The Office of Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA) conducted this subject audit. This report contains findings that describe problems we identified and corrective actions we recommend. This report represents our opinion and does not necessarily represent the final EPA position. EPA managers will make final determinations on matters in this report in accordance with established audit resolution procedures. Region 6 did not agree with the conclusions and recommendations in the draft report and requested that the matter be elevated in accordance with EPA's Audit Management Process.