EPA-350-K-04-001
                                          May 2004
\.
OFFICE OF INSPECTOR GENERAL
                         Catalyst for Improving the Environment
   Semiannual Report
   to Congress

   October 1, 2003 - March 31, 2004
 The EPA Office of Inspector General recently conducted a review
 ofhardrock mining Superfund sites. See inside for details.

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                           EPA Inspector General
                           Vision Statement
   We are catalysts for improving the quality of the Environment and Government through problem
   prevention and identification, and cooperative solutions.
                                  Mission
   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.
            To find out more about the U.S. Environmental Protection Agency's
                    Office of Inspector General, visit our web site at:

                       http://www.epa.gov/oig
Cover photo:   The Homestake Mine hardrock mining site, Lead, South Dakota (EPA OIG Photo).
         Printed with vegetable oil based inks on 100% recycled paper (minimum 50% postconsumer)

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Foreword
            Our work during the semiannual reporting period noted several areas of potential
            funding problems with regard to Superfund projects.

            In response to a Congressional request, we estimated that there was a $174.9 million
            shortfall for fiscal 2003 non-Federal Superfund projects.  This prevented the
            Environmental Protection Agency (EPA) from beginning construction at all sites or
            providing the amount of funds believed to be needed in some instances. In addition,
            during our audit of EPA's financial statements for fiscal 2003, we noted that the
            Superfund Trust Fund transferred funds in excess of the  Fund assets available for
            transfer by $82.7 million for that year, and that shortfall  was subsequently covered by
            fiscal 2004 appropriations from the Treasury's general fund.

            During the period, we issued a report on hardrock mining (extraction of certain metals
            and minerals from the earth, excluding coal). We found 156 hardrock mining sites
            nationwide with the potential to cost between $7 billion and $24 billion to clean up (at a
            maximum EPA cost of $15 billion), and many of these sites will involve Superfund
            work.  The EPA costs noted are over 12 times EPA's total annual Superfund budget of
            about $1.2 billion for the last 5 years.

            We also issued reports regarding EPA's homeland security efforts.  We found that EPA
            does not have  adequate processes for identifying, obtaining, maintaining, and tracking
            counter terrorism/emergency response equipment, and needs to do better planning. We
            also found that EPA's Office of Homeland Security needs to better define its homeland
            security role regarding air protection; while we acknowledge this is a relatively new area
            for EPA, we want to stress the importance of clarifying EPA's future roles and
            responsibilities.

            A review disclosed that EPA has not fully implemented Executive Order  12898 to
            provide environmental justice for minority and low income  populations. Although
            progress has been made at the EPA regional level, definitions and a clear vision need to
            be provided at the national level to ensure EPA provides environmental justice in a
            consistent and sufficient manner.

            EPA earned an unqualified opinion on its fiscal 2003 financial statements, and we did
            not note any material weaknesses in internal controls and compliance.  When evaluating
            internal controls, we noted eight reportable conditions that should be corrected, but we
            do not believe they represent material weaknesses that would prevent the fair
            presentation of reliable statements.

            Details on these issues and others are in this semiannual report.
                                               Co-tĞ~U~
                                               Nikki L. Tinsley
                                               Inspector General

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                       Table of Contents
Highlights
Profile of Activities and Results ..
2
Significant OIG Activity	    3

      Air (helping to make air safe and healthy to breathe) 	    3
      Water (ensuring that drinking water is safe and sources are protected) 	    6
      Land (improving waste management and cleanup - includes Superfund) 	    8
      Cross-Media (issues involving overlapping areas - includes homeland security) 	   13
      Grants (improving EPA's use of assistance agreements)	   16
      Contracts (improving EPA's use of contracts) 	   19
      Financial Reporting (improving the Agency's financial reporting) 	   21
      Business Systems (improving the Agency's information technology) 	   23
      Investigations (investigating laboratory fraud, financial fraud, and computer crimes)	   24
      Public Liaison (addressing specific concerns of the public)  	   31
      Congressional Requests (providing Congress with specific information) 	   34
      Testimony (providing testimony before Congressional committees)  	   36
      Other Activities  	   38
Statistical Data
Appendices
         Appendix 1 - Reports Issued  	  51
         Appendix 2 - Reports Issued Without Management Decisions
                     (Available Upon Request)

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                                Highlights
 Environmental Justice Not
 Consistently Implemented

EPA has not fully implemented
Executive Order 12898 to
provide environmental justice
for minority and low income
populations (page 13).

 Buying Counter Terrorism
 Equipment Can Be Improved

EPA does not have adequate
processes for obtaining and
tracking equipment to respond
to terrorist attacks and other
emergency situations (page 19).

 EPA Financial Statements
 Earn Unqualified Opinion

EPA earned an unqualified
opinion on its fiscal 2003
financial statements, and no
material weaknesses were noted
(page 21).

 Sentencing Handed Down in
 Child Pornography Case

A former contract employee
was sentenced for possession of
child pornography, after using
an EPA computer to download
the material (page 26).

 Superfund Shortfall of
 $174.9 Million Reported

In response to a Congressional
request, we issued a report on
Superfund financing that
estimated a $174.9 million
shortfall for non-Federal sites
(page 34).
 Lobbying Organization
 Inappropriately Given Grant

We questioned $4.7 million in
grant funds given to Consumer
Federation of America, a
lobbying group (page 16).

 Financial Impacts of
 Hardrock Mining Sites Noted

Hardrock mining sites
identified nationwide may have
major financial impacts on
Superfund resources and States
(page 8).

 Drinking Water Goals
 Incorrectly Reported

In each of the last 4 years, EPA
incorrectly reported meeting its
drinking water goal since it
relied on flawed and
incomplete data (page 6).

 Air Toxics Measurement
 Can Be Improved

Although air toxics estimating
methods have been improving,
unvalidated assumptions and
other limitations continue to
impact usefulness (page 3).

 Testimony Addresses
 Assistance Agreements

During testimony before
several Congressional
subcommittees, we discussed
the need to improve
management of assistance
agreements (page 36).
 Bunker Hill Review Notes
 Actions Appropriate
A review of complaints
regarding the Bunker Hill
Superfund site and the
surrounding area found that
EPA generally followed laws
and regulations (page 31).

 EPA Should Improve
 Computer Network Firewalls
While EPA has taken positive
actions to improve computer
system firewalls, additional
areas need to be addressed
(page 23).

 Impersonator Sentenced
 to Prison Term
A man was sentenced to prison
for impersonating an employee
of EPA and other organizations
to defraud employment
agencies (page 27).

 Inspector General  Receives
 Leadership Award
The EPA Inspector General
was presented with the
Distinguished Federal
Leadership Award from the
Association of Government
Accountants (page 40).

 Inspector General  Issues
 Revised Strategic Plan
The Office of Inspector
General has revised and issued
anew Strategic Plan (page 42).

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                 Profile of Activities  and Results
              Audit Operations
          Reviews Performed by EPA OIG
                                    October 1,2003 to
                                      March 31, 2004
                                   (dollars in millions)
Questioned Costs *
 - Total
 - Federal

Recommended Efficiencies *
 - Federal

Costs Disallowed to be Recovered
 - Federal

Costs Disallowed as Cost Efficiency
 - Federal

Reports Issued - OIG-Managed Reviews
 - EPA Reviews Performed by OIG

Reports Resolved
 (Agreement by Agency officials to
 take satisfactory corrective actions)***
$4.7
$4.7
 $0


$0.5


 $0


 18



 51
                     Audit Operations
                         Other Reviews
         (Reviews Performed by Another Federal Agency
                   or Single Audit Act Auditors)
                                          October 1, 2003 to
                                            March 31, 2004
                                         (dollars in millions)
Questioned Costs *
 - Total
 - Federal

Recommended Efficiencies *
 - Federal

Costs Disallowed to be Recovered
 - Federal

Costs Disallowed as Cost Efficiency
 - Federal

Reports Issued - Other Reviews
 - EPA Reviews Performed by
    Another Federal Agency
 - Single Audit Act Reviews
 Total

Agency Recoveries
 Recoveries from Audit Resolutions
 of Current and Prior Periods
 (cash collections or offsets to
 future payments) **
$3.4
$3.4
 $0


$0.5


 $0
 87
 72
 159
                                                                                               $0.007
                                    Investigative Operations
                                                                 October 1, 2003 to
                                                                   March 31, 2004
                                                                (dollars in millions)

                        Fines and Recoveries (including civil) ****                  $1.0

                        Cases Opened During Period                             58

                        Cases Closed During Period                             75

                        Indictments/Criminal Informations/Complaints                 8

                        Convictions                                           26

                        Civil Actions                                           3

                        Administrative Actions Against EPA Employees/Firms          21
      Questioned Costs and Recommended Efficiencies subject to change pending further review in 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.
      Total includes actions resulting from joint investigations.

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Significant OIG Activity
  Helping to make air safe and healthy to breathe.
             Air Toxics Measurement Can Be Improved

             Although the methods used to estimate air toxics emissions have improved substantially
             in recent years, unvalidated assumptions and other limitations underlying the National
             Toxics Inventory continue to impact its use as a Government Performance and Results
             Act measure.

             Toxic air pollutants are harmful substances that are known or suspected to cause cancer
             and other serious health problems, and can also have adverse environmental effects.
             A vital component related to  reducing such pollutants is the National Toxics Inventory,
             an estimate made once every 3 years of the total amount of air toxics emitted annually
             nationwide.
             EPA is not certain how much progress it has actually made in reducing air toxics
             emissions since it established its 1993 baseline.  Due to improvements in later
             inventories, the meaningfulness of comparing new inventories against the 1993 baseline
             is questionable. For example, although use of State-validated emissions data is EPA's
                                                  preferred calculation methodology, only
                                                  3 States provided data to EPA for the 1993
                                                  inventory, while 36 States provided data for
                                                  the 1996 inventory and 39 for the 1999
                                                  inventory. Further, States were not required
                                                  to verify their emissions data for any of the
                                                  inventories. Agency officials said the  Clean
                                                  Air Act only required limited scope studies
                                                  on a select number of toxic air pollutants
                                                  found primarily in urban areas. As a result,
                                                  only 33 of the 188 total number of air toxics
                                                  have received more in-depth study.
Pollution from an industrial smokestack (photo courtesy
New York State Department of Environmental Conservation).
                                     EPA could also improve its current air
                                     toxics performance measure by including
                                     toxicity information along with tonnage
                                     measures.  Currently, EPA aggregates the
tonnage reductions of emissions for all 188 toxic air pollutants, but does not provide
specific measurement information on those pollutants that are most dangerous to human
health and, thus, would be of most interest to EPA, Congress, and the public.

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We recommended that EPA improve the accuracy, reliability, and usefulness of its
current air toxics performance measure by (1) promulgating air toxics reporting
requirements, (2) requiring State and local agencies to periodically report validated
emissions data, and (3) providing increased funding and support for developing more
accurate emissions factors and activity data for the National Toxics Inventory.  We also
recommended that EPA supplement the existing tonnage measure with specific measures
regarding health risks. EPA generally agreed with our recommendations, although the
Agency did not agree to use the more reliable 1996 National Toxics Inventory as the
baseline rather than the 1993 inventory.  However, we maintain that the 1996 inventory
would be a more reliable baseline measure of EPA's progress in reducing air toxics
emissions.

(Report No. 2004-P-00012, EPA 's Method for Calculating Air Toxics Emissions for
Reporting Results Needs Improvement, March 31, 2004)
Fort Worth Asbestos Demolition Method
Needs Significant Modifications

The current design and methodology of the "Fort Worth Method" for removing regulated
asbestos-containing materials during demolition is not adequate to demonstrate
protection of human health and the environment, and does not meet applicable EPA
criteria.  Asbestos is a known human carcinogen.
                                                 The City of Fort Worth, Texas,
                                                 has proposed an alternative
                                                 method - under EPA's Project
                                                 XL - for demolishing selected
                                                 structures with regulated
                                                 asbestos-containing
                                                 materials. EPA's Project XL is
                                                 a national initiative that
                                                 encourages testing of alternative
                                                 ways to achieve environmental
                                                 results, as long as those results
                                                 are superior to those achieved
                                                 under current regulations.
                                                 In general, the "Fort Worth
                                                 Method" calls for thoroughly
                                                 wetting a structure with a fire
hose while it is demolished using a bulldozer or back hoe, but does  not call for removing
all the regulated asbestos-containing material prior to demolition. Phase I testing
involved demolishing a single family dwelling in 2001.  The planned Phase II calls for
demolishing an abandoned hotel, and Phase III would involve multiple demolitions.
Since other cities have shown interest in the Forth Worth Method, it has national policy
implications that could be precedent-setting.
A Fort Worth Method Phase I demolition project (EPA photo).

