United States
Environmental Protection
Agency
Office of
Inspector General (2441)
Washington DC 20460
EPA-350-K-00-002 Y
November 2000
v>EPA Office of Inspector General
Semiannual Report
to the Congress
April 1, 2000 through
September 30, 2000
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INSPECTOR GENERAL VISION
STATEMENT
We are agents of positive change striving for continuous improvement in our
Agency's management and program operations, and in our own offices."
The Inspector General Act of 1978, as amended, requires the Inspector General
to: (1) conduct and supervise audits and investigations relating to programs and
operations of the Agency; (2) provide leadership and coordination, and make
recommendations designed to (A) promote economy, efficiency, and
effectiveness and (B) prevent and detect fraud and abuse in Agency programs
and operations; and (3) fully and currently inform the Administrator and the
Congress about problems and deficiencies identified by the Office of Inspector
General relating to the administration of Agency programs and operations.
STRATEGIC PLAN GOALS
O Contribute to improved environmental quality and human health.
© Improve EPA's management and program operations.
€) Produce timely, quality and cost-effective products and services that meet customer needs.
Enhance diversity, innovation, teamwork and competencies.
Cover Photo: Fire at Bitterroot National Forest in Montana
Photo Courtesy of John McColgan
U.S. Environmental Protection Agency
Region 5, Libraiy (PL-12J)
77 West Jackson Boulevard. 12th R«3f
Chicago. IL 60604-3590
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Foreword
Since 1998, when I was appointed as EPA's Inspector General, the Office of Inspector
General (OIG) has focused on making a real difference in assisting EPA with its
mission of protecting human health and safeguarding the natural environment. I have
always firmly believed that the OIG can be a force for positive change and I am committed to
maintaining a workplace which promotes creativity, innovation, and teamwork.
As part of our journey to improve performance, OIG has invested in training to
enable OIG staff to clearly understand their role in helping the Agency improve management
and program operations. Specifically, all OIG staff have learned: (1) The Science of
Leadership and the Art of Gaining Followers; (2) Malcolm Baldrige National Quality Award
Criteria; (3) The Seven Habits of Highly Effective People; and (4) Building High
Performance Organizations for the Twenty-First Century. Future learning opportunities will
address team building, project management, program evaluation, activity-based costing,
process management, benchmarking, and re-engineering.
We recently completed our second OIG Strategic Plan which builds on our past
accomplishments, establishes new directions through FY 2005, and demonstrates our
commitment to lead by example. Our new directions include:
• Performing program evaluations to provide Congress and the Agency with best
practices, analyses, and recommendations to address the most serious management
challenges, accomplish environmental objectives, and achieve Government Performance and
Results Act goals;
• Partnering with others, including Federal and State auditors, evaluators, law
enforcement officials and associations, with oversight responsibility for environmental issues
to leverage resources to attain maximum environmental benefits; and
• Implementing human resource and knowledge management strategies to ensure
that we have a diverse, highly-motivated, and accountable staff with the skill sets and tools
needed to perform increasingly complex work.
In FY 2000, substantial progress was made in establishing an Office of Program
Evaluation within the OIG. This Office will lead the design and implementation of program
evaluations which are intended to build on traditional performance audits using sophisticated
analytical tools, methodologies, and specialized skills applied with a broad perspective to
guide policy and investment decisions. They involve the systematic measurement and
analysis of environmental, economic, and other external outcomes, benefits, and results in
relation to the application of resources, and legislative and policy initiatives. This new office
has partnered with the EPA Office of Research and Development and Office of Water in two
pilot studies helping to further develop the concept.
During the past six months, our quest for continuous improvement within the
Agency and our own office has yielded significant results as evidenced by the audits and
investigations summarized in this semiannual report.
I am encouraged by the positive change occurring within the OIG and by the
continuing spirit of cooperation evident between Agency and OIG staff. Together, I am
certain that we can resolve major management challenges, achieve impressive environmental
results, and ensure a cleaner, healthier global environment.
Nikki L. Tinsley
Inspector General
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Table of Contents
Section 1-Helping EPA Achieve Environmental Goals and Improve
Programs
Program Audits and Investigations 1
Followup Audits 7
Financial Management 9
Assistance Agreement Investigations 14
Contract Investigations 16
Employee Integrity Investigations 19
Section 2-Fostering Strong Working Relationships
Advisory and Assistance Services 20
Section 3- Operating at The Highest Performance Level
OIG Strategic Plan 23
Timeline for EPA OIG Journey to Improve Performance 25
Section 4-Audit Report Resolution and Summary of Investigative Results
Status Report on Perpetual Inventory of Reports in Resolution Process
for the Semiannual Period Ending September 30, 2000 27
Status of Management Decisions on IG Reports 28
Inspector General Issued Reports With Questioned Costs 28
Inspector General Issued Reports With Recommendations that Funds Be
Put to Better Use 29
Summary of Investigative Results 30
Appendices
Appendix 1- Reports Issued 31
Appendix 2- Reports Issued Without Management Decisions (Available upon request)
The complete text of selected audits is available through the EPA OIG
internet home page http: // www.epa.gov/oigearth
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Profile of Activities and Results
Audit Operations ($ in millions)
OIG Managed Reviews:
Reviews Performed by EPA, Independent Public
Accountants and State Auditors
Audit Operations ($ in millions)
Other Reviews:
Reviews Performed by Another Federal
Agency or Single Audit Act Auditors
April 1, 2000 to Fiscal
September 30, 2000 2000
Questioned Costs *
- Total
- Federal
Recommended Efficiencies*
- Federal
Costs Disallowed to be Recovered
- Federal
Costs Disallowed as Cost Efficiency
- Federal
$1.7
1.1
$51.1
38.7
$6.7 $21.6
Reports Issued - OIG Managed Reviews:
- EPA Reviews Performed By OIG: 32
- EPA Reviews Performed by
- Independent Public Accountants: 0
- EPA Reviews Performed by
State Auditors: 0
Total 32
Reports Resolved (Agreement by
Agency officials to take satisfactory
corrective action.) ***
122
59
0
0
59
222
April 1,2000 to
September 30, 2000
Questioned Costs *
- Total $ 0.8
- Federal 0.8
Recommended Efficiencies*
- Federal $ 0
Costs Disallowed to be Recovered
-Federal $1.0
Costs Disallowed as Cost Efficiency
- Federal $ 0
Reports Issued - Other Reviews:
- EPA Reviews Performed by
Another Federal Agency: 183
- Single Audit Act Reviews: 83
Total
266
Fiscal
2000
$4.2
4.2
$ 0
$1.5
$ 0
452
140
592
Agency Recoveries - Recoveries from Audit $5.6M
Resolutions of Current and Prior Periods
(cash collections or offsets to future payments.)**
Investigative Operations
Fines and Recoveries
(including civil)
Investigations Opened
Investigations Closed
Indictments of Persons or Firms
Convictions of Persons or Firms
Administrative Actions Against
EPA Employees/ Firms
Civil Judgments
$29M $70.8M
28
46
15
4
28
59
79
32
25
35
13
Monetary Results* of EPA OIG Operations
(Cumulative)
3.0
2.5
| 20
E 1.5
o 1.0
Q
0.5
0.0
1993 1994 1995 1996 1997 1998 1999 2000
Fiscal Year
* Potential recoveries, savings and offsets from OIG recommendations,
and criminal, civil and administrative actions
„** , Questioned Costs and Recommended Efficiencies subject to change pending further review in the audit resolution process
Information on recoveries from audit resolution is provided from EPA Financial Management Division and is unaudited
*** Reports resolved are subject to change pending further review.
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Section 1- Helping EPA Achieve Environmental Goals and Improve
Programs
Prosram Audits and Investigations
Region 3 Needs to
Increase Number
of School Asbestos
Inspections
At current staffing levels, EPA Region 3 was unable to perform an adequate number
of inspections at schools to assure that school districts were complying with the
Asbestos Hazard Emergency Response Act. Consequently, school children and
employees may be subject to greater health risks. Due to budget and staff cuts,
Region 3 only inspected a very small number of schools, and those inspections
generally only occurred in response to specific tips or complaints. Moreover, at the
time of our audit, EPA Headquarters was considering a "disinvestment" from the
Agency's asbestos inspection program.
Also, an unknown but possibly large percentage of the country's 1,605 charter
schools, attended by about 250,000 students nationwide, had never been inspected
because EPA had not informed them of the Act's mandate and that it applied to them.
Furthermore, in some instances state inspectors found violations and assisted non-
charter schools in complying but never reported the violations to EPA, resulting in
the number of inspections being understated.
We recommended that EPA Region 3 devote the resources necessary to operate a
viable asbestos inspection program. We also recommended that EPA Headquarters
notify all charter schools of Asbestos Hazard Emergency Response Act mandates and
develop a strategy to ensure that the charter schools comply with the Act. We issued
the final report (2000-P-00024) on September 28, 2000. In response to the draft
report, Region 3 initiated various corrective actions. A response to the final report is
due December 27, 2000.
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PAGE 1 -APRIL 1,2000 THROUGH SEPTEMBER 30,2000
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Program Audits and Investigations
Water Quality
Standards Program
Needs More
Emphasis
More than 20 years after Congress charged EPA with issuing criteria for 126 of the
most persistent, prevalent, and toxic priority pollutants known at the time, EPA still
had not developed criteria for 19 of the pollutants. EPA had not developed a
systematic process for setting criteria development priorities that is driven by
environmental concerns, and that uses data generated by other programs. As a result,
many toxic pollutants were being discharged into the nation's waters without
pollution prevention and detection controls in place. Because many states have
limited ability to adopt water quality standards beyond federal standards, it is
essential that EPA lead the way in developing water quality criteria.
Also, while the Clean Water Act made EPA responsible for approving state water
quality standards, there were 45 state water quality standards submissions, dating
back to 1994, awaiting EPA action. In addition, 25 years after EPA first required
that states develop antidegradation policies and implementation plans, 15 states and
territories still did not have plans. Lack of EPA guidance identifying what should be
included in these plans contributed to the absence of several state antidegradation
plans.
We recommended that EPA develop a process to proactively obtain and use data
generated by its various program offices to identify those pollutants that warrant
criteria development and to develop guidance on antidegradation implementation.
We issued the final report (2000-P-00023) on September 29, 2000. In response to
the draft report, EPA generally agreed with the recommendations, and to develop
both the national guidance and a systematic approach for setting criteria development
priorities. A response to the final report is due December 29, 2000.
State Stack Testing
Not Consistently
Implemented
EPA and the states inconsistently implemented the stack test portion of their air
enforcement programs, due to unclear EPA guidance. Stack testing measures the
amount of specific pollutants emitted through stacks at a facility. However, there
was confusion and disagreement within EPA and between states and EPA regarding
such issues as what stack test information should be reported, what is a stack test,
and how tests should be performed and evaluated.
Without sufficient stack testing information, EPA does not know what facilities are
being tested and how often, and facilities in some states may therefore be subject to
less stringent testing requirements than in other states. For example, some regions
require states to report stack test data into EPA's data base while other regions do
not. In addition to the potential for health risks going undetected as a result of
inadequate testing, the inconsistency in having these expensive tests done can result
in an unfair advantage for untested firms.
We recommended that EPA headquarters work with its regions and states to issue
national guidance on stack testing addressing identified concerns, and that EPA
regions increase oversight of states' stack testing programs. We issued the final
report (2000-P-00019) on September 11, 2000. In response to the draft report, EPA
initiated various corrective actions. A response is due December 26, 2000.
HTTP://WWW.EPA.GOV/OIGLARTI I-PAGIi 2
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Program Audits and Investigations
Stronger Controls
Over Access to
Sensitive Data on
EPA's Mainframe
Computer Needed
EPA Oversight of
North Carolina 's
National Pollution
Discharge
Elimination System
(NPDES) Needs
Improvement
Better management oversight and additional administrative procedures are needed
over the software that controls entry to EPA's mainframe computer to reduce
potential misuse, manipulation, and destruction of information resources. The
mainframe computer provides a national data repository for Agency environmental,
administrative (including major financial systems), and scientific systems. Much of
the data is sensitive.
