 

Resource Management, on May 16, 2013, the EPA has taken immediate, aggressive actions to address 

the situation even before receiving recommendations for action in your forthcoming early warning letter. 

Once the EPA receives that letter, we will quickly review any recommendations ofthe OIG that we have 

not yet addressed. We look forward to working with OIG staff on remedying the immediate concerns at 

the facility and determining th e need for new and enhanced policies and procedures to prevent a similar 

si tuation from occurring again at the EPA. 

As detailed below, since receiving these briefings, the EPA has : 

• 	 issued a stop-work order to Apex Logistics, LLC, ensuring there will be no further access to the 

site by Apex personnel and that no further costs will be incurred under the Apex contract; 

• 	 re-secured the facility, including rekeying all exterior doors and remediating key worker safety 

concerns; 

• 	 inventoried and catalogued 100 percent ofthe items at the warehouse, excluding one class of 

furniture that requires the assistance ofthe manufacturer for cataloguing; 

• 	 identified, marked and segregated all surplus furniture, which will enable the reuse ofthe 


furniture by the General Services Administration; 


• 	 drafted new standard operating procedures for interacting with and maintaining the warehouse, 

which the EPA intends to implement expeditiously; 

• 	 consulted with the U.S. Department ofState and implemented immediate changes to existing 

procedures to ensure safe handling of expired or no longer needed government passports; 

• 	 initiated an investigation and review by the agency's Breach Evaluation Team to evaluate any 

potential concerns with the safeguarding of personally identifiable information and to make 

recommendations as to how to address any breach or potential breach ofthe EPA's procedures to 

protect such information; 

• 	 commenced a review ofthe EPA's records program to identify and strengthen any policies and 

procedures addressing the transport, storage, access and disposition of agency records, including 

records that contain personally identifiable information; 

Internet Address (URL) • http://www.epa .gov 

RecycledJRecyclable • Printed with Vegetable Oil B ased Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
• 	 began a review ofEPA personnel to determine whether any agency employees failed to perform 

their duties and, if so, what type of remedial or disciplinary action is appropriate; and 

• 	 ordered an agencywide review of warehouses and storage facilities, incl uding directions to EPA 

senior managers to evaluate the conditions at all warehouses and storage facilities by the close of 

business on Thursday May 23,2013. 

Chronology of Actions by the EPA to Date 

Actions Taken on Friday, May 17, 2013 

Upon receiving a briefmg by the OIG, the EPA took immediate action to remedy this situation. On 

Friday, May 17, 2013, OARM Principal Deputy Assistant Administrator Nanci Gelb and senior agency 

officials from OARM conducted a site visit to the warehouse and developed a plan of action. At 11 a.m. 

on May 17, 2013, OARM officials convened a meeting ofsenior managers from OARM, including 

those from OARM's Office ofAdministration, Office of Acquisitions Management and Office of Grants 

and Debarment; the Office ofGeneral Counsel; the Office of International and Tribal Affairs; the Office 

ofEnvironmental Information; and the Office ofExternal Affairs and Environmental Education to 

discuss each office's role and responsibilities in that action plan. Each office or sub-office left the 

meeting with clear direction on immediate steps to take in response to the warehouse conditions. 

By 4 p.m. on May 17,2013, the EPA had taken critical actions to remove Apex Logistics, LLC 

employees from the warehouse and to secure the site. The agency issued a stop-work order to Apex, 

immediately preventing Apex from completing any additional work under the contract or from incurring 

any additional reimbursable expenses under the contract. The Office of Acquisitions Management also 

determined this was the only contract Apex held with the EPA. The EPA's security staff confiscated the 

EPA contractor badges that had been issued to Apex personnel that were onsite and escorted those 

personnel off the premises. Contractor employees not at the site on May 17, 2013, had their access 

badges terminated remotely on May 17, 2013, as well. The EPA rekeyed all perimeter doors to ensure 

no future access by Apex personnel. The agency evaluated the security-camera system at the facility, 

determined that the most recent eight days ofsecurity-camera recordings were stored on a computer 

hard drive at the facili ty and conducted an initial review ofthe recordings. The EPA reset the warehouse 

intrusion-detection system to ensure that the system could be activated and deactivated by only the EPA. 

The EPA also contacted the warehouse landlord to update the landlord on the situation and seek 

assistance in controlling the site. The agency began the process of cataloguing and indexing the contents 

ofthe warehouse. Finally, the agency secured the services of a new contractor and several staff ofthe 

EPA to assess the facility during the weekend ofMay 18-19, 2013. Those actions are discussed below. 