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We concluded that the current design and methodology of the Fort Worth Method is not
adequate.  Significant modifications will be necessary to ensure that the data generated
and used to evaluate this project will be valid. For example, the description of the Fort
Worth Method does not identify the key factors or variables that could be encountered
during demolition, or how the materials would be handled or treated to minimize
potential exposures. We also had concern about the appropriateness and effectiveness of
Fort Worth's proposed ambient air monitoring during demolition activities.

We also found that the Fort Worth Method does not yet meet EPA's Project XL criteria
of superior environmental performance, appropriate regulatory flexibility, adequate
stakeholder involvement, or transferability. Thirteen of the 15 external stakeholder
groups we interviewed indicated they did not think the method was equivalent or
superior to the Asbestos National  Emission Standard for Hazardous Air Pollutants. EPA
has yet to make such a determination, and we found that EPA's oversight to date has not
ensured that the Phase II proposal will allow the Agency to reach valid conclusions on
the effectiveness of this method.

We made recommendations for EPA to assist Fort Worth in modifying the method, work
with the City to develop a Final Project Agreement and ensure that Project XL team
concerns are adequately addressed, and develop guidance for conducting oversight.
Although EPA did not concur with all our conclusions, it agreed to implement the
majority of our recommendations, and has already taken some actions that we considered
beneficial.

(Report No. 2004-P-00002, Significant Modifications Needed to Ensure Success of
Fort Worth Asbestos Demolition Method, December 19,  2003)

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Ensuring that drinking water is safe and sources are protected.
             EPA Incorrectly Reported  Meeting
             Drinking Water Goal

             In each of the past 4 years, EPA incorrectly reported meeting its drinking water goal
             under the Government Performance and Results Act, because it had concurrently
             reported that the data used to draw those conclusions were flawed and incomplete.

             For fiscal years 1999 through 2002, EPA reported for each year that it had just met its
             annual performance goal of having 91 percent of the population served by community
             drinking water systems receive drinking water meeting all health-based standards.
             However, the Agency did not in fact meet its goals. This was because both EPA and
             Office of Inspector General (OIG) reviews indicated that performance was less than what
             was reported, due to missing data in EPA's Safe Drinking Water Information System on
             violations of drinking water standards.

             For example, while EPA's 2002 Annual Performance Report stated EPA met the
             91-percent goal, it also indicated that under reporting to EPA of monitoring and
             reporting violations was a
             significant data quality problem
             that limited the accuracy of its
             data (see box). EPA's 2003 Draft
             Report on the Environment noted,
             "the Agency estimated that states
            were not reporting 40 percent of
            all health-based violations to
            EPA."
The most significant data quality problem is under
reporting to EPA of both monitoring and reporting
violations and incomplete inventory characteristics
. . ..  Such under reporting of violations limits EPA's
ability to precisely quantify the population served that
are meeting health based standards.
               - 2002 Annual Performance Report
            Therefore, we believe EPA has not accurately reported its performance to the
            approximately 268 million people who drink water from community water systems.
            While we must note that this inaccuracy in reporting does not necessarily indicate a
            direct or immediate threat to human health, it is important to provide Congress and the
            public with accurate information.

            We have made suggestions to EPA that it change how it reports under the Government
            Performance and Results Act to compensate for known concerns over the reliability of
            this measure, but the Agency has not indicated how it will change its reporting.
            (Report No. 2004-P-00008, EPA Claims to Meet Drinking Water Goals Despite
            Persistent Data Quality Shortcomings, March 5, 2004)

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Improvements Needed in Reporting Industrial
Releases to Wastewater Treatment Facilities

EPA needs to improve its data quality reviews to better identify potential misreporting to
its Toxics Release Inventory System, so that industrial users can more accurately report
the amount of pollutants they release to wastewater treatment facilities.

The Toxics Release Inventory System is a database that contains the information
submitted by facilities related to the release to wastewater treatment facilities of more
than 600 chemicals. However, while conducting a review of the EPA's pretreatment
program, we identified errors in industrial user reporting.

In seven cases, industrial users incorrectly reported transfers of copper, lead, chromium,
and silver to private recovery or recycling companies as transfers to publicly owned
treatment works, resulting in EPA reports on transfers to wastewater treatment facilities
being overstated by 1,165,258 pounds. While the number of errors noted was relatively
small, those errors made a significant impact on determining trends  in transfers to
publicly owned treatment works.

Additionally, EPA's Toxics Release Inventory Explorer database did not specifically
identify metals transferred to wastewater treatment facilities.  Such a category would
enable the public to better know what is being transferred to a local  wastewater facility,
and would assist EPA program staff conducting various evaluations.

According to EPA, Federal, State, and local governments have used the Toxics Release
Inventory System to set priorities, measure progress, and target areas of special and
immediate concern. Also, the public has used the Toxics Release Inventory data to
understand their local environment and to participate in debates of concern. Therefore,
it is important to have accurate and clearly described data for use by both the  public and
government agencies.

We recommended that EPA provide a schedule for obtaining corrected forms and make
Toxics  Release Inventory System improvements. EPA generally agreed with our
recommendations, and has already taken action to identify metals transferred  in its
Explorer database.

(Report No. 2004-P-00004, EPA Should Take Steps to Improve Industrial Reporting to
the Toxics Release Inventory System, February 2, 2004)

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Improving waste management and cleanup - includes Superfund.
            Hardrock Mining  Sites Pose Significant Challenges
            for Superfund Program

            Hardrock mining sites identified nationwide may have significant financial impacts on
            the Superfund Trust fund and on States.  Most of the sites will require decades to clean
            up, and the ability of the Superfund program, States, or responsible parties to pay for
            generations of sustained cleanup activities needed for many mining sites is questionable.
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                                                       Hardrock mining, which is not coal
                                                       mining, involves the extraction of
                                                       certain metals and minerals from the
                                                       earth, including copper, gold, iron ore,
                                                       lead, and silver.  Hardrock mining can
                                                       cause significant adverse impacts on
                                                       the environment.  EPA has reported
                                                       that the metal mining industry was the
                                                       largest toxic polluter in 2000, releasing
                                                       3.4 billion pounds of toxics, or
                                                       47 percent of the total released by
                                                       U.S. industry.

                                                       Our review identified 156 hardrock
                                                       mining sites nationwide that have the
                                                       potential to cost between $7 billion and
                                                       $24 billion to clean up (at a maximum
            total EPA cost of $15 billion). These costs are over 12 times EPA's total annual
            Superfund budget of about $1.2 billion for the last 5 years. This suggests potential
            difficulties for the Superfund program. Following are some observations:

            •    There is some uncertainty regarding the human health and environmental risks
                associated with National Priorities List sites and sites in the Superfund database.
                For example, some National Priorities List sites had an unknown current human
                health risk, while Non-National Priorities List sites had current medium or high
                human health risks.  Similarly, half of the National Priorities List mining sites have
                current high or medium environmental risks, while nearly two thirds of the
                Non-National Priorities List mining sites in the Superfund data base have current
                high or medium environmental risks. Agency officials indicated that future risks
                may sometimes be greater than current risks based on land use decisions.

            •    Although at least one potentially responsible party has been identified at 83 percent
                of the hardrock mining sites, there are uncertainties regarding how many will have
                the ability to pay for lengthy cleanup actions.

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    For long-term remedial actions
    financed by Superfund, EPA
    performs these actions for the first
    10 years with the State paying
    10 percent of costs, after which
    responsibility is turned over to
    the State. This can have significant
    impacts on States.

    Hardrock mining sites are not
    proportionately distributed
    throughout the country - more
    than 70 percent of the sites are
    located in four EPA Regions (4, 8,
    9, and 10). These Regions may
    have greater needs for resources.
    Additional Superfund Reviews
< In response to a Congressional request,
  we issued a report on the fiscal 2003
  funding for non-Federal Superfund sites
  (see page 34).
< We reviewed grants related to Superfund
  cleanups in Idaho and New Mexico
  (see pages 17 and 18, respectively).
< A review of complaints regarding the
  Bunker Hill Superfund site found EPA
  actions to generally be appropriate
  (see page 31).
< A subcontractor entered into a settlement
  related to cleanup at  a Superfund site in
  Lock Haven, Pennsylvania (see page 24).
We recommended that EPA report on the long-term sustainability and liability of
businesses involved in hardrock mining operations, the type of remediation technologies
currently available, and promising new technologies.  We also recommended continued
support for improving EPA's National Hardrock Mining Framework, and the prioritizing
of efforts based on human health and environmental risks. The Agency agreed with our
recommendations and proposed several actions.

(Report No. 2004-P-00005, National Identification of Hardrock Mining Sites, March 31,
2004)
EPA  Response to  Petition Against
Idaho  Program Supported

Our review of EPA Region 10's response to a petition seeking withdrawal of
authorization for Idaho's Hazardous Waste Program found that the Region supported its
positions on most of the allegations. However, we found several areas of concern.

EPA in 1990 had authorized the Idaho Department of Environmental Quality to manage
the State's Hazardous Waste Program, as authorized by the Resource Conservation and
Recovery Act. A petition filed with EPA by two environmental groups and a citizen
alleged that the State had failed to administer environmental laws at the U.S. Department
of Energy's Idaho National Environmental and Engineering Laboratory in southeastern
Idaho.  The site's current mission is to perform research, hazardous and radioactive
waste management, environmental cleanup, and environmental technology development;
nuclear reactors were originally prototyped on the site.

We found that Region 10 generally supported its positions on most of the allegations
with appropriate criteria and documentation and, consequently, did not withdraw
authorization from Idaho. However, we found several areas of concern, resulting in there

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being less assurance that hazardous waste was managed in a safe manner and in
accordance with law.  Specifically:

•   A date for submitting information to correct deficiencies in an application for the
    New Waste Calcining Facility Calciner (used to convert liquid radioactive waste into
    a dry substance) was not established until 1997 even though permit deficiencies were
    identified in 1991. No further action is required, since the unit is currently
    undergoing closure, but our finding
    supports petitioners' concerns on
    Idaho's failure to exercise control in
    requiring permits.
    A date for submitting information to
    address unresolved permit application
    deficiencies for the High Level Liquid
    Waste Evaporator (used to concentrate
    and reduce liquid radioactive wastes)
    also was not established as required
    by EPA regulation. Further, followup
    actions to obtain a complete permit
    application for the Evaporator were
    not taken until almost 8 years after a
    notice of deficiency was issued to
    the Department of Energy.
Smoke drifts from the stack of the calciner at the
Idaho National Environmental and Engineering
Laboratory (photo courtesy of Laboratory).
•   Data had not been collected to determine whether the Process Equipment Waste
    Evaporator - also used to concentrate and reduce liquid radioactive wastes - and
    associated tank systems were in compliance with emission standards.

We made recommendations for EPA Region 10 to require Idaho to timely address and
resolve Research Conservation and Recovery Act permit application deficiencies, and
evaluate compliance with emissions standards.  EPA Region 10 agreed with our
recommendations.

(Report No. 2004-P-00006, Review of EPA 's Response to Petition Seeking Withdrawal
of Authorization for Idaho's Hazardous Waste Program, February 5, 2004)
Office of Underground  Storage Tanks
Inadequately Managed  Contracts

Our review of a hotline complaint found that EPA's Office of Underground Storage
Tanks had inappropriately used and inefficiently managed contract funds.

EPA's Office of Underground Storage Tanks, which administers cleanup efforts related
to leaking underground storage tanks, uses two primary contracts to perform its mission.
In 1999, the Office awarded a contract to ICF, Incorporated, with a potential maximum
value of $5.4 million. In 2001, the Office issued another contract, this time to the Bristol
                               10

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Environmental Engineering & Services Corporation, with a maximum potential value of
$11.1 million.  The latter contract specifically involves remediation efforts in Indian
Country.