We recommended that EPA improve controls over its software package that provides
security for the mainframe computer including periodic security reviews of the access
settings and users, and removing unnecessary access profiles.
The final report (2000-1-00330) was issued on June 30, 2000. In response to the
report, EPA agreed with the audit findings and implemented corrective action for all
report recommendations. In particular, the Agency implemented a process for regular
review of security settings. Moreover, the Agency tasked system administrators to
review their use of sensitive settings, certify that they understand the risks inherent
in using these settings, and formally request and justify use of high-risk settings.
EPA Region 4 needs to expand and strengthen its oversight of North Carolina's
NPDES enforcement program. The Region was unaware of continuing whole
effluent toxicity violations and continuing permit violations by NPDES minor
permitted facilities. Further, EPA generally did not overfile or take other comparable
actions against facilities with continuing permit violations when North Carolina's
actions were not timely or appropriate. Without changes, the Region cannot work
with the State to improve water quality.
Our review disclosed the following specific problem areas requiring greater attention:
• North Carolina did not identify daily and weekly violations of permit limits,
obtain agreements from permit violators to achieve compliance, or incorporate
economic benefit analysis into its enforcement actions against permit violators.
• The State did not routinely inspect storm water industrial sites, monitor
inspections of non-construction storm water sites, or review self-monitoring
reports despite concerns regarding the need to reduce pollution from storm
water run-off. Without a storm water program, the State could not assure that
facilities were complying with storm water permits or taking all required
measures to reduce pollution.
• The test methods North Carolina used to analyze discharges for chlorine and
mercury were not always sensitive enough to determine compliance with
permit limits and, thus, the potential harm to the environment.
PAGE 3 -APRIL 1,2000 THROUGH SEPTEMBER 30,2000
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Program Audits and Investigations
• The State did not issue NPDES permits that met applicable concentrated
animal feeding operation permit regulations or include all applicable NPDES
regulatory provisions in State animal feeding operation permits, even though
manure and wastewater from feeding operations contribute significant
pollutants.
We recommended that EPA take specific actions to correct the conditions reported.
We issued the final report (2000-P-00025) on September 28, 2000. In response to
the draft report, Region 4 generally agreed with our conclusions and to work with
North Carolina to resolve many of our recommendations. Although North Carolina
had concerns with some of our recommendations, State officials indicated they would
work with EPA to develop a plan to address the issues in our report. A response to
the final report is due December 27, 2000.
Multimedia
Enforcement:
Successes and
Opportunities
EPA's Office of Enforcement and Compliance Assurance (OECA) encourages the
use of multimedia enforcement (involving more than one media such as air, water,
and land, or more than one law). However, we found that it has not developed a
comprehensive plan that will increase the likelihood of success in this program.
Specifically, OECA did not (a) establish a plan to manage the multimedia program;
(b) clearly communicate its philosophy to EPA managers and staff; or (c) issue
policies on how or when to use the multimedia approach as an enforcement tool.
Multimedia enforcement actions can achieve significant environmental benefits. For
example, enforcement actions at three petroleum refineries resulted in $5.8 million in
penalties, $12 million spent to correct violations, $14.9 million for supplemental
environmental projects, and a measurable reduction in many pollutants.
EPA's lack of written policies or plans resulted in variations in the effectiveness of
regional approaches to multimedia. The success rates in identifying significant
violations using multimedia inspections ranged from 55 to 100% of the time in the
regions we reviewed. OECA did not know whether the multimedia approach was an
effective or efficient tool for reducing noncompliance and improving the environment
and human health.
The Agency addressed all report issues in response to the draft report. The Assistant
Administrator stated he would use the audit report to reiterate OECA's management
philosophy, the objectives of multimedia enforcement, and additional steps necessary
to implement multimedia enforcement. To evaluate the effectiveness of multimedia
enforcement, OECA will develop a consistent definition of multimedia enforcement,
improve the collection of information on enforcement action benefits, and work to
build into the Agency's cost accounting system information on the costs of all types
of enforcement actions. We issued the final report (2000-P-000018) on June 30,
2000.
HTTP://WWW.hPA.GOV/OIGEARTH-PAGh4
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Program Audits and Investigations
Improvements
Needed to Increase
Effectiveness of
Louisiana's Water
Quality Program
Although EPA Region 6 generally implemented effective procedures to approve and
evaluate Louisiana's water quality standards, the Region's oversight of Louisiana's
water quality program was limited because the Region had not formally evaluated the
adequacy of the Region's monitoring and reporting requirements under the Clean
Water Act. The Region's ability to evaluate the program was limited by Louisiana's
untimely and incomplete water quality planning documents. Without a formal
evaluation, the Region cannot assure the Act's requirements are being met or that
Louisiana has focused its water quality efforts on priority areas.
Louisiana could improve its water quality program by: using more sensitive test
methods for standard setting, adopting EPA recommended bacteria criteria, clarifying
its antidegradation implementation plan, and using biological monitoring. Louisiana
had not adopted bacteria criteria that would better protect the public from
gastrointestinal illnesses.
We recommended that EPA revise or develop policies and/or regulations that would
require permittees to use the most sensitive test methods; establish national guidance
on antidegradation implementation plans; and, through grant commitments, work
with Louisiana to clarify its antidegradation implementation plan, adopt
recommended bacteria criteria, and implement biological monitoring. We issued the
final report (2000-P-00185-00022) on September 29, 2000. In response to the draft
report, Region 6 generally agreed with the findings and recommendations, but
Louisiana officials did not. A response to the final report is due December 29, 2000.
Plastics
Manufacturers
Agree to Pay
$400,000 Civil
Penalty
Aeroquip Corporation, and Aeroquip-Vickers, Incorporated, entered into an
agreement with the United States to pay $400,000 in civil penalties for alleged
violations of chlorofluorocarbon (CFC) requirements in the Clean Air Act. The
agreement was reached on April 28, 2000, in U.S. District Court, Middle District of
Georgia. The investigation disclosed that Aeroequip-Vickers submitted false
documents to the EPA stating that certified technicians repaired equipment
containing CFCs when they, in fact, did not, and they did not use CFC recovery
equipment as required by the Clean Air Act. Restrictions on refrigerants such as
CFCs are necessary to reduce the risk of depletion of the ozone layer caused by such
substances. This investigation was conducted jointly by the EPA OIG and the EPA
Criminal Investigation Division.
New Hampshire
Company and its
President Ordered
to Pay $40,000 for
Environmental
Cleanup
A Consent Decree issued in U.S. District Court ordered Bruce Migell and the Tilton
Trust and Atlantic Battery Company, Inc., doing business as Surrette American
Battery, to pay $40,000 for reimbursement of cleanup costs incurred by the EPA at
Surrette's facility in Northfield, New Hampshire. The decree, issued on May 18,
2000, in the District of New Hampshire, was the result of an OIG investigation
focusing on false financial disclosures and a civil complaint filed by EPA on June 9,
1999, against Migell, the firm's president, and the company. The facility was used to
manufacture deep-cycle batteries used in marine vehicles and industry. Hazardous
substances such as lead and sulfuric acid used in the manufacturing process were
disposed of at the site and released into the environment.
PAGE 5 -APRIL 1,2000 THROUGH SEPTEMBER 30,2000
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Program Audits and Investigations
Agreement
Reached to
Reimburse EPA
$10,000 in
Cleanup Costs
Robert H. Book, former chairman and consultant to Photech, Inc., agreed on May 5,
2000, to pay EPA $10,000 in a civil settlement agreement with the U.S. Attorney's
Office, Western District of Pennsylvania. The amount represented reimbursement of
costs EPA incurred to clean up the release and threatened release of hazardous
substances at the Photech Superfund site in Rochester, New York. The DIG
investigation centered on alleged false statements made by Book to EPA regarding
his responsibility for the operation of Photech and his ability to pay for the cleanup.
Pursuant to the Comprehensive Environmental Response, Compensation, and
Liability Act, the EPA filed a civil suit on April 28, 2000, against Book to recoup
$577,113 in cleanup costs. Photech manufactured specialty photographic film at the
site, and the process utilized significant amounts of hazardous substances that were
disposed of at the site. Photech ceased operations in June 1990.
Producer of
Purported
Environmental
Cleanup Product
and Retail Brokers
Ordered to Pay
$2.5 Million for
Price Fixing
Scheme
A civil judgment for $2.5 million was entered in U.S. District Court against the
former president of Exsorbet Industries Inc., of Arkansas and several other officials
for price fixing. The judgment was entered on June 16, 2000, in the Northern
District of Illinois, against Floyd Leland Ogle, former president of Exsorbet; Reuben
Peters, a market maker; and Chicago stock brokers Albinas Kurkulis, Andrew
Kurkulis, and Paul Kurkulis. In the Securities and Exchange Commission complaint
filed on February 1, 1999, the defendants were alleged to have manipulated the price
of Exsorbet stock by purchasing the stock for $1 per share, artificially fixing the price
of Exsorbet floating stock, and then selling the stock for $13 per share. As part of
the price fixing scheme, Ogle allegedly issued a forged EPA letter endorsing
Exsorbet's oil absorbent peat moss, a product purportedly useful in environmental
cleanups, and issued a false press release stating Exsorbet had obtained $5 million in
government contracts. This investigation was conducted by the EPA OIG, the
Federal Bureau of Investigation, and the Securities and Exchange Commission.
HTTP://WWW.KPA.GOV/OIGKARTH-PAGE 6
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Follow up Audits
Brownfields
Initiative to
Revitalize Urban
Areas Has
Progressed
EPA has taken significant steps to implement our March 1998 recommendations.
For example, the Brownfields pilot proposals were more focused on site assessment
than they were before. Also, site assessment pilots were providing better quarterly
reports to EPA. However, the loan program had been slow to make loans, and
better reporting and documentation were needed in certain areas relating to site
assessment pilots. The purpose of the Brownfields Initiative is to restore
contaminated industrial and commercial facilities to productive use. We found the
following areas in need of improvement:
• The Brownfields Cleanup Revolving Loan Fund grant program pilots had been
slow to make loans. As of June 30, 2000, only about $1 million of $43 million
available had been loaned, and only one cleanup had been completed. The
Fund needs additional flexibility and time before its success can be fairly
evaluated.
• Site assessment pilots needed to improve on the timeliness of their quarterly
reports to EPA.
• The site assessment pilot selection process should be better documented. In
general, the strength of regional quality assurance programs varied.
We recommended that EPA complete implementing our prior recommendations,
revise and better document the results of the assessment pilot selection process,
evaluate regional implementation of quality assurance guidelines, and clarify pilot
reporting requirements. The Agency's response to our draft report included
corrective actions that, when completed, will address the recommendations. We
issued the final report (2000-P-00027) on September 29, 2000.
First Brownfield site (Las Vegas Armory) cleaned up using EPA revolving loan funds.
PAGE 7 -APRIL 1,2000 THROUGH SEPTEMBER 30,2000
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Follow up Audits
EPA Region 5 Still
Needs to Improve
Billings and
Collections
We recommended in a March 1997 report that EPA Region 5 develop and
implement time frames for preparing and reviewing bills for the oversight of
cleanup work performed by Superfund responsible parties, as well as issue dunning
letters timely. Although Region 5 substantially improved the timeliness of its
oversight billings, our fiscal year 2000 followup audit found that Region 5 still
needs further improvement.
The Region was still late in sending out dunning letters because it relied on a
manual process for tracking and issuing the letters. In April, 2000, EPA issued
revised guidance that replaced the need for dunning letters with a requirement for a
single notice before referral to the Department of Justice. As of April 2000, the
Region had not implemented the new requirement because it doubted that it could
obtain aging reports necessary to implement the new procedure.
We recommended that Region 5 request guidance on obtaining aging reports and
benchmark with other offices to help implement the new collections guidance. We
issued the final report (2000-P-00026) to Region 5 on September 28, 2000. In
response to the draft report, the Region generally agreed with our recommendations.
A response to the final report is due January 2, 2001.
Interagency
Agreements Still
Need Indirect Cost
Rate Established
Our followup on a March 1995 audit "Interagency Agreements: Off-Loading at
EPA" (Report No. 5400051) disclosed that while EPA made significant
improvements in improving guidance and training related to agreements, EPA had
not established an indirect cost rate to recover the full cost of doing work for another
agency.