In addition to the efforts to secure the facility on or before Friday May 17, 2013, the EPA took key 

actions within the agency to address information security issues identified by OIG. OIT A contacted the 

Department of State to determine an interim standard operating procedure for the decommissioning of 

expired or no longer needed government passports for agency personnel. Beginning immediately, the 

EPA will send expired or urmeeded government passports to the Department ofState for destruction, 

until such time as the agency can put in place a passport decommissioning process with the appropriate 

safeguards. OEI determined that the presence of documents containing personally identifiable 

information at the warehouse, when considered in light ofthe other conditions at the warehouse, 

warranted referring the matter to the EPA's Breach Evaluation Team. The Breach Evaluation Team 

comprises EPA senior career employees and is tasked with evaluating any breaches or potential breaches 

ofthe EPA's procedures for safeguarding personally identifiable information and determining 

appropriate responses to any breach or potential breach. OARM's Office ofGrants and Debarment 

began the process ofdetermining whether the problems identified with Apex's performance ofthis 
contract provide grounds for a suspension action. If suspended, Apex would be temporarily excluded 

from receiving future contracts from the EPA and other federal agencies. 

Actions Taken by the EPA on Saturday, May 18,2013, and Sunday, May 19,2013 

EPA personnel worked at the warehouse with new contract employees during the weekend of May 18­

19, 2013 , to continue to evaluate and secure the site . The EPA initiated a health and safety review of the 

warehouse. The agency removed all propane tanks that had been brought onsite by Apex employees and 

secured those tanks outside of the building. Finally, the agency reoperationalized the facility's eye wash 

station for the safety ofthe workers in the building. 

The EPA also made significant progress creating a new inventory ofthe warehouse ' s contents. By the 

end ofthe weekend, the agency had numbered and labeled all aisles and shelves in the warehouse. The 

EPA completed an inventory of all items in the warehouse, except for stationery and a single class of 

furniture that must be inventoried by the manufacturer. One hundred percent of that inventory was 

entered into a spreadsheet to enable accurate tracking moving forward. Staff from OARM identified, 

marked and segregated all surplus furniture, i.e. furniture no longer needed by the EPA. By designating 

serviceable furniture as surplus, the EPA begins a process where that furniture will be made available to 

other agencies through the General Services Administration. With regard to stationery, the EPA 

completed an inventory of approximately 75 percent of the stationery on site. Finally, the agency 

evaluated all of the boxes of documents on site to assess whether the boxes contained personally 

identifiable information. The review confirmed that some boxes did contain personally identifiable 

information in a range of dates. Any boxes that contained even a single document containing personally 

identifiable information were moved to a gated, locked and secured section of the warehouse. All 

information learned about the presence of personally identifiable information has been and will continue 

to be conveyed to the Breach Evaluation Team for consideration. 

Actions Taken by the EPA on Monday, May 20, 2013 

The EPA continued its aggressive response on Monday, May 20, 2013. On that day, the agency 

completed its inventory of all stationery at the warehouse. With the inventory ofthe stationery 

completed, the agency finalized the spreadsheet cataloguing an inventory of all items at the site, except 

for one type offurniture for which assistance from the manufacturer is required. The EPA began the 

development of a new security plan for the facility that focuses on both internal and external security 

measures. This plan will include specifying locations where additional cameras will be placed, how 

many days of recordings will be preserved for each camera, how often the recordings will be reviewed 

and any other appropriate security measures. Once the new security plan is in place, the EPA will 

develop critical standard operating procedures to implement the plan. The EPA also neared completion 

of its review of the numerous examples of government form 5100, which is the form the agency uses to 

request action by Apex under the contract. The EPA will use these forms to help identify the source of 

the various documents and furniture contained at the site. Finally, the agency continued work on the 

finalization of interim SOPs to safeguard agency documents and resources until permanent SOPs can be 

established. The SOPs address operational and management procedures and specify internal controls 

relating to inventory, acquisition, performance reviews and management. 

The EPA also continued to take actions and evaluate possible actions with regard to Apex Logistics, the 

contractor at the facility. While the EPA's stop-work order would prevent Apex from conducting 

additional work through the current end date of the contract of May 28, 2013, the agency began a legal 

analysis to determine whether the EPA could terminate the contract for cause before May 28, 2013. 

OARM ' s Office of Grant s and Debarment and Office of Acquisitions Management continued to work 

with OGC and OIG to determine whether suspension or debarment of Apex from future government 

3 
contracts can be supported by the facts available. The EPA reviewed agency background investigations 

of Apex employees to help inform future actions. The agency took control of any computers that 

appeared to have been used by Apex personnel. OARM will work with OEI and OIG to recover any 

information relevant to the situation that is contained on those computers. 

Actions Taken by the EPA on Tuesday, May 21,2013 

On Tuesday, May 21 , 2013, the EPA took additional steps to address the situation. At 8 a.m. OARM's 

Gelb reconvened a group ofsenior agency officials, including OARM senior officials and those from 

OARM' s Office of Administration, Office of Acquisitions Management and Off1ce of Grants and 

Debarment as well as those from OGC, OEI and OEAEE. Each office reported on their actions taken to 

date and key next steps. At 9 a.m. Gelb and representatives from OGC, OEI, OEAEE, OITA, the Office 

of the Administrator and the Office ofCongressional and Intergovernmental Relations briefed me on the 

agency ' s actions in response to the briefings by OIG, the current conditions of the warehouse and the 

plan for continued action. 