For these two contracts, which the hotline complaint specifically requested we review,
we found that the Office did not always identify the correct appropriations to be charged
when ordering  and paying for work.  The Office used $218,000 in funds from the
Leaking Underground Storage Tank appropriation when funds from the Environmental
Program Management appropriation should have been used.

We also found  that the  Office obligated money to contracts but did not order a
commensurate  amount  of work.  The Office allowed approximately $330,000 in funds to
expire because it did not order work from contractors during the life of the appropriation.
We also found  that the  Office risks losing $483,648 in unliquidated obligations related to
the practice of  "parking" funds on contracts (obligating funds to contracts although no
corresponding work has been identified).

Further, based on our limited review of the Office's performance measures, we are
concerned that measures are not transparent (readily understandable) and meaningful.
In March 2003, the Office changed the definition of "Cleanup Completed" and "Cleanup
Initiated" to include sites where  an evaluation determines no cleanup is  needed, yet its
performance reports do not explain this.  We believe the definitions should be provided
in performance reports.

In response to our findings,  the Office of Underground Storage Tanks has taken or plans
to take actions that should address our concerns. These actions involve better linking
appropriations to work  assignments, and better managing funds to prevent their
expiration. Further, the Office indicated that EPA has initiated various actions to
adequately use all contract funds available and plans to receive additional training in
contract administration. Finally, the Office indicated it has posted performance
measurement definitions on its web site and will link the definitions to future
performance reports.

(Report No. 2004-P-00014,  The  Office of Underground Storage Tanks:  Contract
Administration and Performance Measurement Concerns, March 31, 2004)
Immediate Action Needed for  Identifying
Hazardous Waste Sites  in Indian Country

In connection with our ongoing evaluation of EPA activities to enhance the role of Indian
tribes in the Superfund program, we noted immediate actions were needed to address
weaknesses in the Agency's development of an inventory of hazardous waste sites in
Indian Country.

In 1999, the Agency started its development of an inventory of hazardous waste sites on
Indian land, and provided funding to the Tribal Association on Solid Waste and
                               11

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Emergency Response (TASWER) to provide EPA with necessary tribal input. Our
review of EPA's efforts to develop an inventory disclosed some serious shortcomings:

•    Project mismanagement issues associated with TASWER caused substantial delays.
•    EPA had not fully defined the inventory-related information needed.
•    TASWER's methodology for obtaining tribal input had serious limitations.
•    EPA had not developed a detailed plan for validating, managing, storing, or updating
    the baseline inventory.

We believe that these shortcomings, if not substantially revised, will prevent a credible
and reliable inventory from being produced.  Moreover, without significant
modifications, EPA will be required to make an additional investment in this effort.
                                                Because TASWER's contractor
                                                was just beginning its tribal input
                                                activities in July 2003, we issued a
                                                "flash" memorandum to the
                                                Agency advising it of the need to
                                                take immediate actions to address
                                                the weaknesses in the inventory
                                                development effort.
                                                We recommended that EPA
                                                provide more oversight to
                                                TASWER; define specific program
                                                information needs; review the
                                                inventory methodology and address
                                                key limitations; and develop a
                                                detailed plan for validating,
                                                managing, storing, and updating
                                                the baseline inventory. EPA
                                                generally indicated our
recommendations were appropriate, but it needs to provide details on how it will
implement our recommendations.

(Report No. 2004-P-00003, Immediate Action Needed to Address Weaknesses in
EPA Efforts to Identify Hazardous Waste Sites in Indian Country, January 30, 2004)
The Upper Columbia River, a hazardous waste site impacting the
Confederated Tribes of the Colville Reservation (EPA OIG photo).
                                12

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Cross-Media
Issues involving overlapping areas - includes homeland security.


             EPA Not Consistently  Implementing
             Environmental Justice
            EPA has not fully implemented Executive Order 12898 to provide environmental justice
            for minority and low income populations, nor has it consistently integrated
            environmental justice into its day-to-day operations.

            In 1994, President Clinton issued Executive Order 12898, "Federal Action to Address
            Environmental Justice in Minority Populations and Low Income Populations," to ensure
            such populations are not subjected to a disproportionately high level of environmental
            risk.

            Although EPA has been involved in implementing the Executive Order for 10 years, the
            Agency has not identified minority and low income populations or sufficiently defined
            "disproportionately impacted." EPA has not developed a clear vision or a
                                                          comprehensive strategic plan, and
                                                          has not established values, goals,
                                                          expectations, and performance
                                                          measures for environmental justice.
                                                          We did note  that the Agency made
                                                          an attempt to issue an
                                                          environmental justice toolkit,
                                                          endorsed environmental justice
                                                          training, and required that all
                                                          regional and programmatic offices
                                                          submit "Action Plans."
          Citation from Executive Order 12898
To the greatest extent practicable and permitted by law and
consistent with the principles set forth in the report on the
National Performance Review, each Federal agency shall make
achieving environmental justice part of its mission by identifying
and addressing, as appropriate, disproportionately high and
adverse human health or environmental effects of its programs,
policies and activities on minority populations and low-income
populations in the United States.... (Section 1-101)
            In the absence of environmental justice definitions, criteria, or standards from the
            Agency, many regional and program offices implemented environmental justice policies
            on their own. This has resulted in inconsistent approaches, and environmental justice is
            dependent not only on minority and income status but also on the EPA region in which
            the person resides. Our comparison of how environmental justice protocols used by
            three different regions would apply to the same city resulted in a disparity in what EPA
            would designate as a protected population.

            Moreover, in 2001, the Agency restated its commitment to environmental justice in a
            manner that does not emphasize minority and low income populations, which is the
            stated intent of the Executive Order.

            We recommended that EPA issue a memorandum reaffirming that Executive  Order
            12898 is an Agency priority. We made other recommendations regarding definitions,
                                           13

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goals, measurements, vision, approaches, training, and a comprehensive strategic plan
for environmental justice.  The Agency disagreed with our position, and believes it is
sufficiently implementing the Executive Order.

(Report No. 2004-P-00007, EPA Needs to Consistently Implement the Intent of the
Executive Order on EnvironmentalJustice, March 1, 2004)
Survey  on Water Infrastructure Security
Notes Ways to Improve Vulnerability Assessments

Recent terrorist activities and other incidents, such as the blackout in the midwest and
northeast United States, demonstrated the crucial role of the water sector infrastructure
in the health and economic well-being of the Nation. A survey on water security issues
conducted at our suggestion by the Domestic Working Group - an informal group of
local, State, and Federal auditors - disclosed how various water utilities performed
vulnerability assessments.
We noted five key security activities critiqued
 ,     ,  ,    11-1-                    /           Five Key Security Activities
through the vulnerability assessment process (see
box).  A variety of sources provided useful
information to help water utilities prepare
vulnerability assessments. Utilities most
Threat Identification
Detection
Delay
Response and Consequence
Remote Access
frequently cited consultants hired to assist in the
preparation of vulnerability assessments
as sources that provided useful information.  This
suggests a possible disadvantage to smaller
utilities, which are required to complete vulnerability assessments by June 2004 but,
unlike larger utilities, may not be able to afford a consultant.

All utilities surveyed had additional concerns and research needs. The utilities indicated
that they still needed additional information regarding potential types of vulnerabilities
that might exist. Further, utilities stated they needed financial assistance to make
necessary security improvements, as well as  training, research, and procedural changes.
We noted in a prior report that  EPA could use performance indicators to measure
improvements in water security levels, and EPA officials agreed such indicators could be
beneficial.  Utilities provided input concerning indicators that EPA could use to measure
changes in water security.

Based on our survey results and observations, we suggested that EPA ensure that small
utilities have access to information gathered  by consultants at larger utilities, ensure that
water utilities have access to information on  funding security enhancements, and
consider using performance indicators.

(Report No. 2004-M-0001, Survey Results on Information Used by Water Utilities to
Conduct Vulnerability Assessments, January 20, 2004)
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EPA Needs to Better Define  Homeland Security Role
Regarding Air

EPA's Office of Homeland Security does not have a framework in place to carry out its
responsibilities as designated by the Administrator. We acknowledge that this Office
was recently created, but want to stress the importance of clarifying EPA's future roles
and responsibilities in this area.

In particular, we found that some of EPA's homeland security roles and responsibilities
related to air protection were limited and not well defined to enable  EPA to be prepared
for future events.  To have a more coordinated, comprehensive approach to homeland
security, EPA's Office of Homeland Security should first identify EPA's delegated
homeland security responsibilities, and then track and oversee these efforts.
Coordinating efforts amongst the various EPA offices, as well as with other agencies,
is critical in order for success to be achieved.

We recommended that EPA's Office of Homeland Security clarify EPA's future roles
and responsibilities in homeland security to enable it to properly prioritize and commit
resources to its traditional and homeland security missions, and establish and maintain
a database to oversee and track the progress for all EPA homeland security efforts.  EPA
generally agreed with our recommendations, although the Agency needs to be more
specific on how it plans to carry out the recommendations.

(Report No. 2004-M-00005, EPA's Homeland Security Role to Protect Air from Terrorist
Threats Needs to be Better Defined, February 20, 2004)
                        Additional Reviews Addressed
                           Homeland Security Issues

                     < We found that EPA needs to improve
                       management of counter terrorism/
                       emergency response equipment
                       (see page 19).
                     < In response to a Congressional request,
                       we provided Congress with details on
                       various enforcement issues, including
                       new EPA duties related to homeland
                       security (see  page 35).
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Grants
Improving EPA's use of assistance agreements.
                                                 Recent testimony by an EPA Assistant Inspector
                                                 General before several Congressional
                                                 committees addressed a number of issues
                                                 involving assistance agreements, including the
                                                 inappropriate funding awarded to the Consumer
                                                 Federation of America. See page 36.
Lobbying Organization Inappropriately
Received Federal  Funds

The Consumer Federation of America, a Washington-based lobbying group, effectively
received Federal funds under EPA cooperative agreements in violation of the Lobbying
Disclosure Act of 1995.  Consequently, we questioned $4.7 million in funds provided.

Although EPA awarded five cooperative agreements to the Consumer Federation of
America Foundation based on  applications that showed labor and other operating costs,
the Foundation did not have any employees, space, or overhead expenses. Instead, the
Consumer Federation of America
itself, a lobbying organization
described under section 501(c)(4) of
the Internal Revenue Code,
effectively received the EPA funds
and performed the work.
The Lobbying Disclosure Act
prohibits 501(c)(4) lobbying
organizations from receiving
Federal funds under such grants.

Further, our examination disclosed that the financial management system used to account
for the Federal funds was not in compliance with the Code of Federal Regulations, the
procurement standards required by those regulations were not always followed, and sub-
grants were not administered in accordance with the regulations.

We also have serious concerns about the role EPA may have had in the award and
oversight of the subject cooperative agreements.  In its response to the draft report, the
Federation alleged that EPA asked the Federation to manage a program on indoor air
quality and to manage a national public service campaign to educate consumers about
health risks of radon.  Both awards were initiated by EPA, and EPA determined the need
and the scope of both programs.

We recommended that EPA annul the five subject cooperative agreements and recover
all funds paid to the recipient.  We also recommended that EPA suspend work under
current grants or cooperative agreements not covered by this audit, and make no new
awards until the recipient can demonstrate that its financial management practices and
controls over Federal funds comply with all regulatory requirements. Further, we
recommended that EPA require the recipient to prepare and submit performance reports
for current grants or cooperative agreements.

(Report No. 2004-4-00014, Consumer Federation of America Foundation -
Costs Claimed Under EPA Cooperative Agreements CX825612-01, CX825837-01,
X828814-01, CX824939-01, and X829178-01, March 1, 2004)
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            Grant for Basin Cleanup Coalition Found to Be
            Inappropriate, Subsequently Terminated

            Based on our review of a hotline complaint, we found that a technical assistance grant
            was inappropriately awarded to the Basin Cleanup Coalition in Coeur d'Alene, Idaho.
            Subsequently, as a result of our review, EPA terminated the grant, which would have
            totaled $50,000 in Federal funds.
Details on our review of other
complaints regarding cleanup efforts
in the Coeur d'Alene area are on
page 31.
We found that the Coalition was not a qualified grant
recipient because of potential conflicts of interest and
because it did not meet administrative and management
capability requirements.  Specifically, based on our review
of the complainant's allegations, we found that:
            •    The Coalition did not have a sufficient membership to have a Board of Directors
               and, as a result, was unable to enter into contracts to hire a technical advisor as
               required under the grant.