Specifically, EPA improved its guidance and training to: (1) justify why an
Interagency Agreement rather than a procurement was chosen; (2) ensure that the
cost of the proposed work was reasonable; and (3) obtain detailed cost information
related to payments. Additionally, the Office of General Counsel opined that there
was no legal prohibition against EPA paying another agency's contractor directly
under an Interagency Agreement.
However, EPA had not established an indirect cost rate to recover the full cost of
doing work for another agency under an Interagency Agreement. As a result, EPA
continues to transfer an unknown amount of its resources to other agencies, in
violation of the Economy Act. In addition, despite the improvements made, we
noted several areas where guidance and training could be improved.
We recommended that the Office of Administration and Resources Management
assist the Office of the Chief Financial Officer in establishing an indirect cost rate to
recover the full cost of work performed for another agency under an Interagency
Agreement. We also recommended steps for EPA to update and strengthen its
guidance documents and training. The final report (2000-P-00029) was issued on
September 29, 2000. The Assistant Administrator, Office of Administration and
Resources Management, generally agreed with the findings and recommendations in
our followup report. A response to the final report is due December 29, 2000.
HTTP://WWW.LPA.GOV/OIGEARrH-PAGE8
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Financial Management
More Consistent
Management
Would Improve
Region 8 Tribal
Assistance
Program
EPA Region 8 was not consistent in awarding and monitoring Tribal grants. Tribal
Assistance Program (TAP) officials placed a high priority on external relationships,
generally with the Tribes, and did not pay sufficient attention to grant management
and internal relationships.
TAP's inconsistent grants management gave the appearance to some regional staff
that certain grants were illegal. Our review disclosed that Region 8 legally awarded
all 137 Tribal grants managed by TAP between fiscal years 1996 and 1999.
However, some grants included unallowable activities or had inadequate or untimely
work plans and progress reports. In general, TAP appeared to advocate too strongly
for Tribes, which sometimes hindered relationships between the Tribes and other
program officials within Region 8.
We recommended that the Regional Administrator implement a new Region 8
policy on grant roles and responsibilities and balance TAP's external focus with
internal program and grant management. We made other recommendations to
improve procedures, including development of a systematic grant review process.
We issued our final report (2000-P-00021) to the Regional Administrator on
September 29, 2000. Region 8 initiated some steps to correct problems observed.
The Region's response to the final report is due December 28, 2000.
Stronger Controls
Needed to Improve
Rhode Island
Grants
Management
We found that the Rhode Island Department of Environmental Management (Rhode
Island) did not have adequate internal controls to ensure that over $16.7 million in
federal funds awarded to it since fiscal year 1996 were being managed appropriately.
As a result, EPA had limited assurance that grant funds were used in accordance
with workplans and met negotiated environmental targets.
The objectives of an internal control structure are to provide management with
reasonable assurance that assets are safeguarded and transactions are executed
appropriately. However, review of Rhode Island's management of over $16.7
million in grants to help the State improve the quality of air, land, and water
disclosed that Rhode Island:
• charged payroll expenses based on a budget rather than actual hours, and did
not include the cost of leave as part of its fringe benefits rate;
• did not have a system in its Office of Air Resources to ensure charges to the
Federal grants were allowable, allocable, and reasonable;
• lacked documentation to support that it had met the minimum cost sharing
requirements;
PAGE 9 -APRIL 1,2000 THROUGH SEPTEMBER 30,2000
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Financial Management
• submitted multiple final Financial Status Reports with different ending
balances, had excess Federal funds on hand, and made transfers without prior
EPA approval; and
• did not maintain Title V operating permit fee revenue in accordance with either
federal or state regulations.
We recommended that EPA work with Rhode Island to develop a corrective action
plan that addresses the internal control weaknesses. Regional officials should then
meet regularly with State officials to review progress. We issued our final report
(2000-1-00416) on September 21, 2000. The Regional Administrator generally
concurred with the findings and recommendations in the draft report, and indicated
Rhode Island agreed to develop a detailed corrective action plan. The Region
requested our assistance in reviewing the progress that Rhode Island makes towards
meeting its planned actions.
Ohio Needs to
Improve
Administration of
Superfund
Cooperative
Agreement
The Ohio Environmental Protection Agency (Ohio) needs to improve its financial
and program results reporting and its procedures for drawing down cash under a
consolidated Superfund cooperative agreement that authorized $5.5 million in
federal funding.
On September 30, 1997, EPA Region 5 awarded Ohio a consolidated cooperative
agreement for several different types of general and site-specific Superfund
activities. The agreement, as amended, authorized federal assistance of $5,528,747
and required State matching costs of $ 192,732 through June 30, 2001. In general,
Ohio was meeting the objectives of the cooperative agreement. However, we found
the following:
• Ohio had not submitted accurate or timely Financial Status Reports. As a
result, Region 5 was neither aware of the financial status of the program nor
that Federal and State expenses were misstated.
• Ohio did not meet its 10 percent cost sharing requirement for core activities in
fiscal years 1998 and 1999. As of September 30, 1999, Ohio had under-
matched core activity expenses by more than $76,000.
• Ohio's cash draw downs exceeded the Federal share of expenses under the
cooperative agreement. As a result, Ohio frequently carried excess cash
balances at the end of the month and occasionally did not request enough funds
to cover expenses, resulting in a negative cash balance at the end of the month.
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Financial Management
• Ohio had not always identified the site-specific activity performed in its fiscal
year 1999 progress reports. As a result, Region 5 may not be able to recover
more than $45,000 of Ohio's payroll costs from responsible parties because the
specific tasks were not always identified.
We recommended that the Regional Administrator for Region 5: (1) clarify
reporting requirements for Ohio, (2) ensure that Ohio reconciles and confirms its
cost sharing requirements, (3) require Ohio to develop an effective method for
determining cash needs, and (4) require Ohio to ensure that employees provide the
description of the work required to support cost recovery efforts. The Regional
Administrator and Ohio agreed to work together to resolve the issues and implement
recommendations. We issued the final report (2000-P-00020) on September 15,
2000.
Michigan
Association's
Accounting System
Did Not
Adequately
Account for EPA
Funds
The Michigan Association of Conservation Districts (MACD) could not adequately
account for almost $169,000 of the $300,000 in EPA funds it received through two
grants, due to an inadequate accounting system. MACD, a non-profit organization
established to represent and provide services to Michigan's 82 Conservation
Districts, received two $150,000 grants from EPA Region 5 to assist in promoting
the use of native plants in Michigan. The two grants cover a four-year period
ending September 30, 2001.
MACD's financial management system did not meet the minimum Federal
requirements of supporting the authorized use of Federal funds and providing
accurate financial statements. Consequently, MACD could not adequately account
for almost $169,000 in EPA funds. We were not able to reconcile MACD's claimed
costs with its general ledger, and therefore could not identify the specific costs
reported by MACD. In addition, MACD did not properly support its labor, indirect,
or numerous other direct costs, and drew down EPA funds in advance of actual
need. Also, MACD and EPA incorrectly included services of another Federal
agency when negotiating the grantee's cost-sharing ratio.
We recommended that the Regional Administrator for Region 5 immediately
suspend the two grants until MACD completes a series of corrective actions. In the
event that MACD does not do so timely, we also recommended that the Regional
Administrator terminate the grants and recover all unsupported costs. We issued the
final report (2000-4-00059) on September 7, 2000. MACD has initiated several
corrective actions in response to the draft report. A response to the final report is
due by December 7, 2000.
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Financial Management
Pesticide
Reregistration
Tracking Problems
Continue
EPA Making
Progress on
FFMIA
Recommendations
As part of our annual audit of the financial statements for the Pesticides
Reregistration and Expedited Processing Fund (FIFRA Fund), we found that system
problems continue to affect EPA's ability to accurately report on the status of
pesticides reregistration. EPA is responsible for reassessing the safety of older
pesticide registrations against modern standards as part of reregistration. EPA
deposits fees for reregistration and tolerance activities into the FIFRA Fund, and
each year prepares FIFRA financial statements that include information about
EPA's progress in reregistering pesticides and assessing tolerances.
The fiscal year 1999 FIFRA financial statements were fairly presented. However,
system problems continued to affect the EPA Office of Pesticide Programs' ability
to accurately report on the status of reregistration. We had reported problems with
the Office's Pesticide Regulatory Action Tracking System in prior FIFRA financial
statement audit reports. At the time, program officials informed us that they had
identified and corrected the problems. However, our fiscal year 1999 audit work
finds that these problems continue and have resulted in the Office of Pesticide
Programs reporting inaccurate reregistration data since 1989.
We recommended that the Office of Pesticide Programs convene a workgroup to
address continuing system problems that affect its ability to accurately report on the
status of product reregistration. The final report (2000-1-00278) was issued on May
25, 2000. On August 3, 2000, we received a response indicating EPA agreed to
convene such a workgroup.
As a part of our annual audit of EPA's financial statements, the Federal Financial
Management Improvement Act (FFMIA) of 1996 (Public Law 104-208) requires us
to report on whether EPA's financial management systems comply substantially
with applicable requirements.
On September 28, 2000, in response to our fiscal year 1999 financial statement
report that noted the Agency was not in substantial compliance with FFMIA, the
Acting Comptroller provided a corrective action plan with milestones for a number
of audit findings and recommendations. This response included a remediation plan
addressing planned actions for four specific noncompliance areas, as follows:
• Final corrective actions regarding improving the financial statement preparation
process are planned to be completed by October 31, 2000.
• EPA reported significant progress since September 30, 1999, toward improving
security plans for its core financial systems. Final corrective actions are planned
to be completed by June 30, 2002.
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Financial Management
• Final corrective actions are planned to be completed by March 31, 2001,
regarding compliance with the Managerial Cost Accounting Standard. We are
continuing to discuss the planned corrective actions with the Acting Chief
Financial Officer.
• Final corrective actions regarding federal trading partner information are
planned to be completed by December 31, 2000.
We will monitor and report on EPA's progress on completing corrective actions in
the next semiannual report as well as in our fiscal 2000 financial statement audit
report. The plan will be transmitted to the Office of Management and Budget with
the annual A-l 1 budget submission in December 2000.
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Assistance Agreement Investigations
Embezzler Given
30-Month Prison
Term, Ordered to
Pay $1.8 Million in
Restitution
The former lead accountant of the National Asian Pacific Center on Aging
(NAPCA) was sentenced in U.S. District Court to a 30-month prison term and
ordered to pay $1.8 million in restitution for his role in various embezzlement
schemes. His daughter received probation as a result of her involvement.
On June 5, 2000, Wallace G. Jorgensen, former lead accountant for NAPCA, was
sentenced in the Western District of Washington to 30 months imprisonment and
3 years probation, and was ordered to pay $1,802,546 restitution to NAPCA. He
had pleaded guilty to embezzling property from a program receiving federal funds
and falsifying an income tax return. On June 15, 2000, his daughter, Gina R.
Jorgensen, was sentenced to 5 years probation, 30 days home confinement, and 100
hours of community service, following her pleading guilty to wire fraud.
The NAPCA, funded by EPA through the Senior Environmental Employment
Program, is a non-profit organization whose mission is to serve the needs of older
Asian and Pacific Americans throughout the United States through employment and
training programs. Wallace Jorgensen devised various schemes in which he issued
thousands of NAPCA payroll and travel advance checks to himself and immediate
family members, embezzling in excess of $1.8 million from 1993 through 1999. He
also failed to report the income from the embezzled funds on his federal income tax
returns, resulting in a tax loss of $609,083.
Gina Jorgensen devised and executed a scheme to obtain a home mortgage loan. In
application papers, she claimed to be employed by Jorgensen Construction, a
fictitious company, variously claiming earnings of $4,800 and $5,700 per month.
She also sent, via wire facsimile, a copy of her checking account monthly statement
showing deposits of more than $10,000, knowing that all the deposits were actually
derived from funds provided by her father. This investigation was conducted jointly
by the EPA OIG, the Department of Labor OIG, the Federal Bureau of
Investigation, and the Internal Revenue Service Criminal Investigation Division.