At that meeting, I directed those present to evaluate the conditions at all warehouses and storage 

facilities used by the EPA and to take swift action to remedy any concerns identified with the conditions 

at any of those facilities. Later that day, OARM directed all assistant regional administrators to ensure 

that all organizations with warehouse or storage facilities conduct a thorough walk-through of their 

facilities and report the results of that walk-through to OARM by the close of business on Thursday, 

May 23,2013. The assistant regional administrators were instructed that the walk-through should ensure 

that: 

1) there are standard operating procedures and inventory systems in place that account for 1 00 

percent of all equipment, vehicles, materials and supplies that are located in the facility; 

2) any and all equipment, vehicles, materials and supplies are stored in an efficient, organized and 

safe manner; 

3) 	 there are standard operating procedures that clearly define the roles and responsibilities of all 

personnel- either contractor or federal employee -that are responsible for managing and 

operating the warehouse or storage facility; 

4) for any contractor-run warehouse or storage facility, that there are procedures in place that 

ensure robust federal oversight of the contract; 

5) all safety and health requirements for the facility are in place and that all s afety and health 

equipment is operational; 

6) any materials that are stored in the warehouse or storage facility that contain personally 

identifiable information are stored in a secure and safe location; 

7) there are standard operating procedures in place for storage, handling and disposal of personally 

identifiable information; and 

8) adequate security procedures are in place to ensure that the perimeter and interior space of the 

warehouse or storage facility are adequately secured and protected. 

Later in the evening of May 21, 2013, Acting Principal Deputy General Counsel Kevin Minoli 

forwarded these instructions to the agency's regional counsels and deputy regional counsels and asked 

those individuals to assist the assistant regional administrators in completing thi s review. Within the 

EPA' s headquarters similar instructions were provided to OlE, the Office of Research and Development, 

the Office ofSolid Waste and Emergency Response and the Office of Air and Radiat ion. OARM and 

OGC will provide support to those offices as they examine any warehouse or storage facilities within 

their control. 

4 

In addition, OEI continued its effort to identify and implement improvements to the agency's 

management of records, including records that contain personally identifiable information. In particular, 

OEI intends to review and strengthen, if necessary, existing policies and procedures addressing the 

sensitivity level of records and the identification of such before the transport of those records to a 

storage or disposal facility. OEI will also ensure that safeguards for protecting personally identifiable 

information are a part of future records trainings for agency employees. They will work with property 

management and the Facilities Management Services Division in OARM to identify the established 

processes for safeguarding personally identifiable information in warehouses and storage facilities and 

improve those processes where necessary. Finally, OEI will work with the Facilities Management 

Services Division to revise standard operating procedures to ensure every EPA form 5100 is properly 

marked, whether for storage or shredding, when the form denotes that the files subject to the Form 

contain personally identifiable information or other sensitive information. 

The EPA also continued its efforts at the warehouse facility on Tuesday May 21,2013. The agency 

completed its safety and health audit of the facility to ensure that all of the worker health and safety 

issues identified by OIG employees or EPA employees had been addressed. Renee Page, director of 

OARM's Office ofAdministration, conducted a walk-through of the facility for Gelb and Minoli. The 

EPA continued work on a contract for interim logistics support until a permanent contract is awarded in 

June 2013. Finally, OARM began a review ofthe performance of employees responsible for the 

oversight and monitoring of the contractor's performance and will determine the appropriate response. 

Conclusion 

I deeply appreciate the strong relationships we have with OIG and your continued assistance to the EPA. 

As can be seen from the EPA's aggressive, comprehensive and coordinated response, the EPA took very 

seriously the conditions at the warehouse identified by OIG. During the past seven days, the EPA has 

taken significant steps to eliminate the conditions of concern identified by OIG in its initial briefing of 

agency leadership. I and agency staff will continue to update you and OIG staff on agency actions in the 

days ahead and will follow up with you as we receive any additional recommendations from your office. 

The EPA is committed to addressing the previous conditions at the warehouse and implementing 

institutional protections to ensure those conditions do not recur at this facility or any other used by the 

agency. We look forward to working with OIG on any additional recommendations for action that you 

may have. 

cc: 	Craig Hooks 

Michelle DePass 

Malcolm Jackson 

Brenda Mallory 

Jose Lozano 

Tom Reynolds 

Arvin Ganesan 

Gwendolyn Keyes-Fleming 

Kevin Mi noli 

Nanci Gelb 

Charles Sheehan 

Renee Wynn 

Roxanne Smith 

Nancy Grantham 

5 
Laura Vaught 

Renee Page 

Katrina Cherry 

Robert Adachi 

Craig Ulmer 

6 

 

 
 

Appendix B 

Distribution 

Office of the Administrator 

Deputy Administrator 

Assistant Administrator for Administration and Resources Management 

Assistant Administrator for Environmental Information and Chief Information Officer 

Assistant Administrator for International and Tribal Affairs 

Principal Deputy Assistant Administrator for Administration and Resources Management 

Director, Office of Administration, Office of Administration and Resources Management 

Agency Follow-Up Official (the CFO) 

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Audit Follow-Up Coordinator, Office of Administration and Resources Management 

13-P-0272