            •    The Coalition was not eligible as a technical assistance grant recipient because it did
               not obtain tax exempt status.

            •    While we could not confirm the allegation as to whether the Coalition was the
               "creation" of the Coeur d'Alene Chamber of Commerce, the Coalition and the
               Chamber did have common characteristics. The Coalition incorporator was also the
               President and General Manager of the Chamber, which we considered a conflict of
               interest, and the Coalition and Chamber shared the same address.  Further, it was the
               intent of the Coalition to enter into a contract with the Chamber that would have
               enabled the Chamber to act as the grant administrator, in spite of EPA's notification
               that such  an arrangement was prohibited.

            As a result of our meeting with EPA's Region 10 regarding these issues, the Region
            notified the Coalition on December 5, 2003, that the grant was being terminated.  This
            resulted in $50,000 in Federal funds being put to better use, as well as the resolution of
            an improper award. Further, the Region agreed with our recommendation to improve
            post award procedures.

            (Report No. 2004-P-00010, Review of Hotline Complaint Regarding Technical
            Assistance Grant No.  1-97025201 Awarded to the Basin Cleanup Coalition, Coeur
            d'Alene, Idaho, March 25, 2004)
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Financial Statements for New Mexico Grant Generally
Accurate,  But $11,558  in Costs Questioned

             An examination of total outlays reported by the New Mexico Environment Department
             under an EPA cooperative agreement related to Superfund efforts indicated financial
             statements were generally accurate, although we noted $11,558 in questioned costs.

             Of $2,919,206 in cumulative total outlays claimed under Cooperative Agreement
             V986338-01, we found that the State did not fully match its 10-percent cost sharing
             requirements for its core program activities under the agreement, resulting in an $11,558
             overdraw of Federal funds.  The State agreed with our recommendation that EPA recover
             that amount. The State also did not report $29,239 of its State match.

             The agreement was authorized under the Comprehensive Environmental Response,
             Compensation, and Liability Act to provide financial support for various Superfund
             activities, including: pre-remedial activities; EPA-lead management assistance activities;
             State-lead activities for Fruit Avenue and North Railroad Avenue plume sites; voluntary
             remediation activities; and various core program activities, such as administrative and
             legal services.

             (Report No. 2004-4-00012, New Mexico Environment Department Costs Claimed Under
             Cooperative Agreement No. V986338-01, March 31, 2004)
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Contracts
Improving EPA's use of contracts.
            EPA Needs to Improve Management of
            Counter Terrorism/Emergency Response Equipment

            EPA does not have adequate processes for identifying, obtaining, maintaining, and
            tracking equipment needed to respond to terrorist attacks and Nationally Significant
            Incidents (events that may exceed the resources of a single EPA region).

            Our review disclosed that EPA leadership did not move expeditiously to develop
            sufficient EPA capability and capacity to respond to the consequences of multiple major
            terrorist acts or Nationally Significant Incidents.  Specifically:

            •    EPA took 12 months to identify salient characteristics (the key performance
               characteristics needed to actually purchase the items) for 11 of 13 categories of
               counter terrorism/emergency response equipment, and had still not obtained almost
               40 percent of the items. Further, for more than a year, EPA paid for warehouse
               space for equipment not yet obtained.

            •    EPA's older counter terrorism/emergency response equipment on hand has been
               poorly maintained, and maintenance records were sometimes inaccurate.

            •    EPA does not have a national system for tracking counter terrorism/emergency
               response equipment.

            We did note that EPA complied with the Federal Acquisition Regulation when
            purchasing counter terrorism/emergency response equipment, and has an adequate
            process for moving equipment.
                                                       The deficiencies noted occurred
                                                       because EPA did not develop a
                                                       coordinated plan with aggressive
                                                       milestones and points of
                                                       accountability for identifying,
                                                       obtaining, maintaining, and tracking
                                                       this equipment. As a result, EPA's
                                                       ability to  protect the public health
                                                       and the environment in the event of
                                                       future terrorist attacks and
                                                       Nationally Significant Incidents may
                                                       be impaired. Also, since the Agency
                                                       had obligated almost $3.7 million for
                                                       warehouse space before significant
Emergency Response Demonstration Exercise held in Portland,
Oregon, using counter terrorism/emergency response equipment
(EPA OIG photo).
                                          19

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quantities of equipment were delivered, a portion of that amount was needlessly
obligated.

We recommended that EPA develop a plan with aggressive milestones and points of
accountability, for identifying, obtaining, maintaining, and tracking counter
terrorism/emergency response equipment. EPA generally agreed with our
recommendations.

(Report No. 2004-P-00011, EPA Needs to Better Manage Counter Terrorism/Emergency
Response Equipment, March 29, 2004)
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 Financial  Reporting
Improving the Agency's financial reporting.
            EPA  Earns Unqualified  Opinion on
            Financial  Statements

            EPA earned an unqualified opinion on its fiscal 2003 financial statements. Further, we
            did not note any material weaknesses in internal controls or compliance during our
            review.

            During our review, we noted that the Superfund Trust Fund, managed by the
            U.S. Treasury Bureau of Public Debt, transferred funds to EPA in excess of the assets
            available to be transferred by $82.7 million in fiscal 2003.  This occurred because the
            fund had decreased over several years and because of unanticipated tax refunds. The
            $82.7 million shortfall was subsequently covered by fiscal 2004 appropriations from the
            Treasury's general fund.

            In evaluating EPA's internal controls, we identified eight reportable conditions.
            Although we do not believe they represent material weaknesses that would prevent the
            fair presentation of reliable financial statement amounts, they are internal weaknesses
            that still should be corrected. The eight reportable conditions were as follows:

            •    EPA did not always adequately document standard vouchers for transfer requests
                from Treasury to EPA Trust Fund accounts (Superfund and Leaking Underground
                Storage Tank Trust Funds) prior to transactions being entered into the Integrated
                Financial Management System.

            •    EPA project officers regularly approved invoices without the detailed documentation
                to support costs.

            •    EPA did not reconcile the unearned revenue from State Superfund Contracts to the
                general ledger, and therefore could not ensure the accuracy of the approximately
                $29 million recorded for that account.

            •    EPA did not promptly record approximately $2 million in marketable securities
                received  in fiscal 2003 from companies in settlement of debts.

            •    The Integrated Financial Management System suspense file was not in compliance
                with the requirement that the Application Program Interface provide internal
                controls, such as control totals and record counts, to ensure integrity.

            •    Due to system shortcomings, we continued to be unable to assess the adequacy of the
                automated internal control structure as it relates to automated input, processing, and
                output controls for the Integrated Financial Management System.
                                           21

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•    For accounts receivable, we noted numerousinstances where receivables were not
    recorded timely due to late submission of supporting documentation from
    Department of Justice, Regional Counsel, or program offices. Further, one regional
    financial management office did not properly calculate its allowance for doubtful
    accounts.

•    EPA's Financial Systems Branch bypassed the Integrated Financial Management
    System manual online data entry controls when making a systemic correction of
    erroneous transactions; instead of using the journal voucher process, it reversed
    transactions by processing negative debts and positive credits. As a result, the audit
    trail for these transactions was hidden and basic evidence requirements for the
    transactions were circumvented.

Our tests of compliance with laws and regulations did not identify any instances of
noncompliance with laws and regulations that would materially misstate the financial
statements. However, we identified three noncompliances under the Federal Financial
Management Improvement Act.  Although EPA made significant improvements
regarding cost accounting, EPA was not in compliance with the Statement of Federal
Financial Accounting Standards No. 4 that requires EPA to provide full costs per output
to management in a timely fashion. Further, we noted noncompliances related to
reconciliation of intragovernmental transactions and completion of the fiscal 1999
remediation plan. None of these noncompliances met the Office of Management and
Budget's definition of substantial noncompliance.

In its response to our draft report, the Office of the Chief Financial Officer generally
concurred with our recommendations and noted the completion or planning of a number
of corrective actions. Regarding our concerns related to the Superfund Trust Fund
shortfall and the decline in cost recoveries, the Office of the Chief Financial Officer
indicated the Superfund program will continue to operate as long as Congress continues
to appropriate funds for it, and noted that EPA's fiscal 2003 appropriation came from
Trust Fund assets and the general fund.

(Report No. 2004-1-00021, Audit of EPA 's Fiscal 2003 and 2002 Financial Statements,
November 21, 2003)
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 Business Systems
Improving the Agency's information technology.
            EPA Needs to Improve Administration  of
            Computer Network Firewalls

            While the Office of Environmental Information has taken positive actions to properly
            implement EPA's computer system firewalls, additional areas need to be addressed to
            provide greater assurance that the Agency's information resources are adequately
            secured.

            EPA uses "firewall" technology, in combination with other network security devices, as
            the foundation to secure information resources. EPA's "physical" security practices  for
            the firewalls, which include continuity of operations practices and procedures, were
            adequate. However, logical and configuration improvements are needed. Specifically:

            •    Several of the workstations used to remotely administer EPA's firewall need to  be
               configured to maximize network security.
            •    EPA's firewall enforcement point servers (i.e., Public Access and Agency) need to
               be properly maintained to prevent malicious attacks on the network.

            As a result, hackers could circumvent EPA's network security, allowing them the
            potential to negatively affect integrity, confidentiality, and availability of EPA systems
            and data on the network.
            These weaknesses occurred
            because of problems related
                            Firewall Weaknesses occurred because:
                                          EPA management had not established a standard
                                          configuration requirement for workstations used to
                                          remotely administer firewalls.
                                          The firewall change and patch management process
                                          does not define a procedure to ensure that when
                                          changes or patches are applied they do not adversely
                                          affect previously applied fixes.
                                          EPA relied on an ineffective methodology for scanning
                                          the National Computer Center's network infrastructure.
to remote administration,
the change and patch
management process,
and scanning methodology
(see box).

To provide greater
assurance that information
resources are adequately
secured, we recommended
several improvements assigned to firewall components. These include establishing a
standard configuration requirement related to remote administration, modifying the
change and patch management processes, and modifying the network vulnerability
assessment methodology regarding scanning of all firewall components.  EPA agreed to
take appropriate corrective actions.

(Report No. 2004-P-00013, EPA 's Administration of Network Firewalls Needs
Improvement, March 31, 2004)
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  Investigations
  Investigating laboratory fraud, financial fraud, and computer crimes.
Laboratory Fraud
                 Laboratory President Suspended
                 On November 18, 2003, EPA's Debarring Official issued a Notice of Suspension to
                 Edward V. Kellogg, President and Quality Control Manager of Johnson
                 Laboratories, Inc., New Cumberland, Pennsylvania.  This suspension notice was
                 issued as a result of a May 2003 indictment in U.S. District Court, Eastern District of
                 Pennsylvania, for 34 counts of mail fraud.

                 The indictment alleged that from May 1998 through July 2000, Kellogg engaged in a
                 scheme to defraud Johnson Laboratories' customers  by creating and billing
                 customers for false and fraudulent environmental test reports.  Johnson Laboratories
                 provided analytical testing services to the EPA at the Bruin Lagoon Superfund Site
                 in Bruin, Pennsylvania, as well as to commercial clients. The Notice of Suspension
                 is a temporary action pending completion of the investigation and any legal
                 proceedings that may ensue.

                 This investigation is being conducted jointly with the EPA Criminal Investigation
                 Division, the U.S. Army Criminal Investigation Command, and the Pennsylvania
                 Attorney General's Office.
                 Subcontractor Agrees to $260,605 Settlement

                 The government, through its prime contractor, entered into a contractual settlement
                 with Environmental Chemical Corporation (ECC), Cincinnati, Ohio, resulting in a
                 savings to the government of $260,605.  ECC was a subcontractor that provided
                 laboratory testing services for an EPA-funded, U.S. Army Corps of Engineers
                 contract to perform cleanup work at the Drake Chemical Superfund Site in Lock
                 Haven, Pennsylvania.

                 During the course of the contract, it was determined that ECC was involved in
                 laboratory testing improprieties, such as not following its own established policies
                 and procedures for testing and false calibrations, which resulted in ECC losing its
                 Lab Validation and resulted in harm to the government.  The government and ECC,
                 through the prime contractor, agreed that if ECC would close out its subcontract and
                 not seek payment of $260,605 of previously billed but unpaid costs, the government
                 would consider that just compensation for the potential ECC fraud.