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Assistance Agreement Investigations
Private Utility
Company and its
President Plead
Guilty to Polluting
Sarasota Bay
Watershed;
$1.75 Million in
Restitution, Fines
Set
South Bay Utilities, Inc., and its corporate president pleaded guilty in U.S. District
Court to a criminal Information charging them with violating the Clean Water Act.
In the plea agreement entered on May 15, 2000, in the Middle District of Florida,
the defendants admitted to not disclosing to government officials that the waste
water discharged by South Bay Utilities directly into Dryman Bay in Sarasota
County, Florida, was not properly treated. As part of the plea. South Bay Utilities,
Inc., and the corporate president, Paul L. Paver, will pay a total of $1.75 million in
restitution and fines. Of that amount, $1.2 million will be paid directly to three
different Florida environmental trust funds for environmental restoration and
enhancement projects.
Shortly after the utility's wastewater treatment plant came on line in 1976, its drain
fields became saturated and were not able to process the amount of affluent
discharged. To relieve the pressure on the drain fields, South Bay illegally installed
underground bypass pipes without informing government regulators. After their
installation, the pipes allowed affluent to flow through the storm water pipes
directly into Dryman Bay, discharging about 1 !/z tons of nitrogen into Sarasota Bay
annually.
Affluent contains nitrogen which can spawn algae blooms that deplete oxygen
needed by fish and block sunlight essential to the growth of sea grass, a key source
of food and shelter to marine life. The illegal bypass undermined EPA's efforts and
investment of millions of dollars to restore the watershed. Sarasota County has
closed the utility company and dismantled the wastewater plant. This investigation
was conducted jointly by the EPA OIG, the EPA Criminal Investigation Division,
the Federal Bureau of Investigation, the Internal Revenue Service, the Florida
Department of Law Enforcement, the Sarasota County Office of Pollution Control,
and the Florida Department of Environmental Protection.
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Contract Investigations
EPA Contractor
Enters Settlement
Worth
$24.3 Million
Kaiser Group International, Inc., entered into a settlement with the United States
Attorney's Office under which the government will realize $24 million in contract
savings. The agreement, reached on September 15, 2000, in the Eastern District of
Virginia, settled a federal False Claims Act case that involved the EPA and 17 other
federal departments/agencies.
The settlement was the culmination of a lengthy investigation which disclosed that
Kaiser (formerly ICE Kaiser International, Inc.) may have billed government
contracts for computer center costs in excess of costs actually incurred. In addition,
EPA OIG questioned costs relating to the alienability, allowability, and
reasonableness of Kaiser's direct and indirect costs dating back to their fiscal year
ending February 28, 1985, due to unsatisfactory documentary support.
Under the terms of the settlement agreement, the government's potential contract
savings could reach $390.1 million pending verification of unbilled obligated fund
balances by the 17 other federal departments/agencies. In settling the final rates,
EPA to date will realize $23.2 million in contract savings due to Kaiser's agreement
to relinquish all rights in potential claims in the form of retainages, rate variances,
costs, profits, and fees accrued or otherwise owed in connection with services
provided under a schedule of government contracts from March 1, 1985 through
December 31, 1999. Additionally, in settling the alleged false claims associated
with the computer center overtoiling, Kaiser agreed to forgo $828,604 in repudiated
claims against two Department of the Navy contracts. This investigation was
conducted jointly by the EPA OIG and the Nuclear Regulatory Commission OIG.
In another case, Kaiser Group International, Inc., entered into a settlement
agreement with the U.S. Attorney's Office for the Middle District of North Carolina
in which Kaiser will forgo $300,000 in repudiated claims to resolve civil claims
arising under the federal False Claims Act. In the agreement, reached June 7, 2000,
the United States alleged that Kaiser prematurely billed EPA, the Department of the
Navy, and other federal agencies for subcontract and other direct costs that Kaiser
had not yet paid. Such billing practices are prohibited by the Paid Cost Rule set
forth in Section 52.216-7(b) of the Federal Acquisition Regulation. Kaiser denied
any criminal misconduct, but agreed to forgo $300,000 in outstanding claims
submitted against a Department of the Navy contract. This investigation was
conducted jointly by the EPA OIG and the Naval Criminal Investigative Service.
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Contract Investigations
EPA Contractors
Indicted on
Federal
Racketeering
Charges
Former Employees
of Laboratory
Charged in
30-Count
Indictment
A group of current and former Lexington, Kentucky, residents were indicted in U.S.
District Court on federal racketeering charges, arising from their participation in the
Small Business Administration (SBA) minority preference contract set aside
program. The indictments were filed on May 30, 2000, in the Eastern District of
Kentucky, in connection with more than $150 million in federal contracts awarded
for environmental cleanup projects, mostly with EPA and the Department of
Defense.
Pritnam Sabharwal, who headed the group, initially entered the SBA program with a
business named Environmental Health Research and Testing, headquartered in
Lexington. After graduating from the program in 1998, Pritnam Sabharwal
allegedly obtained, in the name of his son, Paul Sabharwal, SBA minority
preference status for another company he controlled, named Environmental
Chemical Corporation. The Sabharwals allegedly obtained the certification by
fraudulently concealing from SBA the relationship between the two companies.
Furthermore, minority certification was allegedly fraudulently obtained for a third
company, purportedly headed by another son, Shaw Sabharwal.
The indictment further alleges that from 1990 through 1996, the Sabharwals and
their associates engaged in other fraudulent activities, including fraud on auditors
and investigators looking into contracts, fraud on a bank that loaned them money,
fraud on a bankruptcy court, and fraud on a court in a criminal case in North
Carolina. In addition, the indictment alleges two instances of bribery of a public
official with regard to obtaining inside information on government contracts, and
acts of audit obstruction and money laundering. Named as defendants in addition to
Pritnam Sabharwal are his sons, Paul and Shawn Sabharwal; his wife, Jean D.
Sabharwal; Harpreet Chadha, of North Carolina; and Dushyant Gulati. of
Clearwater, Florida. This investigation was conducted jointly by the EPA OIG and
the Defense Criminal Investigative Service.
A vice president and 12 former employees of Intertek Testing Services
Environmental Laboratories, Inc. (ITS), were indicted in U.S. District Court on
charges of conspiracy, mail fraud, wire fraud, and presenting false claims against the
United States. The indictments were handed down on September 21, 2000, in the
Northern District of Texas. ITS was formerly known as NDRC Laboratories, Inc.,
and Inchcape Testing Services Environmental Laboratories, Inc.
PAGE 17 -APRIL 1,2000 THROUGH SEPTEMBER 30,2000
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Contract Investigations
Between January 1994 and December 1997, ITS, a full service environmental
testing laboratory, generated $35.7 million in gross billings and performed
environmental sample analysis on more than 59,000 separate environmental projects
involving over 250,000 air, soil, liquids, pesticides, explosives, and nerve/chemical
agents samples. These analyses were conducted for determining, among other
things, the presence of known or suspected human cancer-causing contaminants.
The 30-count indictment charges that each of the 13 named defendants was involved
in the conspiracy at some time during the period 1988 through 1997. The alleged
conspiracy involved:
• altering data to make diagnostic instruments appear to be properly calibrated
and within the quality control limits when they were not;
• falsely certifying that the equipment used to perform the analyses was properly
calibrated and within the quality assurance/quality control criteria set by their
clients and the EPA; and
• representing that samples analysis was done in accordance with contract
specifications requiring specific procedures, quality controls, and assurance
methods.
This investigation was conducted jointly by the EPA OIG, the EPA Criminal
Investigations Division, the Defense Criminal Investigative Service, the Army
Criminal Investigation Command, and the Air Force Office of Special
Investigations.
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Employee Integrity Investigations
Former EPA
Attorney
Sentenced to One
Year Probation,
Fined$5,000
Marc M. Radell, an attorney with the EPA Office of Regional Counsel in Chicago,
was sentenced in U.S. District Court on charges of testifying falsely in a court
ordered deposition during federal civil cases in Wisconsin. Radell was sentenced to
one year probation, fined $5,000, and ordered to perform 50 hours of community
service. The sentencing occurred September 25, 2000, in the Eastern District of
Wisconsin, following an August 2000 guilty plea by Radell to a misdemeanor
charge of contempt of court. Prior to the sentencing, Radell voluntarily resigned his
position with the EPA.
According to court documents, in 1996, the EPA granted the Menominee Indian
Tribe, the Oneida Tribe of Indians of Wisconsin, and Lac du Flambeau Band of
Lake Superior Chippewa Indians "Treatment as State" status under the Clean Water
Act so that each group could develop a water quality standards program within their
respective reservations. The state of Wisconsin filed civil lawsuits in federal
district court challenging EPA's decision. The indictment charged that, during the
course of this litigation, Radell and a co-defendant created and backdated EPA
documents (factual analyses of substantial effects of non-Indian activities within
each applicant's reservation). They were charged with falsely stating in affidavits
and depositions that the documents were created in January 1996 and were relied on
by the EPA to make its decisions when, in fact, the defendants created these
documents in May 1996 after the lawsuits were filed.
The Treatment as State lawsuits were subsequently dismissed and the EPA was
ordered to pay Wisconsin and other parties approximately $369,000 in attorney's
fees and court costs.
Former EPA
Employee
Sentenced for
Theft
Adrenia L. Ward, a former computer specialist in EPA's Office of the Chief
Financial Officer, was sentenced in U.S. District Court, District of Columbia, for
theft. She was sentenced on June 27, 2000, to 3 years probation and 50 hours of
community service, and was ordered to pay EPA $4,941 in restitution and a $25
special assessment fee. From June 1997 through March 1999, while employed by
EPA, Ward used her government credit card to purchase computer equipment, audio
equipment, a DVD player, and dozens of compact discs and videotapes for her
personal use. To conceal these purchases, she intentionally did not list them on the
purchase log she maintained and, on numerous occasions, falsely certified on a
monthly Statement of Account that the purchases were for official business. A total
of $7,723 of the equipment was recovered during the investigation.
PAGE 19 -APRIL 1,2000 THROUGH SEPTEMBER 30,2000
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Section 2- Fostering Strong Working Relationships
Advisory and Assistance Services
Auditor Site Visit
Leads to Repairs at
Ramapo
Superfund Site
A site visit by EPA OIG auditors at the Ramapo Landfill, a Superfund site in
Ramapo, New York, disclosed storm damage had remained unrepaired for close to a
year. Two downchutes had been damaged by August 1999 rainstorms and the
September 1999 Tropical Storm Floyd. The geocomposite cover along the
downchutes was exposed down to the rubber impermeable membrane, with a two-
foot-square opening in one section. No attempts had been made to repair the
damage even though the EPA Remedial Project Manager and the Ramapo Director
of Public Works had documented this damage in inspection reports. While the
conditions did not pose an imminent danger to public health or the environment, the
potential for substantial compromise of the integrity of the landfill cap and
subsequent health risk existed as long as the conditions remained unrepaired.
As a result of an August 1, 2000, EPA OIG advisory memorandum urging
correction of the situation, the Town of Ramapo obtained a grant from the Federal
Emergency Management Agency to repair the damage. The town plans to redesign
the site's surface drainage system so that it has sufficient capacity to control the
runoff from a major storm and to repair the landfill cap.
Erosion to rubber membrane at Ramapo Superfund site.
The Ramapo Landfill, located about 35 miles northwest of New York City, had
been used to dispose of refuse, including industrial and sewer sludge, waste from a
pharmaceutical company, and asbestos.
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Advisory and Assistance Services
EPA's Revised
Strategic Plan:
New Ideas Needed
to Solve Old
Problems
While the EPA Strategic Plan is correctly moving toward an outcome rather than
output approach, it still needs significant changes to ensure that the Agency fully
integrates the management processes of the Government Performance and Results
Act (GPRA) into its operations.
Based on an analysis that we conducted of the revised Plan, we believe this Plan
should reflect lessons learned from the previous plan and performance reports; new
knowledge about the interrelationship of environmental issues; and an evaluation of
customer/stakeholder/partner inputs about risks, priorities, benefits, and costs. This
would create a clear map to better guide future action and accountability. Our
analysis noted four major areas in need of improvement:
Management Challenges: We are particularly concerned that EPA's
Strategic Plan does not address the Major Management Challenges with
more than just a passing reference, despite the attention this area has
received by several Congressional committees, the Office of Management
and Budget, the General Accounting Office, and the OIG. The Agency's
Strategic Plan provides an opportunity for the Agency to demonstrate its
intention and commitment for solving some of these long-standing
problems.
Relationship Between Goals and Results: We are concerned that many of
the goals appear to be abstract and do not create a system linkage of
intermediate steps, actions, measures with future outcomes, and impacts.
Goals are addressed independently, without an overall scheme for
prioritization or interaction. There is no reference to the need for new
environmental legislation that would create an eco-system or holistic
approach repeatedly mentioned by stakeholders. Also, there is little if any
reference to what resources will be needed to achieve the goals and how the
Agency will hold its managers and implementers accountable.
Congressional and Stakeholder Consultation: We do not believe that this
Plan reflects the consultations that EPA had with its customers and
stakeholders. Therefore, it is difficult to determine whether the goals and
strategies were developed with adequate consideration of the risks and
priorities as viewed from outside EPA.
Data Quality, Capacity, and Measures: While the Plan generally
acknowledges that the Agency's environmental performance measures and
financial data are not complete, consistent, or reliable, this problem appears
to be understated. We believe that the lack of such information undermines
the fulfillment of GPRA and EPA's own objective of "Public Right to
Know" about environmental results and the costs of achieving them. This
also denies EPA management the information needed to make sound plans
and decisions.
PAGE 21 -APRIL 1,2000 THROUGH SEPTEMBER 30,2000
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Advisory and Assistance Services
EPA OIG Creates
Environmental
Consortium to
Achieve
Government-wide
Efficiencies
EPA OIG has created an innovative Environmental Consortium through the
President's Council on Integrity and Efficiency and Executive Council on Efficiency
and Integrity, forming partnerships throughout the federal government to achieve
greater efficiencies and more effective solutions to cross-cutting environmental
issues. The Consortium, established in May 2000, currently includes
representatives from 19 executive agencies and the U.S. General Accounting Office.
The Consortium was formed based on EPA OIG's recognition that environmental
and waste management issues were Major Management Challenges commonly
identified by a number of federal OIGs. Environmental mandates, issues,
objectives, and challenges common among these agencies present a unique
opportunity to provide better advice and recommendations to Congress from cross-
agency reviews of potential gaps, conflicts, or duplications in laws/regulations, as
well as agency performance plans and results. The Consortium illustrates how the
OIG community can work together to improve Government and solve national
issues. EPA OIG hopes to develop similar partnerships through the creation of State
Environmental Roundtables.
In recognition of his role in coming up with the concept and then creating the
Consortium, Michael Binder of the EPA OIG received a Special Achievement
Award for Excellence from the President's Council on Integrity and Efficiency.
Michael Binder (on right) receives an award presented by
Gaston Gianni, Vice Chair of the PCIE.
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Section 3 - Operating at the Highest Performance Level
New OIG Strategic
Plan Points Way to
Customer-Focused
Performance
The OIG has developed a new Strategic Plan, designed to provide a roadmap for
increasing OIG's ability to work as a results-driven, customer-focused organization.
The new Plan, which represents a major reworking of OIG's original Strategic Plan,
is designed within the framework of the Government Performance and Results Act.
The new Plan is based on the concept of "starting with the end in mind,'' by linking
OIG products and services through intermediate outputs and outcomes to anticipated
environmental outcomes and impacts. The Plan was developed mostly from input
and consultation with OIG staff, Agency management, the Office of Management
and Budget, the General Accounting Office, and over 18 Congressional committee
staffs.
The Plan features four goals:
1. Contribute to improved environmental quality and human health;
2. Improve EPA's management and program operations;
3. Produce timely, quality, and cost-effective products and services
that satisfy customer needs; and
4. Enhance diversity, innovation, teamwork, and competencies.
Our Strategic direction through fiscal year 2005 highlights both new lines of
business and organizational approaches to maximize the performance of OIG staff
and provide highly significant products and services that positively influence the
attainment of EPA's environmental goals. We will be:
Q Performing program evaluations by multi-discipline teams, to
improve accountability, reduce risks, and help EPA solve its most
difficult environmental and operational issues;
Q Partnering with others at both the federal and state levels to leverage
resources, knowledge, best practices, and solutions across a wider
scope of application; and
Q Implementing human resource and knowledge management
strategies to ensure a diverse, motivated, and competent staff.
We plan to measure our progress and performance by using a "balanced scorecard,"
combining intermediate outcomes, financial indicators, and customer satisfaction
results.
The EPA Strategic Plan is available through our web site at www.epa.gov/oigearth.
PAGE 23 -APRIL 1,2000 THROUGH SEPTEMBER 30,2000
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OIG Ho Ids
Organization- Wide
Sessions to Stress
Importance of
Diversity
The EPA OIG held several listening sessions during September to stress the
importance of diversity within the organization and give employees the opportunity
to share questions or concerns about issues of race, gender, religion, disability, age,
or sexual orientation in the workplace. The listening sessions were held as part of
OIG's actions to update its Diversity Action Plan.
"Does the OIG have an environment where you want to come to work and do a good
job ... is there an issue related to race, gender, sexual orientation, age, religion, or
disability that makes you not want to work or affects your ability to do your job. If
so, I want to hear about that issue ?" These are some of the questions Nikki Tinsley,
EPA Inspector General, asked attendees during listening sessions that she conducted
with OIG staff.
"We need to have an ongoing awareness of the need for diversity," Ms. Tinsley said,
noting that ensuring diversity within OIG will be a continuing process that will
involve listening to all employee concerns and holding senior management
accountable for maintaining a diverse and fair workplace.
During the listening sessions, Ms. Tinsley asked for comments from personnel in
the field offices. She also noted employees could provide input on a more private
basis, such as by phone, email, or in-person meetings. The team updating the
Diversity Action Plan will use the comments to develop recommendations to
eliminate barriers toward achieving diversity and a healthy working environment.
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Timeline for EPA OIG Journey
Baldrige Steering Committee Four New
Training Leadership Training Teams
HPO
Training
Office of Planning,
Analysis, & Results
1-98
4-98
6-98
1-99
3-99
12-98
Awards
Program
Maxiflex
Policy
Direction
Statement
Nearly three years ago, the Office of Inspector General embarked on a journey to improve its work environment
and productivity by gaining new skills and involving employees and customers in charting its course as "Agents of
Positive Change." Our progress is illustrated in the timeline above and summarized below.
January 1998: The journey started with a single step - a systems-oriented approach toward organizational
performance as structured by the Malcolm Baldrige Award Criteria. All OIG staff learned to use the Baldrige
criteria to assess OIG and EPA systems.
April 1998: The OIG Steering Committee, a small group of senior executives and managers, was established.
The purpose of the Committee is to provide leadership and management decisions. In addition, the committee
sponsored personal leadership training stressing the importance of active leadership. All OIG staff developed
personal leadership skills.
June 1998: The OIG Steering Committee commissioned four improvement teams: (1) "Communications," to
enhance internal communications; (2) "Awards," to support the new direction and teamwork; (3) "Process
Improvement," to steamline and improve core processes; and (4) "Strategic Planning," to increase customer and
stakeholder involvement and better assess and respond to external conditions.
December 1998: The New Awards Program was initiated to reward OIG-wide accomplishments and teamwork.
January 1999: High Performance Organization training was introduced to all staff to explain the need for system-
wide organizational change and improvement. An organizational climate survey known as the "Keys" instrument
was introduced to assess the organization's climate for innovation. A Maxiflex Policy was implemented to give
employees more flexibility and enhance the quality of the work environment.
February 1999: OIG developed a Direction Statement, outlining our vision, declaring our values, defining high
performance, and stating our leadership philosophy. This document became a definitive statement of our
improvement efforts.
March 1999: We established the Office of Planning, Analysis, and Results (PAR), to provide centralized
planning and evaluative capability. Also, OIG managers participated in enhancing the Direction Statement.
PAGE 25 -APRIL 1,2000 THROUGH SEPTEMBER 30,2000
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to Improved Performance
Business
Conference
Vision/
Perf. Workshop
Program
Evaluation
Pilots
New Organization
Structure
6-99
Strategic Plan
Process
Investigations Communications
Process Strategy
Audit Flexiplace Strategic
Process Policy Plan
June 1999: The Strategic Planning Process Team presented the OIG Steering Committee with its
recommendations for a Five-Year Strategic Plan. These suggestions stressed greater involvement of customers,
stakeholders, and employees, as well as changing various approaches. The Committee adopted the
recommendations and assigned them to PAR for implementation.
November 1999: All OIG staff participated in a Theory of the Business Conference, which was organized
around the Baldrige Award Criteria, to communicate our new direction and outline strategies. A new
Investigations Process was also established to increase Agent authority and accountability while streamlining
internal controls.
December 1999: The internal Communications Strategy was published, emphasizing the importance of personal
involvement by all OIG staff members for open and continuous communications and placing greater emphasis
on OIG's Intranet.
January 2000: The OIG Steering Committee engaged in a "Vision to Performance" workshop to give shape
and structure to our Strategic Plan. Also, the Committee sponsored two new work teams ("Values to Behaviors"
and "New Contract") to address human resource issues. All OIG staff received training in "The 7 Habits of
Highly Effective People."
April 2000: A new, streamlined Audit Process was introduced to increase accountability, reduce cycle time, and
improve product quality.
June 2000: The first Program Evaluation pilots were initiated to define evaluation objectives, scope, and
testing of our approach to program evaluation. We also initiated a survey to assess staff perceptions of our
middle managers and initiated a Flexiplace policy that allows staff to work up to two days a week at home. We
implemented the behaviors performance element for all OIG staff.
September 2000: A new OIG organizational structure was announced. The new structure separates assignment
management from human capital issues and manages the process through a matrixed organizational design,
placing greater emphasis on productivity and customer satisfaction. We completed a new performance
management system linking personal accountability to organizational goals which we will implement for all
staff in January 2001 along with 360 feedback. We also implemented the Five-Year Strategic Plan, which
adopts our new strategic goals and performance measures. Details on the Strategic Plan are on page 23 in this
semiannual report.
HTTP://WWW.EPA.GOV/OIGEARTH-PAGE26
-------
Section 4-Audit Report Resolution and Summary of Investigative Results
Status Report on Perpetual Inventory of Reports in Resolution Process for Semiannual Period Ending
September 30,2000
Report Category
A. For which no
management decision was
made by April 1, 2000
B. Which were issued
during the reporting period
C. Which were issued
during the reporting period
that required no resolution
Subtotals (A + B - C)
D. For which a
management decision was
made during the reporting
period
E. For which no
management decision was
made by
September 30, 2000
Reports for which no
management decision was
made within six months of
issuance
No.
of
Rpts
137
298
178
257
124
133
42
Report Issuance
(Dollar Value in Thousands)
Questioned
Costs
5114,425
1,964
0
116,389
15,423
100,966
99,348
Recommended
Efficiencies
SO
0
0
0
0
0
0
Report ResolutionCosts Sustained
(Dollar Value in Thousands)
To Be Recovered
$7,731
As Efficiencies
$0
(Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this report and our
previous semiannual report results from corrections made to data in our audit tracking system.)
PAGE 27-APRIL 1,2000THROUGH SEPTEMBER 30,2000
-------
Status of Management
Decisions on IG Reports
This section presents statistical
information as required by the
Inspector General Act Amendments
0/1988 on the status of EPA
management decisions on reports
issued by the OIG involving
monetary recommendations.
As presented, information contained
in Tables 1 and 2 cannot be used to
assess results of reviews performed
or controlled by this office. Many of
the reports were prepared by other
Federal auditors or independent
public accountants. EPA OIG staff
do not manage or control such
assignments. Auditeesfrequently
provide additional documentation to
support the allowability of such costs
subsequent to report issuance. We
expect that a high proportion of
unsupported costs may not be
sustained.