                 This case was conducted jointly with the U.S. Army Criminal Investigation
                 Command and the Defense Criminal Investigative Service.
                                           24

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Computer Crimes


                 Twelve  Plead  Guilty in Software Piracy Case

                 In December 2003, 12 defendants pleaded guilty before a U.S. District Court judge,
                 in the District of Nevada, to charges of conspiracy to commit copyright infringement.
                 The defendants were members of a computer software piracy group known as the
                 "Rogue Warriorz," a secretive underground group that illegally altered and
                 distributed copyrighted software, movies, and games over the Internet.

                 The defendants were among 21 persons indicted in June 2002, as part of "Operation
                 Bandwidth," a 2-year-long, multi-agency undercover operation, to identify and
                 prosecute entities and individuals involved with illegal access to computer systems
                 and piracy of proprietary software utilizing storage sites in the Internet. At least
                 18 group members were hackers who had illegally accessed EPA computer systems
                 to further the reproduction and distribution scheme.

                 The defendants entered into a "group plea" to the charge of conspiracy to commit
                 copyright infringement and have agreed to pay full restitution to the victims of their
                 offense. The defendants have also agreed to surrender the unlawfully obtained
                 copyrighted works and all of the computer equipment they used to commit these
                 offenses.

                 Robert L. Maersch, who previously pleaded guilty to conspiracy to commit copyright
                 infringement, was sentenced on January  12, 2004, in the U.S. District Court, District
                 of Nevada, to 6 months of electronically monitored home detention and 4 years
                 probation.  In addition, he was ordered to pay a $5,000 fine and a $100 special
                 assessment. As part of his sentencing, Maersch was ordered to forfeit 595 computer
                 and computer-related items.
                     Network Penetration Laboratory Established

  In 2003, the Computer Crimes Directorate launched its Network Penetration Laboratory,
  providing tools and investigative expertise to support the EPA in meeting Federal Information
  Security Management Act standards. With its first series of tests of the Office of the Chief
  Financial Officer network, an accurate assessment of system security was obtained and the
  information was used by that office to improve its security.

  The Federal Information Security Management Act requires that network information security
  controls and techniques be periodically tested and evaluated to ensure that they are effectively
  implemented. Further, each government agency is required to perform an independent evaluation
  of the information security program and practices of that agency to determine the effectiveness of
  such programs and practices, including testing of the effectiveness of information security
  policies, procedures, and practices of a representative subset of the agency's information systems.
                                            25

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Daniel Withrow was sentenced in U.S. District Court, District of Nevada, on
February 27, 2004, and placed on 3 years probation and ordered to pay a $200
special assessment.  Withrow previously pleaded guilty to criminal infringement of a
copyright and interfering with government communication systems.

This investigation is being conducted jointly with the Federal Bureau of
Investigation and the Defense Criminal Investigative Service.
Former EPA Contract Employee Sentenced
for Possession of Child Pornography

On March 1, 2004, John Mirisola, a former contract employee working at the EPA
New England Regional Laboratory, Chelmsford, Massachusetts, pleaded guilty and
was sentenced in Middlesex Superior Court, Commonwealth of Massachusetts, for
possession of child pornography. Mirisola was sentenced to 2 years probation and
ordered to pay a $90 fee. Mirisola must register as a sex offender, undergo sex
offender evaluation and/or treatment, and have no unsupervised contact with
children under the age of 16.

While working at the EPA laboratory, Mirisola accessed various internet sites using
his government-owned computer and downloaded pornographic material. An
extensive computer forensic examination was conducted by the OIG Computer
Crimes Directorate that documented instances of Mirisola downloading
inappropriate material, including child pornography. Lockheed Martin, Mirisola's
employer, was notified of his activity and he was subsequently terminated.
Former Contract Employee Found Guilty  of
Unauthorized Access into EPA Computer

On February 5, 2004, Antoine Michael Perry was found guilty by a Federal jury in
U.S. District Court, District of Columbia, of unauthorized access to a computer
causing damage.  Perry is currently awaiting sentencing in this matter.

Perry was temporarily employed as a subcontractor to work as a computer systems
administrator at the EPA in Washington, D.C.  On September 24, 1999, Perry was
terminated from his position. During the following weekend, he connected on
multiple occasions, without authorization, to the EPA computer network through a
remote computer connection from his home. During these connections, Perry
intentionally deleted several programs that controlled the network's printers and
caused other unauthorized damage to the computer network. As a result of his
actions, the computer network had to be shut down for repair, which prevented the
EPA employees using that network from carrying out their responsibilities related to
the cleanup of environmentally contaminated sites around the country.

This case was conducted jointly with the Federal Bureau of Investigation.
                          26

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Financial Fraud
                 Impersonator Sentenced for Defrauding
                 Employment Agencies

                 On October 3, 2003, Steven Wayne Divine was sentenced in U.S. District Court,
                 Western District of Washington, to serve 33 months in prison, followed by 5 years of
                 probation, on charges related to defrauding employment agencies.  In addition,
                 Devine must pay $35,411 in restitution and a $1,200 special assessment.

                 Between October 1999 and May 2003, Divine devised a scheme to defraud
                 temporary employment agencies in Oregon and Washington State. Divine would
                 contact various agencies using a false name and identify himself as an upper level
                 employee of a company or government agency, including the EPA.  He would then
                 contract with the employment agency to "payroll" a purported employee of the
                 company or agency. For an agreed upon fee, the employment agency would handle
                 payroll issues and issue payroll checks to the purported employee, Divine. The
                 employment agencies would either mail an invoice to the company or government
                 agency to receive payment for their services or Divine would appear at the
                 employment agency and present a counterfeit check to pay for the agency's services.
                 Multiple Defendants Sentenced  in Kickback
                 Scheme

                 Several officials from Ebasco Services, Inc., a major government contractor, as well
                 as officials from one of Ebasco's subcontractors, have been sentenced in connection
                 with a kickback scheme.

                 Ebasco provided power generation, environmental remediation, hazardous waste
                 processing, and construction services to numerous government agencies, including
                 the EPA and the Department of Defense. In connection with those contracts, Ebasco
                 entered into subcontracts with various vendors and suppliers to provide the goods
                 and services needed to perform the contracts.

                 Frederic DiNonno, a manager in Ebasco's graphics department; Lawrence Towers, a
                 supervisor in Ebasco's graphics department; and Vincent Patuto, an Ebasco facilities
                 management supervisor, awarded subcontracts to several vendors in exchange for
                 kickbacks. DiNonno and his co-conspirators established at least two companies to
                 receive the kickback payments from the various vendors. More than $2.6 million in
                 kickbacks were paid to DiNonno and his co-conspirators in exchange for favorable
                 treatment. Approximately $800,000 of the kickbacks were in connection with
                 government contracts.  These kickback payments were charged to the government
                 through Ebasco's invoices for payment under the contracts.

                 Robert J. Strom and Thomas M.  Costas, Sr., co-owners of Action Reprographics,
                 Inc. were sentenced in U.S. District Court, District of New Jersey, on December 3,

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2003, and December 13, 2003, respectively.  Each was placed on probation for
5 years, including 6 months of home detention, and ordered to perform 40 hours of
community service. In addition, each was fined $24,000 and a $200 special
assessment. Both Strom and Costas previously pleaded guilty to charges of
conspiracy to violate the Anti-Kickback Act of 1986 and filing a false income tax
form. In 2002, each entered into a $100,000 civil settlement with the
U.S. Government for his part in the kickback scheme.

On November 5, 2003, Vincent Patuto was sentenced in U.S. District Court, District
of New Jersey, to 2 years probation, and ordered to pay a $1,000 fine and a $100
special assessment. Patuto pleaded guilty in September 2001 to conspiracy to violate
the Anti-Kickback Act and subscribing to false income tax returns.

Frederic DiNonno pleaded guilty in 2001 to charges of conspiracy to violate the
Anti-Kickback Act of 1986 and filing a false tax return. Lawrence Towers  pleaded
guilty in 2001 to charges of violating the Anti-Kickback Act and aiding DiNonno in
filing a false tax return. Sentencing for both is still pending.

This case was conducted with the U.S. Postal Service,  Office of Inspector General;
the Defense Criminal Investigative Service; the Internal Revenue Service, Criminal
Investigations Division; and the National Aeronautics and Space Administration,
Office of Inspector General.
Two University Employees Sentenced for Theft

On December 16, 2003, in Superior Court, State of Connecticut, Shili Liu,
Laboratory Director, and Robert Carley, Director, Environmental Research Institute
(ERI), University of Connecticut, were found guilty of conspiracy to commit larceny
in the first degree. Liu was also found guilty of larceny in the first degree.

Both Liu and Carley were sentenced to 12 months in the Accelerated Rehabilitation
Program (Pre-trial diversion), ordered to perform 100 hours of community service,
and fined $100.  In addition, Liu and was ordered to return $62,772 to the university.

Liu and Carley had been receiving rent monies from visiting scholars at ERI, even
though the scholar's housing was provided and paid for by the University of
Connecticut under Federal grant monies awarded to ERI by the  EPA.

This case was conducted with the assistance of the University of Connecticut Police
Department.
Questionable  Expenses Result in
$30,000 Settlement

On February 9, 2004, a settlement agreement was reached between Sherman Titens,
Titens Consulting Group, and the U.S. Government, relating to questionable

                           28

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expenses charged to EPA cooperative agreements by Mr. Titens, former President of
the Coordinating Committee for Automotive Repair (CCAR). This agreement was
facilitated by the U.S. Attorney's Office in Wichita, Kansas. In the settlement,
Titens and Titens Consulting Group agreed to pay $30,000 to the government and be
voluntarily debarred for a period of 3 years.

In 2001, a joint proactive effort between the EPA OIG Office of Audit and Office of
Investigations was initiated to assess various cooperative agreements for
vulnerabilities. The cooperative agreements issued to CCAR were selected for
review in EPA Region 7. CCAR received approximately $2 million in cooperative
agreements from the EPA.  During the assessment, it was discovered that Titens had
submitted approximately 40 questionable claims for travel reimbursement. Titens
resigned his CCAR position before the review began.
Impersonator Sentenced for Copying  Official

Seals

On February 6, 2004, Steven L. Nagy was sentenced in U.S. District Court, Northern
District of Texas, to 46 months in prison, followed by 3 years of supervised release,
in connection with charges related to impersonation. Nagy was also ordered to pay
$218,656 in restitution and a $200 special assessment.

Nagy, the owner and operator of Earth Source Environmental Management,
Sallisaw, Oklahoma, created copies of professional engineering seals bearing the
names and license numbers of at least four professional engineers. Nagy used the
forged credentials to write, sell, and distribute fraudulent Spill Prevention Control
and Countermeasure Plans.

Under Federal regulation, Spill Prevention Control and Countermeasure Plans are
required to be signed and certified by a licensed professional engineer and
maintained on file at certain facilities. If a facility does not have a signed and
certified plan, they are fined $5,000 regardless of the quality of the plan. Nagy
admitted to producing Spill Prevention Control and Countermeasure Plans for more
than 100 customers since 1991 using the forged credentials.
Professor Settles  Civil Complaint

On February 13, 2004, Richard B. Schlesinger, professor of environmental medicine,
New York University School of Medicine, entered into a civil settlement in U.S.
District Court, Southern District of New York, to settle a false claims case. In the
settlement, Schlesinger agreed to pay the United States $17,500. From 1999 to
August 2001, Schlesinger submitted numerous fraudulent reimbursement requests to
New York University. These reimbursement requests were paid from monies
provided by Federal grants funded by the EPA.  Schlesinger used the illegally
obtained funds to support his personal hobby of stamp collecting.
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EPA Employee Sentenced in Credit Card  Case

On March 1, 2004, Laticia Cunningham, Information Management Assistant, Office
of Executive Support, EPA Office of the Administrator, was sentenced in U.S.
District Court, District of Maryland, to 3 years probation and ordered to pay $4,278
in restitution and a $25 special assessment. This sentencing is a result of
Cunningham's guilty plea to conversion of government property. Cunningham's
aunt, an employee of the Department of Health and Human Services, National
Institutes of Health, stole a government purchase card from the National  Institutes of
Health mail room. Cunningham admitted to using this stolen purchase card to make
personal purchases at local retail stores.