Table 1 ~ Inspector General Issued Reports With Questioned Costs for Semiannual Period Ending
September 30,2000
Report Category
A. For which no management decision was
made by April 1,2000**
B. New reports issued during period
Subtotals (A + B)
C. For which a management decision was made
during the reporting period
(i) Dollar value of disallowed costs
(ii) Dollar value of costs not disallowed
D. For which no management decision was
made by September 30, 2000
Reports for which no management decision was
made within six months of issuance
Number of
Reports
58
20
78
42
29
18
36
23
Questioned Costs*
(Dollar Value in Thousands)
SI 14,425
1,964
116,389
15,423
7,731
7,692
100,966
99,348
Unsupported Costs
(Dollar Value in
Thousands)
S35,746
264
36,010
4,127
1,139
2,988
31,883
31,706
* Questioned costs include the unsupported costs.
**Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this report and our
previous semiannual report results from corrections made to data in our audit tracking system.
HnP^AVWW.EPA.GOV/aGEARTH-PAGE 28
-------
Table 2 ~ Inspector General Issued Reports With Recommendations That Funds Be Put To Better Use
for Semiannual Period Ending September 30,2000
Report Category
A. For which no management decision was made by April 1, 2000
B. Which were issued during the reporting period
Subtotals (A + B)
C. For which a management decision was made during the
reporting period
(i) Dollar value of recommendations from reports that were
agreed to by management
(ii) Dollar value of recommendations from reports that were
not agreed to by management
(iii) Dollar value of non-awards or unsuccessful bidders
D. For which no management decision was made by
September 30,2000
Reports for which no management decision was made within six
months of issuance
Number of
Reports
0
0
0
0
0
0
0
0
0
Dollar Value
(In Thousands)
SO
0
0
0
0
0
0
0
0
Audits With No Final Action As Of 9/30/00-Which Are
Over 365 Days Past OIG Report Issuance Date
Audits
Programs
Assistance Agreements
Contract Audits
Single Audits
Financial Statement Audits
TOTAL
Total
34
112
25
8
6
185
Percentage
18
61
14
4
3
100
PAGE 29-APRIL 1,2000THROUGH SEPTEMBER 30,2000
-------
Summary of Investigative Results
Summary Of Investigative
Activities
Pending Investigations as
of September 30, 1999
New Investigations
Opened This Period
Investigations Closed
This Period
Pending Investigations as
of September 30, 2000
181
28
37
172
Prosecutive and
Administrative Actions
In this period, investigative efforts
resulted in four convictions and
fifteen indictments (does not include
indictments obtained in cases in
which we provided investigative
assistance). Fines and recoveries,
including those associated with civil
actions, amounted to $29 million.
Twenty-eight administrative actions
were taken as a result of
investigations.
Resignations 1
Terminations 1
Reprimands 1
Suspensions &
Debarments 17
Compliance
Agreements 3
Recoveries 3
Other 2
TOTAL 28
Profiles of Pending Investigations by Type
General EPA Programs
Total Cases = 116
Superfund
Total Cases = 56
18
Contract
: Assistance Agreement
Employee Integrity
Program Integrity
Other
HriK/AVWW£PA.GOV/C*GEARTH-PAGE 30
-------
Appendix 1 -- Reports Issued
THE INSPECTOR GENERAL ACT REQUIRES A LISTING, SUBDIVIDED ACCORDING TO SUBJECT MATTER, OF EACH REPORT ISSUED BY
THE OFFICE DURING THE REPORTING PERIOD AND FOR EACH REPORT, WHERE APPLICABLE, THE DOLLAR VALUE OF QUESTIONED COSTS
AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE
Questioned Costs
Recommended
Efficiencies
Report Number
2000 1 000330
2000 P 0000 17
2000 P 00001 8
2000 P 000019
2000 P 000020
2000 P 000021
2000 P 000022
2000 P 000023
2000 P 000024
2000 P 000025
2000 P 000026
2000 P 000027
2000 P 000028
2000 P 000029
2000 1 000416
2000 3 000100
Title
ACCESS CONTROLS OVER EPA'S MAINFRAME
COMPUTER
REGION SUPPLEMENTAL ENVIRONMENTAL
PROJECTS
MULTIMEDIA ENFORCEMENT SUCCESSES
AND OPPORTUNITIES
AIR ENFORCEMENT - STACK TESTING
OHIO SUPERFUND COOPERATIVE AGREEMENT
REGION 8 TRIBAL ASSISTANCE PROGRAM
LOUISIANA'S WATER QUALITY PROGRAM
EPA'S WATER QUALITY STANDARDS PROGRAM
CHILDREN'S ASBESTOS HEALTH INITIATIVE
NORTH CAROLINA NPDES ENFORCEMENT AND
EPA REGION 4 OVERSIGHT
FOLLOWUP OF REGION 5 BILLING AND
COLLECTION OF ACCOUNTS RECEIVABLES
BROWNFIELDS INITIATIVE FOLLOWUP
RCRA CORRECTIVE ACTION PROGRAM (GPRA)
INTERAGENCY AGREEMENTS FOLLOWUP
TOTAL PERFORMANCE REPORTS = 14
RHODE ISLAND GRANT MANAGEMENT
DELAWARE DEPT OF NATURAL RESOURCES
Final Report Ineligible Unsupported Unreasonable (Funds Be Put
Issued Costs Costs Costs To Better Use)
6/30/00
5/23/00
6/30/00
9/11/00
9/18/00
9/29/00
9/29/00
9/29/00
9/28/00
9/28/00
9/28/00
9/29/00
9/29/00
9/29/00
9,21,00
& ENVIRONMENTAL CONTROLS 6/14/00
2000 4 000059 MICHIGAN ASSOCIATION OF CONSERVATION DIET 9/07/00
TOTAL ASSISTANCE AGREEMENT REPORTS = 3
36,541
36,541
168,750
168,750
2000
2000
2000
2000
2000
2000
2000
200C
2000
200C
200C
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
000058
000059
000060
000061
000062
000063
000064
000065
000066
000067
000068
000069
000070
000071
000072
000073
000074
000075
000076
000077
000078
000079
000080
VIRGIN VALLEY WATER DISTRICT
WATERLOO, CITY OF
SUMTER COUNTY
PORTLAND, CITY OF
AMERICAN FARMLAND TRUST
SOUTH DAKOTA, STATE OF
ILSI RESEARCH FOUNDATION AND AFFILIATE
GREAT LAKES COMMISSION
HEALTH, DEPARTMENT OF
O'NEILL, CITY OF
DELAWARE, STATE OF
TEXAS, STATE OF
SOUTH CAROLINA, STATE OF
SOUTH CAROLINA, STATE OF
NORTH CAROLINA, STATE OF
LANE REGIONAL AIR POLLUTION AUTHORITY
TAHOE REGIONAL PLANNING AGENCY
NATIONAL SAFETY COUNCIL i RELATED ENTITIES
SOUTHERN APPALACHIAN MOUNTAINS INITIATIVE
UTAH, STATE OF
NEW YORK, STATE OF
NEW MEXICO ENERGY, MINERALS, & NAT RES DEPT
AR DEPT OF POLL CONTROL AND ECOLOGY/
AR DEV FIN AUTH REV
4/06/00
4/06/00
4/06/00
4/17/00
4/17/00
4/17/00
4/18/00
4/18/00
4/18/00
4/18/00
4/26/00
4/26/00
4/26/00
4/26/00
4/26/00
5/03/00
5/03/00
5/03/00
5/03/00
5/08/00
5/08/00
5/08/00
5/09/00
256,194
24,752
86,957
115,000
PAGE 31 - APRIL 1,2000 THROUGH SEPTEMBER 30,2000
-------
Report Number
2000 3 000081
2000 3 000082
2000 3 000083
2000 3 000084
2000 3 000085
2000 3 000086
2000 3 000087
2000 3 000088
2000 3 000089
2000 3 000090
2000 3 000091
2000 3 000092
2000 3 000093
2000 3 000094
2000 3 000095
2000 3 000096
2000 3 000097
2000 3 000098
2000 3 000099
2000 3 000101
2000 3 000102
2000 3 000103
2000 3 000104
2000 3 000105
2000 3 000106
2000 3 000107
2000 3 000108
2000 3 000109
2000 3 000110
2000 3 000111
2000 3 000112
2000 3 000113
2000 3 000114
2000 3 000115
2000 3 000116
2000 3 000117
2000 3 000118
2000 3 000119
2000 3 000120
2000 3 000121
2000 3 000122
2000 3 000123
2000 3 000124
2000 3 000125
2000 3 000126
2000 3 000127
2000 3 000128
2000 3 000129
2000 3 000130
2000 3 000131
2000 3 000132
2000 3 000133
2000 3 000134
2000 3 000135
2000 3 000136
2000 3 000137
2000 3 000138
2000 3 000139
2000 3 000140
2000 3 000141
Final Report
Title Issued
XAVIER UNIVERSITY OF LOUISIANA
NORTHEASTERN UNIVERSITY
SANTA BARBARA CO AIR POLLUTION CONTROL DIST
N.E STATES FOR COORDINATED AIR USE MGT
SOUTH CAROLINA, STATE OF
PENNSYLVANIA, COMMONWEALTH OF
PENNSYLVANIA, COMMONWEALTH OF
COLORADO, STATE OF
ALASKA, STATE OF
ALASKA, STATE OF
TILLAMOOK COUNTY
SETAC FOUNDATION FOR ENVIRONMENTAL EDUC
BOIS FORTE BAND OF CHIPPEWA INDIANS
RHODE ISLAND, STATE OF
RHODE ISLAND, STATE OF
CONNECTICUT, STATE OF
VERMONT, STATE OF
OREGON, STATE OF
BRANDEIS UNIVERSITY
NAT SENIOR CITIZEN EDUC & RESEARCH CENTER
SOMERSET COUNTY, PA
NATIONAL COUNCIL OF THE CHURCHES OF CHRIST
KAISER FOUNDATION HEALTH PLAN
CALIFORNIA INSTITUTE OF TECHNOLOGY
ILLINOIS STATE UNIVERSITY
OHIO STATE UNIVERSITY
NEW MEXICO - ENVIRONMENT DEPT, STATE OF
KENTUCKY, COMMONWEALTH OF
NEBRASKA, STATE OF
LOUISIANA, STATE OF
ENVIRONMENTAL ALLIANCE FOR SEN INVOLVEMENT
SOUTH DAKOTA, STATE OF
HAWAII - DEPARTMENT OF HEALTH, STATE OF
WISCONSIN, STATE OF
OREGON GRADUATE INSTITUTE OF SCIENCE & TECH
ILLINOIS, STATE DEPARTMENT OF PUBLIC HEALTH
STATE OF FLORIDA
GEORGIA, STATE OF
MONTANA, STATE OF
SENACA NATION OF INDIANS
FOND DU LAC RESERVATION
CHILD & FAMILY RESOURCES, INC
BURLINGTON, CITY OF
ALORN STATE UNIVERSITY
INDIANA, STATE OF
ILLINOIS-DEPT OF AGRICULTURE, STATE OF
ILLINOIS-DEFT OF NATURAL RESOURCES
ILLINOIS-DEPT OF NATURAL RESOURCES
NEW MEXICO INSTITUTE OF MINING & TECHNOLOGY
MASSACHUSETTS, COMMONWEALTH OF
DELAWARE, STATE OF
MENOMINNE INDIAN TRIBE OF WISCONSIN
WYOMING, UNIVERSITY OF
SEMINOLE TRIBE OF FLORIDA
CROW TRIBE OF INDIANS
HARVARD UNIVERSITY AND RADCLIFFE
NEW HAMPSHIRE, UNIVERSITY SYSTEM OF
PYRAMID LAKE PAIUTE TRIBE
HOWARD UNIVERSITY
SAN BERNARDINO MUNICIPAL WATER DEPT
5/11/00
5/11/00
5/11/00
5/11/00
5/18/00
5/18/00
5/18/00
5/18/00
5/18/00
5/18/00
5/30/00
5/30/00
5/31/00
6/05/00
6/05/00
6/05/00
6/05/00
6/05/00
6/05/00
6/16/00
6/27/00
6/29/00
7/05/00
7/07/00
7/11/00
7/11/00
7/12/00
7/12/00
7/12/00
7/12/00
7/12/00
7/13/00
7/13/00
7/13/00
7/27/00
7/31/00
7/31/00
7/31/00
7/31/00
8/09/00
8/11/00
8/14/00
8/14/00
8/17/00
8/23/00
8/23/00
8/28/00
8/28/00
8/31/00
8/31/00
8/31/00
8/31/00
8/31/00
9/01/00
9/05/00
9/08/00
9/08/00
9/19/00
9/19/00
9/20/00
Recommended
Questioned Costs Efficiencies
Ineligible Unsupported Unreasonable (Funds Be Put
Costs Costs Costs To Better Use)
186, 686
14,773
6,216
26,126
TOTAL SINGLE AUDIT REPORTS = 83
629,747
86,957
HTTP://WWW.EPA.GOV/OIGEARTH -PAGE 32
-------
Report Number
Title
Final Report
Issued
Questioned Costs
Ineligible
Costs
Unsupported
Costs
Recommended
Efficiencies
Unreasonable (Funds Be Put
Costs To Better Use)
1999 1 000303 TRC - EC FY 94 6/13/00
2000 1 000318 EQMI 1998 6/07/00
2000 1 000371 TRC - EC FY 95 8/24/00
2000 1 000386 PRC EMI TES 2 9/05/00
2000 1 000425 ICF CG SEGMENT D/S COMPLIANCE REVIEW 9/27/00
2000 1 000427 ICF CONSULTING GROUP D/S COMPLIANCE REVIEW 9/27/00
2000 2 000013 E&E PROPOSAL (START 2 - REGION IV) 8/18/00
2000 2 000014 E&E PROPOSAL REGION 2 SAT 8/18/00
2000 2 000015 MPI/REGION 2 SITE ASSESSMENT TEAM 8/25/00
2000 2 000016 EScE PROPOSAL REGION 8 START 9/20/00
2000 4 000060 GUARDIAN ENVIRONMENTAL SERVICES
ACCOUNTING SYSTEM REVIEW 9/22/00
777,680
21,539
TOTAL OIG ISSUED CONTRACT REPORTS
11
799,219
2000 1
2000 2
2000 1
2000 2
2000 2
2000 1
2000 I
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
2000 4
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
2000 4
2000 1
2000 1
2000 1
2000 4
2000 1
2000 1
2000 1
2000 4
2000 4
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
000301
000009
000281
000010
000017
000264
000266
000268
000269
000271
000274
000273
000277
000280
000052
000283
000290
000293
000295
000294
000292
000053
000297
000296
000299
000054
000303
000302
000310
000056
000055
000312
000316
000314
000315
000319
000320
000322
000321
000335
000336
ICES LTD-FY 96 I/C 5/17/00
ADVANCED TECHNOLOGIES SYSTEMS INC 4/05/00
CUMMINGS RITER CONSULTANTS 4/25/00
FEV ENGINE TECHNOLOGY, INC 5/16/00
EC/R INCORPORATED 9/22/00
DEVELOPMENT PLNG & RSCH ASSOC-FY 99 I/C 4/04/00
GREAT LAKES ENVIRONMENAL-FY 98 i/c 4/04/00
FEV OF AMERICA-FY 98 I/C 4/98-12/98 4/06/00
CADMUS GROUP INC, FY 97 I/C 4/06/00
I T CORP-FY98 INCURRED COST 4/10/00
GEOLOGICS CORP-FY 97-98 I/C 4/10/00
LOCKHEED MARTIN SVCS GROUP-FY 97 I/C 4/10/00
ENERGY & ENVIRONMENTAL RSCH-FY 96497 I/C 4/12/00
CTC TECHNOLOGIES, INC-FY 96497 I/C 4/20/00
LEE WILSON 4 ASSOCIATES-FY 98 I/C 4/21/00
LEE WILSON 4 ASSOCIATES-FY97 I/C 4/26/00
LOCKHEED ENGINEERING-FY 92 I/C 5/08/00
ARTHUR D. LITTLE-FY 1995 I/C 5/08/00
ABB ENVIRONMETAL SERVICES-FY96 I/C 5/08/00
DYNCORP VIAR INC-FY91&92 I/C SUPPLEMENTAL 5/08/00
ARTHUR D. LITTLE, INC-FY 96 I/C 5/08/00
ADSYSTECH INC-FY 97 I/C 5/09/00
ADSYSTECH INC-FY 96 I/C 5/09/00
ADSYSTECH INC-FY 93, 94 4 95 I/C 5/09/00
AUTOMOTIVE TESTING LAB-CY 98 I/C 5/15/00
ICES LTD-FY 98 I/C 5/17/00
HYDROGEOLOGIC, INC-FY 98 I/C 5/17/00
NORTHBRIDGE ENVTL MGMT CNST-FY 98 I/C 5/17/00
GRIFFIN SERVICES INC-FY 94,95,4 96 I/C 5/25/00
ACUREX ENVIRONMENTAL CORP-FY 96 I/C 5/25/00
ACUREX ENVIRONMENTAL CORP-FY 97 I/C 5/25/00
DYNCORP VIAR, INC-FY 93 4 94 I/C
SUPPLEMENTAL 6/07/00
TRANDES CORPORATION-FY 97 4 98 I/C 6/07/00
SVERDRUP CORPORATION-FY98 INCURRED COST 6/07/00
AGEISS ENVIRONMENTAL INC-FY 97 I/C 6/07/00
PARSONS ENGINEERING SCIENCE-FY94 I/C 6/08/00
VISTA COMPUTER SERVICES-FY 96 I/C 6/16/00
COMPUTER SCIENCES CORP-FY 95 AND 96 I/C 6/16/00
DYNCORP INC-CY 97-98 MULTI-YEAR I/C 6/16/00
ENTERPRISE ADVISORY SVCS-FY 95 I/C 7/10/00
COMPUTER BASED SYSTEMS-FY 98 I/C 7/10/00
14,475
11,876
59,245
PAGE 33 - APRIL 1,2000 THROUGH SEPTEMBER 30,2000
-------
Recommended
Report Number
2000 1 000337
2000 1 000343
2000 1 000344
2000 1 000346
2000 1 000347
2000 4 000057
2000 4 000058
2000 1 000351
2000 1 000350
2000 1 000348
2000 1 000349
2000 1 000352
2000 1 000356
2000 1 000366
2000 1 000367
2000 1 000368
2000 1 000372
2000 1 000373
2000 1 000374
2000 1 000376
2000 1 000377
2000 1 000375
2000 1 000379
2000 1 000385
2000 I 000382
2000 1 000380
2000 1 000381
2000 1 000388
2000 1 000412
2000 1 000415
2000 1 000413
2000 1 000414
2000 1 000418
2000 1 000422
2000 1 000432
2000 1 000423
Questioned Costs Efficiencies
Final Report Ineligible Unsupported Unreasonable (Funds Be Put
Title Issued Costs Costs Costs To Berrpr- rise!
CDM FEDERAL PROGRAMS CORP-FY 98 I/C
LIFE SYSTEMS-FY 90-93 I/C SUPPLEMENTAL
SEAWARD SERVICES -FY 98 I/C
ADVANCED TECHNOLOGY SYSTEMS-FY 98 I/C
SYSTEMS INTEGRATION GROUP-FY 90 - 92 I/C
SYSTEMS INTEGRATION GROUP-FY 96 I/C
SYSTEMS INTEGRATION GROUP-FY 97 I/C
HALLIBORTON/NUS C/0 BROWN 4 ROOT
FY 96 I/C
BROWN & ROOT ENVIRONMENTAL-FY 97 I/C
SYSTEMS INTEGRATION GROUP-FY 94 I/C
SYSTEMS INTEGRATION INC
MORRISON KNUDSEN COMPANY-FY 98 I/C
AUTOMATED SCIENCES GROUP, INC- CY 88-92 I/C
MAR INC-FY 96 & 97 I/C
ALPHA-GAMMA TECHNOLOGIES -FY 97 I/C
PACIFIC ENVIRONMENTAL SERVICE INC
FY 98 I/C
DYNAMAC CORPORATION-FY 96 & 97 I/C
INTEGRATED LABORATORY SYS-FY 97 I/C
HAZARDOUS AND MEDICAL WASTE-FY 96 I/C
FOUR SEASONS INDUSTRIAL SERVICES
FY 94 I/C
FOUR SEASONS INDUSTRIAL SERVICES
FY 95 I/C
FOUR SEASONS INDUSTRIAL SERVICES
FY 93 I/C
PRC/TETRA TECH EMI-FY 98 I/C
URS GREINER, INC-FY 97 I/C
SCIENCE AND POLICY ASSOCIATE, INC
FY 92 I/C
METCALF & EDDY, INC-FY 97 I/C
SOCIOMETRICS INC-FY 89-94 I/C
NATIONAL ACADEMY OF SCIENCE-FY 98 I/C
SYSTEMS INTEGRATION GROUP-FY 98 I/C
TETRA TECH, INC-FY 98 I/C
ROY F WESTON-FY 98 I/C
MANTECH ENVIRONMENTAL TECH-FY 97498 I/C
METCALF & EDDY INC-FY 91-95 I/C
MARASCO NEWTON GROUP LTD FY 98 I/C
JACOBS ENGINEERING- FY 96 I/C
GANNETT FLEMING ENVIRONMENTAL ENGINEERS
7/10/00
7/26/00
7/26/00
8/02/00
8/04/00
8/04/00
8/04/00
8/04/00
8/04/00
8/04/00
8/04/00
8/07/00
8/10/00
8/21/00
8/21/00
8/23/00
8/24/00
8/24/00
8/25/00
8/25/00
8/25/00
8/25/00
8/30/00
8/30/00 2,756
8/30/00
8/30/00
8/30/00
9/06/00
9/18/00
9/18/00
9/18/00
9/18/00
9/22/00
9/22/00
9/27/00
HTTP://WWW.EPA.GOV/OIGEARTH -PAGE 34
-------
Report
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
1
1
1
1
1
1
1
1
1
I
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Number
000265
000298
000305
000317
000331
000353
000389
000390
000407
000328
000332
000342
000267
000307
000308
000338
000359
000360
000378
000392
000396
000398
000399
000401
Title
FY98 I/C
BATTELLE MEMORIAL INSTITUTE
COMPUTER SCIENCES CORP
RESEARCH TRIANGLE INSTITUTE
BLACK & VEATCH SPECIAL PROJ.-1996 ARCS
TECHLAW INC
VERSAR, INC
BLACK & VEATCH SPECIAL PROJ-FY 97 ARCS
ENTROPY ENVIRONMENTAL INC
CDM FEDERAL PROGRAMS -FY 97
FOSTER WHEELER ENVIRONMENTAL CORP
COMPENSATION FOLLOW-UP
JACOBS ENGINEERING GROUP-BILLING SYSTEM
INTERNAL CONTROLS
CET ENVIRONMENTAL- FY 99 FLOORCHECK
ENSERCH CORPORATION- CAS 405
DPRA-CAS 404
DPRA-CAS 409
DPRA-DISCLSOURE STATEMENT
BATTELLE MEMORIAL INSTITUTE-CAS 416
BATTELLE MEMORIAL INSTITUTE-CAS 403
AST ASSOCIATES INC-CAS 403
SOUTHWEST RESEARCH INSTITUTE-CAS 416
BATTELLE COLUMBUS OPERATIONS-CAS 404
BATTELLE COLUMBUS OPERATIONS - CAS 418
BATTELLE COLUMBUS OPERATIONS - CAS 418
BATELLE COLUMBUS OPERATIONS - FY 97
Recommended
Questioned Costs Efficiencies
Final Report Ineligible Unsupported Unreasonable (Funds Be Put
Issued Costs Costs Costs To Better Use)
9/27/00
4/04/00
5/15/00
5/15/00
6/07/00
7/05/00
8/08/00 6,439
9/07/00
9/07/00
9/14/00
6/29/00
7/05/00
7/24/00
4/06/00
5/23/00
5/23/00
7/10/00
8/10/00
8/10/00
8/30/00
9/07/00
9/11/00
9/11/00
9/11/00
2000 1 000400
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
2000
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
000397
000417
000419
000421
000420
000424
000270
000272
000275
000276
000282
000284
000285
000286
000287
000289
000291
20CO 1 000300
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
2000 1
000304
000306
000309
000311
000313
000323
000324
000325
2000 1 000327
CAS 408 & 409 9/11/00
BATELLE COLUMBUS OPERATIONS - FY 97
CAS 408 & 409 9/11/00