This case was conducted with the Department of Health and Human Services, Office
of Inspector General.
Former Finance Director Sentenced
for Embezzlement

On December 1, 2003, Debra P. Strickland, former Finance Director, Lower
Mississippi River Conservation Committee (LMRCC), was sentenced in U.S.
District Court, Southern District of Mississippi, to 33 months in prison, followed by
3 years of probation, on charges related to embezzlement. She was ordered to pay
$637,855 in restitution to LMRCC and a $100 special assessment. LMRCC received
Federal grant monies from the EPA as well as the U.S. Fish and Wildlife Service.
Strickland, as the Finance Director, was the only person who had signature authority
on the LMRCC bank account.  Strickland would write checks for cash from the
LMRCC bank account and keep the proceeds.

This case was conducted jointly with the Department of Interior, Office of Inspector
General.
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  Public Liaison
  Addressing specific concerns of the public.
              Review at Bunker Hill Site Found EPA Actions to
              Generally  Be Appropriate

              An EPA OIG review of complaints regarding the Bunker Hill Superfund site and the
              surrounding Coeur d'Alene Basin area found that EPA followed laws and regulations in
              listing the site and met community involvement standards.  However, we found that the
              site's Lake Management Plan could better address cleanup.

              The OIG conducted a review of issues that citizens brought to our attention regarding the
              Bunker Hill/Coeur d'Alene Basin site, primarily located in northern Idaho.

              We found that EPA followed laws and regulations in listing the site, and concluded that
              EPA made a logical decision to first do cleanup work in the Bunker Hill "Box" (where
              the mines and smelter were located) and then later pursue further cleanup as needed in
              the overall Basin. EPA is permitted to address the most critical areas first, and we
              consider that a logical decision.

              Another concern raised was whether the Comprehensive Environmental Response,
              Compensation, and Liability Act authorizes the Basin Environmental Improvement
                                                          Commission to plan, prioritize, and
                                                          perform response/remedial actions,
                                                          as specified in the September 2002
                                                          Record of Decision.  The Act does
                                                          not address the creation of such an
                                                          independent body. However, the
                                                          National Contingency Plan - the
                                                          Federal Government's blueprint for
                                                          responding to hazardous substance
Aerial photo of former Bunker Hill smelter facility (EPA photo).
                                                          releases - encourages and allows
                                                          the involvement of such a
                                                          commission.
              We found that the Coeur d'Alene Lake Management Plan could better address cleanup
              under the Clean Water Act.  The management actions recommended in the Plan lack
              detail, and do not fully support an EPA decision to conduct a partial deletion of the Lake
              from the National Priorities List. We recommended better implementation of the plan.
              Further, due to the lack of dedicated funding for Plan implementation, we recommended
              that EPA, the State of Idaho, and the Coeur d'Alene Tribe form a consensus about
              dedicating the funds. EPA indicated it will respond to the specific recommendations
              after the final report is published; a response is due in June 2004.
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Although concerns were raised about EPA properly following laws and regulations in
handling community involvement during the Superfund process, we concluded that
community involvement met standards. We found many instances where EPA took
positive steps to involve the community, and noted considerable input by the community
for the remedial design work for the overall Coeur d'Alene Basin. Also, we found
evidence that EPA took steps to help alleviate the economic downturn in Shoshone
County, which includes the Bunker Hill Box and much of the Coeur d'Alene Basin.

(Report No. 2004-P-00009, Ombudsman Review of Bunker Hill and Coeur d'Alene Basin
Superfund Actions, March 24, 2004)
Additional Public  Liaison Reviews Conducted

In addition to a review of citizen complaints regarding the Bunker Hill Superfund site,
we conducted several other reviews of citizen complaints and provided our conclusions
to interested parties.

Regarding the Lemon Lane Landfill, part of the Westinghouse PCB (Polychlorinated
Biphenyls) Site Cleanup, Bloomington, Indiana, we concurred with EPA and the State
that there was no potential  health risk to the immediate public, since the landfill is not
accessible to the public.  It should be noted that EPA and the State had determined that
there is a risk of PCB contamination of several springs, and we agreed. We also
concluded that studies equivalent to remedial investigation/feasibility studies had been
performed for the various Westinghouse site locations, and that the Lemon Lane Landfill
was remediated to Comprehensive Environmental Response, Compensation, and
Liability Act standards.

Our review of complaints surrounding the Lowery Landfill Site, Arapahoe County,
Colorado, found that EPA has taken appropriate steps to protect public health and the
environment. Extensive sampling has not shown the exceeding of stringent standards for
radionuclides, and we determined that bi-weekly sampling will continue to ensure safety
and protection of public health and the environment. Also, we found that an early
warning monitoring system is  in place for detecting the presence of radionuclides in the
groundwater.

For the Solitron Devices site, Riviera Beach, Florida, regarding concerns about the
burden for payment of the maintenance of the air stripper used to clean the city's
drinking water, we determined that there was agreement that the cost will be borne by
EPA rather than the community. Further, it appears that groundwater contaminated by
volatile organic compounds will be properly treated, and EPA will conduct the necessary
sampling to design the chemical oxidation system. Lastly, EPA completed the additional
data collection pertaining to groundwater testing at the site.
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Hotline Activity
The following EPA OIG Hotline activity regarding complaints of fraud, waste, and abuse
in EPA programs and operations occurred during the past semiannual period:
   Complaints Open

   Complaints Closed


   Complaints Handled by EPA OIG

   Complaints Referred to:

     EPA Program Offices
     EPA Criminal Investigation Div.
     Other Federal Agencies
     State/Local Agencies
                                    Semiannual Period
                                    (October 1,2003 -
                                      March 31, 2004
 30

461


111
129
  2
 40
209
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Congressional  Requests
Providing Congress with specific information.
            OIG  Provides Congress  Details on $174.9 Million
            Superfund Shortfall

            In response to a Congressional request, we issued a report on the fiscal 2003 funding
            needs for non-Federal Superfund sites, and estimated a $174.9 million shortfall. During
            fiscal 2003, this limited funding prevented EPA from beginning construction at all sites
            or providing the amount of funds needed to address sites in a manner believed necessary
            by regional officials.  This caused projects to be segmented in phases and/or scaled back.
Category
New start construction projects not funded
Remedial projects not sufficiently funded
Removal projects not sufficiently funded
Pipeline projects not sufficiently funded
Total (difference due to rounding)
Estimated 2003
Funding Shortfall
(millions)
$118.5
40.8
9.4
6.1
$174.9
                                                        A breakdown of the estimated
                                                        $174.9 million shortfall is shown in
                                                        the table. Removal funding involves
                                                        emergency and time-critical actions;
                                                        pipeline funding involves
                                                        pre-construction activities, such as
                                                        studies and remedy selection; and
                                                        remedial funding is for remedial
                                                        construction, long-term response
                                                        actions, non-time critical removals,
                                                        and five-year reviews.
            EPA emphasized the funding of ongoing construction over new construction starts.  For
            fiscal 2003, the National Risk Based Priority Panel considered 35 new start projects and
            determined that 9 should receive remedial funds.  Of the remainder, 15 did not receive
            remedial funds, and 11 were determined not ready for various reasons, including
            enforcement issues, changed site conditions,  and design complications.

            When calculating amounts obligated for fiscal 2003 removal, pipeline, and remedial
            projects, we included not only the amounts from EPA's fiscal 2003 and prior year
            appropriations, but also the amounts from State Superfund contracts and from potentially
            responsible parties in response to Consent Decrees.  For fiscal 2003, EPA regions
            obligated $160.3 million for removal projects, $107.6 million for pipeline projects, and
            $369.3 million for remedial projects.

            Our shortfall estimate only considers the regions' use of extramural resources (funds
            for contractors and others  outside EPA), and  does not address intramural  resources
            (obligations involving the labor and travel of EPA personnel that are obligated to
            specific Superfund sites).

            (Report No. 2004-P-00001, Congressional Request on Funding Needs for Non-Federal
            Superfund Sites, January 7, 2004)
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Special Request Report Details
Enforcement Information

The OIG provided Congress with details on specifically requested information on EPA
enforcement issues, addressing such topics as new EPA duties related to homeland
security, funding, and case loads.

EPA has shifted priorities, budget, and personnel to activities that would support
homeland security.  EPA's Office of Enforcement and Compliance Assurance criminal
enforcement staff has worked on homeland security investigations, assisted in the
anthrax investigation at the U.S. Capitol, and provided training and other information to
local and State water authorities. For fiscal 2003, the Office of Enforcement and
Compliance Assurance was provided about $4 million to support homeland security.

Regarding funding, for fiscal 2003 as of August 28, 2003, EPA had spent approximately
$318 million on its goal to ensure full compliance with laws intended to protect human
health and the environment. Although we had noted funding shortfalls in certain areas in
the past, EPA lacked sufficient information on workload and results that would allow us
to evaluate the overall sufficiency of funds for EPA's enforcement activities, and EPA
needs this results information.

As noted in the table, EPA
had 3,858 enforcement cases
open in August 2003.
Sometimes there were delays
in pursuing a case.  Various
factors were  cited for such
delays, including insufficient
resources, assigning staff to
work on major disasters (such
as the World Trade Center
collapse), coordinating with
State authorities, and various
legal issues.

Contrary to recent news accounts, we found no indication that EPA has loosely defined
"agent" to inflate its numbers of Criminal Investigation Division agents. We also found
that there were policies in place governing the Division's work performed, although it
appeared that the management systems for tracking leads, time, results, and training
needed improvement.

(Report No. 2003-S-00001, Congressional Request on EPA Enforcement Resources and
Accomplishments, October 10,  2003)
Type of Case                               No.
Criminal (as of August 26, 2003)                1,190

Civil (as of August 9, 2003)
  Clean Air Act                             1,041
  Resource Conservation and Recovery Act        874
  Clean Water Act                            753

Total                                      3,858
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 Testimony
Providing testimony before Congressional committees.
            Assistant Inspector General  Testifies on
            Assistance Agreement Efforts

            During testimony before several Congressional committees, an OIG Assistant Inspector
            General stated that EPA needs to continue to improve the way it manages assistance
            agreements.

            "It is imperative that the Agency use good management practices in awarding and
            overseeing these agreements to ensure that they effectively contribute to attaining
            environmental goals," Melissa Heist, the OIG's Assistant Inspector General for Audit,
            told members of the Senate's Committee on Environment and Public Works during
            testimony on March 3, 2004.

            Heist noted assistance agreements are a primary means EPA uses to carry out its mission
            of protecting human health and the environment. The approximately $4.4 billion in
            assistance agreements awarded during fiscal 2003 encompassed more than half of that
            year's Agency budget.

            In addition to reviewing management of specific grants, Heist noted OIG has also looked
            at overall systemic problems.
It is imperative that the Agency use good management
practices in awarding and overseeing these
agreements to ensure that they effectively contribute to
attaining environmental goals.

   - Melissa Heist, Assistant Inspector General for Audit
                                March 3, 2004
"Our grants management work has focused on
crosscutting national issues and has included
grants made to States, local and tribal
governments, and nonprofit organizations. .  . .
We designed our work to identify systemic
problems preventing the Agency from
achieving the maximum results from the
billions of dollars awarded in assistance
agreements every year," she said.
            Heist noted that we reported in 2003 that project officers did not perform all the
            necessary steps when conducting pre-award reviews. "Without complete pre-award
            reviews of proposed projects, there was insufficient assurance that the funded projects
            would accomplish program objectives or desired environmental results. There was also
            insufficient assurance that proposed costs were reasonable, and that recipients were
            technically capable of performing the work. EPA may also have lost the opportunity to
            fund other projects that would have better achieved its mission," Heist pointed out.

            Oversight of assistance agreements after they are awarded is also an area of concern.
            Heist noted that while the Agency has developed policies and training to improve
            oversight, it did not ensure that the policies were followed consistently. "The challenges
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for EPA will now be to ensure that staff implement, and are held accountable for,
following the new policies and for implementing the new grants management and
training plans," she said.

Heist also provided examples of problems with specific assistance agreements that show
how EPA's lack of review and oversight can contribute to problems with the grantee.
She noted an instance of a $4.7 million grant that the OIG questioned because the work
was performed by an ineligible lobbying organization. For another grant, we questioned
$1.7 million in costs claimed because the recipient did not have an adequate time
distribution system and an indirect cost rate, as required.

Previously, on October 1, 2003, Heist testified on assistance agreements before the
House Transportation and Infrastructure Subcommittee on Water Resources and the
Environment.  She discussed how the OIG has issued hundreds of audits on assistance
agreements over the past few years, involving millions of dollars of questioned costs.

One  particular issue she addressed during that testimony  was that some grant recipients
continued to have problems in the procurement of contractual services, noting that
recipients did not have sufficient knowledge of procurement regulations, and often
procured services as a result of familiarity and long-term relationships with contractors.

"Competition in procuring services is important to ensure that the government is getting
the best product, at the best price, from the most qualified firms. Competition also
promotes innovation and new ideas in solving environmental problems.  EPA needs to
ensure project officers are adequately monitoring recipients' procurements," the
Assistant Inspector General said.
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Other Activities
            OIG Conference Stresses Importance of
            Helping Agency Improve

            The need for the EPA OIG to help the Agency better protect the environment was urged
            by a number a speakers at the OIG National Training Conference held in December 2003
            in Washington, B.C., including key EPA officials.
                              "You're helping the Agency chart a course for improvement - to
                              do the right thing," EPA Acting Deputy Administrator Stephen L.
                              Johnson told the conference attendees.

                              "We need to make sure we're delivering results, delivering the
                              goods," Johnson said, pointing out the OIG needs to help the
                              Agency do so better.

                              Johnson noted the OIG has already had  "some impressive results"
                              in improving Agency functions. "A number of you have really
                              helped to set the stage as scouts, to help us focus," Johnson said,
                              citing in particular the OIG's work in helping EPA improve its
                              financial management systems.
EPA Acting Deputy Administrator
Stephen L. Johnson addressed the
OIG staff (EPA OIG photo).
            The three-day conference featured a number of speakers from the OIG, the Agency, and
            other government organizations. David M. Walker, Comptroller General of the United
            States, emphasized during his presentation
            that the entire OIG community "needs to focus
            more on results rather than best efforts."

            Walker told the EPA OIG attendees, "you're
            on the front lines of fighting fraud, waste, and
            mismanagement," and stressed they need to do
            their best to help government operate more
            effectively.
            Further, Walker pointed out that due to a
            crisis in the public's confidence of the audit
            community's private sector following several
            recent scandals, "we have an opportunity in
            the public sector to be the Gold Standard,"
            and therefore need to set a good example.
                                                       EPA Inspector General Nikki Tinsley (left) and
                                                       U.S. Comptroller General David M. Walker at
                                                       the OIG conference (EPA OIG photo).
            Inspector General Nikki Tinsley, in her opening remarks, stressed that the OIG's mission
            is to "add value" as well as "inspire public confidence." She noted that the EPA OIG "is
            probably better placed than anyone else in the country to make sure EPA is doing its
            job," and the OIG needs to do its best to fulfill that role.
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Inspector General  Community  Celebrates
25th Anniversary

October 12, 2003, marked the 25th Anniversary of the enactment of the Inspector General
Act.  On the occasion of the its  Silver Anniversary, the Inspector General community
marked its accomplishments by, among other things, meeting with the President of the
United States.

President George W. Bush met  with the Inspectors General on October 14, 2003, to
honor and recognize their community. He commended the Inspectors General for their
dedication to the mission of combating fraud, waste, and abuse,  and making programs
work better for the taxpayers. He also commended the community's vigilance to remain
"agents of positive change."

Also, on October 8, 2003, the House Government Reform Subcommittee on
Government Efficiency and Financial Management held a hearing to examine the
progress of the Inspector General Act since it was passed, and expressed interest in
discussing what legislative changes were needed to help the Inspector General
community perform its mission.
President George W. Bush meets with the Executive Council on the 25th anniversary of the IG Act.
From left, Johnnie Frazier, IG, Department of Commerce; Barry Snyder, IG, Federal Reserve Board;
Ken Mead, IG, Department of Transportation; Gaston Gianni, IG, Federal Deposit Insurance
Corporation; President Bush; Greg Friedman, IG, Department of Energy; Nikki Tinsley, IG,
Environmental Protection Agency; Patrick McFarland, IG, Office of Personnel Management; and
Clay Johnson, Deputy Director for Management, Office of Management and Budget.
                               39

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On October 16, 2003, the President's Council on Integrity and Efficiency/Executive
Council on Integrity and Efficiency held its annual award ceremony. This ceremony was
planned and coordinated by the EPA OIG, with EPA Inspector General Nikki Tinsley as
the Mistress of Ceremonies for the second consecutive year.

Further, on December 1, 2003, President Bush signed S.J. Res. 18, a joint Congressional
Resolution, commending the Inspectors General for their efforts to prevent and detect
fraud, waste, abuse, and mismanagement, and to promote economy, efficiency, and
effectiveness in the Federal Government during the past 25 years.
Inspector General  Receives Leadership Award

EPA Inspector General Nikki Tinsley was presented with the Distinguished Federal
Leadership Award from the Association of Government Accountants at the group's
national leadership conference in February 2004.

Tinsley, a member of the Association's Northern Virginia Chapter, received the award in
recognition of her "extraordinary vision, dedication and impact on governmental
financial management and performance systems, and her personal leadership in
advancing the profession and demonstrating the value of governmental auditing
programs."

The Distinguished Federal Leadership Award was established "To formally recognize
elected or Presidentially-appointed federal officials who exemplify and promote
excellence in government management and have demonstrated outstanding leadership in
enhancing sound financial management legislation, regulations, practices, policies and
systems."

Tinsley was appointed as the EPA Inspector General in November 1998.  She had joined
EPA's Office of Inspector General in 1990, after working with the Department of the
Interior's Mineral Management Service and the U.S. General Accounting Office.

Tinsley serves as a member of the President's Council on Integrity and Efficiency and
chairs the Council's Human Resource Committee.  She is also a member of the Advisory
Council on Government Auditing Standards and the Comptroller General's Domestic
Working Group.
Agency Reports on Actions in Federal Managers'
Financial Integrity Act Report

In its recommended actions on EPA's management weakness for its fiscal 2003 Federal
Managers' Financial Integrity Act report, Agency senior managers did not support an
OIG recommendation to declare "Improved Management of Assistance Agreements" a
material weakness.
                             40

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While the Agency indicated further improvement is still needed to correct this current
Agency-level weakness (which, unlike a material weakness, does not merit the attention
of the President and Congress, and only required Agency attention), EPA indicated it has
made significant progress in addressing the concerns raised by the OIG. Specifically,
EPA has noted it has:

•    Established the new long-term Grants Management Plan as the framework for
    ensuring that EPA grant programs meet the highest management and fiduciary
    standards and further the Agency's strategic goals.
•    Enhanced training programs.
•    Increased competitive grants awarded to non-profit organizations.
•    Expanded post-award monitoring.
•    Developed a new comprehensive approach to grants management reviews.
•    Implemented measures to heighten accountability, such as the ongoing review of
    grants management performance standards.

The Agency has reported progress on other Agency-level weaknesses previously noted
by the OIG, and recommended closure of these weaknesses.  Specifically, EPA indicated
it has sufficiently increased the pace of cleanups of properties subject to the Resource
Conservation and Recovery Act. Further, by mid-2003, the Agency reported it had
completed all corrective actions related to Results-Based Information Technology
Investment Planning.  In addition, the Agency has indicated it has completed corrective
actions to develop and implement security tools and processes that mitigate risks to
EPA's data and systems.

In addition to carrying over 10 existing Agency weaknesses, EPA agreed to add an
additional weakness at the suggestion of the OIG, involving assuring implementation of
the  Agency Information Security Program. To address this new weakness, the Agency
plans to establish and validate a robust quality assurance program, a security training
program for those with significant security responsibilities, a process to ensure that the
Agency's information security plan is practiced throughout the  life cycle of information
systems, and a policy and management framework to support development and testing of
up-to-date contingency plans for Agency information systems.

While the Agency reported taking corrective actions related to Results-Based
Information Technology Investment Planning, we are concerned that all actions have not
been completed. In particular, we suggest that the Agency complete actions to
implement monitoring and evaluation phases in its Capital  Planning Investment Control
process.  These phases expand on how Information Technology investments, once
initiated, will be controlled to achieve intended cost, schedule, and performance
outcomes, and how EPA will evaluate performance to maintain a positive return on
investment.  EPA states that it is acquiring additional resources and extramural contract
support to help implement best practices for these two essential investment control
phases.  Further, EPA is still developing procedural guides to provide a framework to
manage the Information Technology portfolio in a more effective manner. Because these
actions are not complete, we believe EPA should add an Agency-level weakness in
fiscal 2004.
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OIG  New Strategic Plan  Revises Goals,
Defines New Directions

The OIG revised and, in February 2004, issued a new Strategic Plan, applicable for
fiscal years 2004-2008.  This plan sets a new direction, featuring three goals instead of
the previous four, and updates OIG's values and presents broad new strategies.

The Strategic Plans's three new goals are:

 1. Contribute to Improved Human Health and the Environment.
 2. Contribute to Improved Agency Business Practices and Accountability.
 3. Continuously Improve OIG Products and Services.

The Plan is built on a Logic Model concept, "starting with the end in mind," to fulfill the
requirements of the Inspector General Act and EPA's goals, based on several cross-
cutting themes:

•   Change is a way of life;
•   Emphasize Environmental Conditions, Risks, Opportunities and Impacts;
•   Link Performance Planning and Measures with Costs and Benefits;
•   Collaborate Across Media and Government Entities; and
•   Apply a Systems Approach to Ask the Right Questions.

This Plan was  formulated using an innovative technique based on research and input
from OIG staff and leadership, EPA leadership, the Office of Management and Budget,
Congressional staff,  State Agencies, key EPA stakeholders, the U.S. General Accounting
Office, and key associations. Responses to key questions were electronically categorized
by topic and characterization to synthesize priorities  and common themes, to help
identify new opportunities.  The Strategic Plan link is:
http://www.epa.gov/oig/reports/2004/20040201-EPA-350-R-001.pdf
Annual Performance  Report Highlights
Return on Investment

The OIG issued its Annual Performance Report for fiscal 2003, the third of it kind,
presenting actual results compared to our fiscal 2003 annual performance targets, as well
as cumulative progress compared to our Strategic Goals from fiscal 2001 through 2003.

The report demonstrates how a linked series of measures within each goal roll up to
support the OIG Vital Few Measures and Results reported to the Office of Management
and Budget and Congress through the EPA Annual Performance Report. This OIG
report features a Balanced Scorecard of outputs, intermediate outcomes, and impact
outcomes for each of the OIG goals.  It also presents related performance results from
measures of customer value, partner/collaborative efforts, staffing, development,
diversity, timeliness of work products, innovation and use of technology, operational
activity, and application of financial resources.
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In addition to the quantitative measures and results, this report provides qualitative
examples of significant actions, outputs, and actions that, together, combine to
demonstrate the total value added by the OIG, and provide accountability for the return
on investment of OIG resources.

Also, for the first time, the OIG has prepared an Executive Summary version of the
Annual Performance Report to present graphical and narrative summary highlights of the
OIG's fiscal 2003 performance results. Both the Annual Performance Report and the
Executive Summary are at OIG's web site.
PCIE GPRA  Roundtable Leads OIG Community
Through Performance  Issues

The President's Council on Integrity and Efficiency (PCIE) Government Performance
and Results Act (GPRA) Roundtable, chaired and coordinated by the EPA OIG, has
presented a series of events demonstrating best practices in planning, measurement, and
accountability.

At the GPRA Roundtable on "OIG Involvement in the Program Assessment Rating Tool
(PART)," the Office of Management and Budget announced that while OIGs themselves
would not be subject to PART reviews, it is relying on the OIG community to assist in
PART assessments of their respective agencies, and requested that OIGs help define that
role. The instructions for the fiscal 2006 budget PART assessment now specifically
include references to OIG independent evaluations.

During the reporting period, other GPRA Roundtable events covered such topics as
designing, deploying, and using customer surveys for planning, measurement, and
performance improvement; and implementing cost accounting in OIGs.  A measures fair
was also held. Minutes from PCIE GPRA Roundtable events are available at
www.IGnet.gov.