BATTELLE COLUMBUS OPERATIONS - CAS 410 9/11/00
BECHTEL NATIONAL - CAS 408 9/22/00
EASTERN RESEARCH GROUP-CAS 403
ALLOCATION OF HOME OFFICE EXPENSES 9/26/00
EASTERN RESEARCH GROUP-CAS 404
CAP OF TANGIBLE ASSETS 9/26/00
EASTERN RESEARCH GROUP-CAS 418
ALLOCATION OF DIRECT/INDIRECT 9/26/00
EASTERN RESEARCH GROUP-CAS 410
ALLOCATION OF BUSINESS G&A 9/27/00
PACIFIC ENVIRONMENTAL SERVICE - CASE
DISCLOSURE STATEMENT 4/06/00
AUTOMOTIVE TESTING LABORATOR - FY 98
FLOORCHECK 4/10/00
DPRA, INC-DISCLOSURE STATEMENT
REVISION #7 4/10/00
DPRA-FLOORCHECK 4/11/00
LOCKHEED MARTIN SERVICES, INC-DISCLOSURE
STATEMENT REV 3 4/26/00
IT GROUP INC-DISCLOSURE STATEMENT
REVISION 5 4/26/00
IT GROUP, INC-FY 2000 PREDETERMINED
DAILY EQUIPMENT RATES 4/26/00
IT GROUP, INC-FY 2000-02 PROVISIONAL
BIDDING & BILLING RATES 4/26/00
IT GROUP, INC-FY 2000 IT QATS
PROVISIONAL RATES 5/01/00
BATTELLE MEMORIAL INST-FY 2000 CPSR 5/08/00
DEVELOPMENT PLANNING & RSCH ASSOC
DISCLOSURE STATEMENT REVS 5/08/00
FEV ENGINE TECHNOLOGY-ACCOUNTING SYSTEM
£c INTERNAL CONTROLS 5/16/00
HYDROGEOLOGIC, INC-CACS 5/17/00
ANALYTICAL ENGINEERING-ACCOUNTING SYSTEM 5/23/00
SVERDRUP CIVIL-FY 2000 FLOORCHECK 5/25/00
ROY F. WESTON-FY 1993 ARCS CLOSEOUT 5/25/00
ROY F. WESTON-FY 1995 ARCS CLOSEOUT 6/07/00
IT GROUP-BUDGETING SYSTEM Sc FIN. REVIEW 6/19/00
LOCKHEED MARTIN SERVICES-FLOORCHECK-NC 6/21/00
ACUREX ENVIRONMENTAL CORPORATION - FY 1998
FLOORCHECK 6/21/00
SCIENCE APPLICATIONS INT'L CORP-CACS 6/28/00
PAGE 35 - APRIL 1,2000 THROUGH SEPTEMBER 30,2000
-------
Recommended
Report Number
2000 1 000333
2000 1 000334
2000 1 000340
2000 1 000341
2000 1 000345
2000 1 000354
2000 1 000358
2000 1 000362
2000 1 000364
2000 1 000365
2000 1 000363
2000 1 000361
2000 1 000357
2000 1 000355
2000 1 000369
2000 1 000370
2000 1 000383
2000 1 000384
2000 1 000387
2000 1 000391
2000 1 000393
2000 1 000394
2000 1 000395
2000 1 000402
2000 1 000403
2000 1 000404
2000 1 000405
2000 1 000406
2000 1 000408
2000 1 000409
2000 1 000410
2000 1 000411
2000 1 000426
2000 1 000428
2000 2 000031
2000 2 000030
2000 2 000029
2000 2 000028
2000 2 000027
2000 2 000026
2000 2 000025
2000 2 000024
Title
JACOBS ENGINEERING GROUP-ACCOUNTING
SYSTEM CONTROLS
BLACK 5c VEATCH SPECIAL PROJECTS CORP
CH2M HILL, INC- COMPENSATION REVIEW
SYRACUSE RESEARCH CORPORATION-FY 99
OVERHEAD AUDIT
DEVELOPMENT PLANNING & RSCH ASSOC
DISCLOSURE STATEMENT REV 9
BATTELLE COLUMBUS OPERATIONS - LABOR
BATTELLE MEMORIAL INSTITUTE-MAAR 13
BATTELLE MEMORIAL INSTITUTE
DISCLOSURE STATEMENT SCO- 4 8
BATTELLE MEMORIAL INSTITUTE
DISCLOSURE STATEMENT BMI-30
BATTELLE MEMORIAL INSTITUTE
LABOR ACCOUNTING SYSTEM
BATTELLE MEMORIAL INSTITUTE
DISCLOSURE STATEMENT CPHRE-14
BATTELLE MEMORIAL INSTITUTE
DISCLOSURE STATEMENT BCO-47
BATTELLE MEMORIAL INSTITUTE
GENERAL INTERNAL CONTROLS
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
BATTELLE MEMORIAL INSTITUTE
JULY FLOORCHECK
BATTELLE MEMORIAL INSTITUTE
AUGUST FLOORCHECK
BECHTEL ENVIRONMENTAL INC
ETS, INC -ACCOUNT ING & BILLING SYSTEM
ENTROPY INC
EC/R INC-FY 1998 FLOORCHECK
ALPHA-GAMMA TECHNOLOGIES INC
FY 1997 FLOORCHECK
BATTELLE COLUMBUS OPERATIONS
LABOR COMPENSATION AUDIT
BATTELLE COLUMBUS OPERATIONS
LABOR COMPENSATION AUDIT
BATTELLE COLUMBUS OPERATIONS
LABOR COMPENSATION AUDIT
BATTELLE COLUMBUS OPERATIONS
LABOR COMPENSATION AUDIT
BATTELLE COLUMBUS OPERATIONS
LABOR COMPENSATION AUDIT
BATTELLE COLUMBUS OPERATIONS
MAAR 13 MATERIAL EXISTENCE
URS OPERATING SERVICE INC
ENTROPY ENVIRONMENTALISTS INC-CACS
Questioned Costs Efficiencies
Final Report Ineligible Unsupported Unreasonable (Funds Be Put
Issued Costs Costs Costs To Better Use)
7/05/00
7/05/00
7/24/00
7/24/00
8/02/00
AUDIT 8/10/00
8/10/00
8/10/00
8/10/00
8/10/00
8/10/00
8/10/00
8/10/00
8/10/00 5,361
8/24/00
8/24/00
8/30/00
8/30/00
9/06/00
AUDIT 9/07/00
9/08/00
9/08/00
9/08/00
9/11/00
9/11/00
9/13/00
9/13/00
9/13/00
9/15/00
9/15/00
9/15/00
ABT ASSOCIATES INC-EDP GENERAL CONTROLS 9/18/00
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
CET ENVIRONMENTAL SERVICES INC
9/27/00
9/27/00
9/27/00
9/27/00
9/27/00
9/27/00
9/27/00
9/27/00
9/27/00
HTTP://WWW.EPA.GOV/OIGEARTII -PAGE 36
-------
Questioned Costs
Report Number
Title
Final Report
Issued
Ineligible
Costs
Unsupported
Costs
Recommended
Efficiencies
Unreasonable (Funds Be Put
Costs To Better Use)
REVIEW OF INVOICES
2 000023 CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
2 000022 CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
2 000021 CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
1 00042S CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
2 000018 CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
2 000019 CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
2 000020 CET ENVIRONMENTAL SERVICES INC
REVIEW OF INVOICES
2000 1 000430 COM FEDERAL PROGRAM CORP-FY 98
2000 1 000431 BECHTEL SYS & INFRASTRUCTURE
INDIRECT/DIRECT COST FOLLOW-UP
2000 1 000434 BECHTEL ENVIRONMENTAL - MAARS 13 & 6
2000 1 000435 BECHTEL ENVIRONMENTAL - MAARS 13 & 6
2000 1 000436 BECHTEL ENVIRONMENTAL - MAARS 13 & 6
TOTAL DCCA CONTRACT REPORTS = 183
93,811
2000 1 000278
2000 1 000326
FY 99 FIFRA FINANCIAL STATEMENT AUDIT
SOUTH CAROLINA CLEAN WATER SRF
2000 S 000005
2000 S 000006
TOTAL FINANCIAL STATEMENT REPORTS = 2
PARKER LANDFILL RESPONSE CLAIM
ABEX CORPORATION
TOTAL SPECIAL REVIEW REPORTS =
8/21/00
8/31/00
130,396
130,396
3, 361
3, 361
TOTAL REPORTS ISSUED = 298
1,696,153
264,167
3, 361
PAGE 37 - APRIL 1,2000 nIROUGII SEPTEMBER 30,2000
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OIG MAILING ADDRESSES and TELEPHONE NUMBERS
OIG HOTLINE 1-888-546-8740 or (202) 260-4977
Headquarters
Environmental Protection Agency
Office of Inspector General
1200 Pennsylvania Ave. NW (2441)
Washington, DC 20460
(202)260-3137
Atlanta
Environmental Protection Agency
Office of Inspector General
61 Forsyth Street, SW
Atlanta, GA 30303
Audit: (404) 562-9830
Investigations: (404) 562-9857
Boston
Environmental Protection Agency
Office of Inspector General
JFK Federal Building (OIG)
(office at 1 Congress St)
Boston, MA 02203
Audit (617)565-3160
Investigations-^ 17) 565-3928
Chicago
Environmental Protection Agency
Office of Inspector General
77 West Jackson Boulevard
13th Floor (IA-13J)
Chicago. IL 60604
Audit: (312) 353-2486
Investigations: (312) 353-2507
Cincinnati
Environmental Protection Agency
Office of Inspector General
MS • Norwood
Cincinnati. OH 45268-7001
Audit- (513)366-4360
Investigations (312) 353-2507 (Chicago)
Dallas
Environmental Protection Agency
Office of Inspector General (6OIG)
1445 Ross Avenue, Suite 1200
Dallas, 'I Xs 75202-2733
Audit (214)665-6621
Investigations (404) 562-9857 (Atlanta)
Denver
Environmental Protection Agency
Office of Inspector General
999 18th Street, Suite 500
Denver, CO 80202-2405
Audit. (303)312-6872
Investigations: (312) 353-2507 (Chicago)
Kansas City
Environmental Protection Agency
Office of Inspector General
901 N 5Ih Street
Kansas City, KS 66101
Audit: (913) 551-7878
Investigations. (312) 353-2507 (Chicago)
New York
Office of Inspector General
290 Boardway. Room 1520
New York. NY 10007
Audit. (212)637-3080
Investigations: (212) 637-3041
Philadelphia
Environmental Protection Agency
Office of Inspector General
1650 Arch Street, 3rd Floor
Philadelphia, PA 19103-2029
Audit (215)814-5800
Investigations: (215) 814-2361
Research Triangle Park, NC
Environmental Protection Agency
Office of Inspector General
Catavvba Building
Highway 54, Mail Drop 53
Research Triangle Park. NC 27711
Audit-(919) 541-2204
Investigations: (919) 541-1027
Sacramento
Environmental Protection Agency
Office of Inspector General
650 Capitol Mall. Suite 6309
Sacramento, CA 95814
Audit: (916) 498-6530
Investigations- (415) 744-2465 (SF)
San Francisco
Environmental Protection Agency
Office of Inspector General
75 Hawthorne St (1-1)
19th Floor
San Francisco. CA94105
Audit (415)744-2445
Investigations- (415) 744-2465
Seattle
Environmental Protection Agency-
Office of Inspector General
12006th Avenue. 19th Floor
Suite 1920, M/SO1G-195
Seattle. WA 98101
Audit. (206) 553-4033
Investigations. (206) 553-1273
PAGE-38 APRIL 1. 2000 THROUGH SEPTEMBER 30, 2000
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ontal Protection
nmenta
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ul
O
ITS YOUR ENVIRONMENT
ITS YOUR MONEY
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