The GPRA Roundtable was highlighted in the PCIE Progress to the President for Fiscal
2003 as a major achievement in the effort to improve Federal programs and operations,
and in promoting budget and performance integration.
Legislation and Regulations Reviewed

Section 4 (a) of the Inspector General Act requires the Inspector General to review
existing and proposed legislation and regulations relating to the program and operation
of EPA and to make recommendations concerning their impact. The primary basis for
our comments are the audit, evaluation, investigation, and legislative experiences of the
OIG, as well as our participation on the President's Council on Integrity and  Efficiency.

During the reporting period, we reviewed 28 proposed changes to legislation,
regulations, policy, and procedures that could affect EPA. We also reviewed drafts of
                              43

-------
EPA's strategic plan, program operations manual, directives, and reorganizations.
Details on several items follow.

Proposed Revision to EPA Order 5700.6, Policy on Compliance Review and
Monitoring:  We commented on our concerns that the EPA Order does not specifically
reference the guidance for grants management self assessment, and that the frequency of
self assessments was changed from 2 to 3 years.  With a 3-year cycle, it is important that
there is followup to ensure that corrective actions are taken. The Grants Management
Division needs to update its review guidance and establish tracking and followup
procedures on issues previously identified.  EPA agreed to make changes regarding our
concerns.

General Accounting Office's Draft Strategic Plan: We commented that, overall, this
Draft Strategic Plan significantly improved on the prior plan. Our suggestions for
improvements included: emphasizing partnering  opportunities with Federal Office  of
Inspectors General to share knowledge and work on common objectives; acknowledging
the expanding role of States, tribes, local governments, and third parties; streamlining the
Plan by including an Executive Summary of the External Factors and Consultations; and
adding annual performance targets.

Proposed Revision to EPA Delegation 1-6-A, Security; and a  New EPA Order,
National Security Information: We commented that the EPA Office of Administration
and Resources Management should have the overall responsibility for the National
Security Information program. However, as an independent entity, OIG should be
delegated authority to operate its own such program. We also expressed concern that
EPA's Chief Information Officer appears to have been excluded  from having any
responsibility for contributing to policy and maintaining a program for classified national
security information.

Proposed Long-Term Grants Management Training Plan: We believe this Plan is a
foundation of EPA's sincere effort to turn a long-time Management Challenge into a
strength. As such, the Office of Grants and Debarment should consider this plan a "work
in progress" that will need to be re-evaluated and revised with experience. We made
several suggestions for improvement: all goals should be incrementally phased by fiscal
year (some only had a 100-percent target); the outcome/impact measures of the training
should be linked to improved outcome performance  measures built into agreements; and
grantee "compliance" should not be used as a valid performance  measure of the training
since it is not closely related to training quality.
                               44

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Statistical Data
Status Report on Perpetual Inventory of Reports in Resolution Process
for Semiannual Period Ending March 31, 2004
Report Category
A. For which no management decision
was made by October 1 , 2003**
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 March 31 , 2004
F. Reports for which no management
decision was made within 6 months
of issuance
No. of
Reports
98
177
117
158
51
107
56
Report Issuance
($ in Thousands)
Questioned
Costs
$51,717
$8,120
$0
$59,837
$2,841
$56,966
$45,688
Recommended
Efficiencies
$3,627
$0
$0
$3,627
$29
$3,598
$3,598
Report Resolution Costs I
Sustained 1
($ in Thousands)
To Be
Recovered




$1 ,086


As
Efficiencies







  ** 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.
                                     45

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Status of Management Decisions on Inspector General Reports

       This section presents statistical information as required by the Inspector General Act
       Amendments of 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.
       Auditees frequently 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 March 31, 2004 (Dollar Value in Thousands)
Report Category
A. For which no management decision was made by
October 1 , 2003"
B. New reports issued during period
Subtotal (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 March 31 , 2004
Reports for which no management decision was made
within 6 months of issuance
Number of
Reports
53
19
72
22
13
9
50
34
Questioned
Costs*
$51,717
$8,120
$59,837
$2,841
$1 ,086
$1 ,755
$56,996
$45,688
Unsupported
Costs
$10,726
$0
$10,726
$153
$42
$111
$10,573
$10,573
   Questioned costs include the unsupported costs.
   Any difference in number of reports and amounts of questioned costs between this report and previous semiannual
   report results from corrections made to data in our audit tracking system.
                                          46

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Table 2  -  Inspector General Issued Reports With Recommendations That Funds
           Be Put to Better Use for Semiannual Period Ending March 31, 2004
           (Dollar Value in Thousands)
Report Category
A. For which no management decision was made by October 1 , 2003**
B. Which were issued during the reporting period
Subtotal (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 March 31 , 2004
Reports for which no management decision was made within 6 months of issuance
Number of
Reports
7
0
7
1
0
1
0
6
6
Dollar
Value
$3,627
$0
$3,627
$29
$0
$29
$0
$3,598
$3,598
    Any difference in number of reports and amounts of questioned costs between this report and previous semiannual report
    results from corrections made to data in our audit tracking system.
Audits With No Final Action as of March 31, 2004,
That Are Over 365 Days Past OIG Report Issuance Date
Audits
Programs
Assistance Agreements
Contract Audits
Single Audits
Financial Statement Audits
Total
Total
23
50
24
25
2
124
Percentage
18.5%
40.3%
19.3%
20.2%
1 .7%
100.0%
                                               47

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Summary of Investigative Results
                         Cases open as of September 30, 2003
                         Cases opened during period
                         Cases closed during period
                         Cases pending as of March 31, 2004
•
Investigations Pending by Type
as of March 31, 2004

Contract
Assistance Agreement
Employee Integrity
Program Integrity
Computer Crime
Lab Fraud
Other
Total
Superfund
14
3
3
3
0
14
2
39
Management
23
28
19
16
17
16
8
127
Total
37
31
22
19
17
30
10
166
                         Indictments / Criminal Informations / Complaints
Personnel and Administrative Actions
Termination
Restitutions
Resignations
Suspension and Debarments
Other
Total
Cost Savings
1
2
3
5
10
21
$309,355
                                      48

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Scoreboard of Results: At Mid-Year (March 31, 2004)
Compared to Fiscal 2004 Annual Performance Goal Targets

All results are of those reported, and do not include all followup actions of previous periods - unaudited
Strategic Goal; With Fiscal 2004
Performance Targets Compared to Results Reported
Supporting Measures
Goal 1. Contribute to Improved Human Health and Environmental Quality
Influence environmental improvements/
actions/ changes
Target: 42; Reported: 17 (40%)
Reduce or eliminate environmental or
infrastructure risks and challenges
Target: 18; Reported: 5 (28%)
Environmental recommendations, best practices,
risks identified
Target: 80; Reported: 22 (28%)
0 Legislative changes/decisions
0 Regulatory changes/decisions
17 EPA policy, process, practices change
0 Examples of environmental improvement
0 Best environmental practice implemented
4 Environmental risks reduced/eliminated
1 Certifications/validations/verifications
6 Environmental recommendations
0 Environmental best practices identified
16 Environmental risks identified
Goal 2. Improve EPA's Management, Accountability, and Program Operations
Return on investment: Potential dollar return as
percentage of OIG budget ($48 million)
Target: 150%; Reported: $9.2 million; (13%)
Improve operational integrity: Criminal, civil,
and administrative actions reducing risk of loss/
operational integrity
Target: 80; Reported: 60 (75%)
Improvements in business/systems/efficiency and
resolve public concerns/management challenges
Target: 100; Reported: 38 (38%)
Recommendations, best practices, challenges
identified for operational improvements
Target: 240; Reported: 103 (43%)
Dollars in Millions
$ 8.1 Questioned costs
$ 0.1 Recommended efficiencies, costs saved
$1.0 Fines, recoveries, settlements
26 Criminal convictions
9 Indictments/informations/complaints/arrests
3 Civil judgments/settlements
22 Administrative actions
18 Policy process, practice, control changes
1 Corrective action on FMFIA/mgt. challenge
6 Best practices implemented
1 3 Certifications/validations/verifications/
allegations disproved
95 Recommendations
6 Best practices identified
0 FMFIA/management challenges identified
2 Referrals for OIG or Agency action
                                  49

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 Preceeding Page Blank
                                                                                                                                 Precee
  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.
Report Number Title
2004-P-00001 Boxer/Dingell Congressional Request - 2003
2004-P-00002 Project XL Asbestos /Demolition
2004-P-00003 Superfund Issues in Indian Country
2004-P-00004 EPA's Pretreatment Program
2004-P-00005 Mega Financial Responsibilities at Superfund
Mine Sites
2004-P-00006 Idaho National Eng. & Env . Lab Petition
Special Review
2004-P-00007 Emissions Credit Trading and Environmental
Justice
2004-P-00008 Review of SDWIS GPRA Measure
2004-P-00009 Coeur d ' Alene/Bunker Hill Ombudsman Audit
2004-P-00010 Hotline Complaint - Basin Cleanup Coalition
2004-P-00011 EPA Equipment Purchases for Counter Terrorism
P repa rednes s
2004-P-00012 Evaluation of Air Toxics Emissions for GPRA
Reporting
2004-P-00013 EPA's Implementation of Network Firewalls
2004-P-00014 Review of Hotline Allegation (OUST)
Final Report
Issued
07-JAN-04
19-DEC-03
20-JAN-04
02-FEB-04
04-FEB-04

05-FEB-04

Ol-MAR-04

05 -MAR- 04
22-MAR-04
25-MAR-04
29-MAR-04

31-MAR-04

31-MAR-04
31-MAR-04
Recommended
Questioned Costs Efficiencies
Ineligible Unsupported Unreasonable (Funds Be Put
Costs Costs Costs To Better Use)






$0












        TOTAL PERFORMANCE REPORTS
                                    14
                                                                           $0
                                                                                            $0
                                                                                                            $0
                                                                                                                    $0
2004-4-00014  Consumer Federation of America Foundation-
             Costs Claimed
2004-4-00015  New Mexico Environment Department SF
             Cooperative Agreement

         TOTAL ASSISTANCE AGREEMENT REPORTS = 2
Ol-MAR-04

31-MAR-04
$4,714,638

   $11,588


$4,726,226
                                                                                           $0
                                                                                           $0
                                                                                                            $0
                                                                                                             $0
                                                                                                                    $0
2004-3-00001 Thlopthlocco Tribal Town                     27-OCT-03       $47,217
2004-3-00002 South Carolina,  State of                     27-OCT-03
2004-3-00003 Delaware, State  of                           27-OCT-03      $350,244
2004-3-00004 Pyramid Lake Paiute Tribe                    28-OCT-03      $521,591
2004-3-00005 Alliance for the Chesapeake Bay,  Inc.         28-OCT-03
2004-3-00006 St. George Traditional council               31-OCT-03
2004-3-00007 Blackfoot, City  of                           31-OCT-03      $332,461
2004-3-00008 Middletown Rancheria                         31-OCT-03
2004-3-00009 Hampshire College                           31-OCT-03
2004-3-00010 Combes, City of                              31-OCT-03
2004-3-00011 Northway Village Council                     31-OCT-03       $69,393
2004-3-00012 Ute Indian Tribe                            19-NOV-03
2004-3-00013 NATIVE VILLAGE OF MEKORYUK IRA COUNCIL        19-NOV-03
2004-3-00014 Chitina Traditional Indian Village Council    20-NOV-03
2004-3-00015 Chitina Traditional Indian Village Council    20-NOV-03
2004-3-00016 Montgomery County Combined Health District    12-DEC-03
2004-3-00017 Leech Lake Band  of Ojibwe                    18-DEC-03
2004-3-00018 LEECH LAKE BAND  OF OBJIBWE - 2001            18-DEC-03
2004-3-00019 Chickaloon,  Native Village                   31-DEC-03
2004-3-00020 Shoemakersville,  Borough of                  31-DEC-03
2004-3-00021 National Senior  Citizen Edu. & Research       31-DEC-03
2004-3-00022 Colorado, State  of                           31-DEC-03
2004-3-00023 California,  State of                         15-JAN-04
2004-3-00024 Commonwealth of  the Northern Mariana  Islands  21-JAN-04
2004-3-00025 Sssociation of State & Interstate Water Pol.  21-JAN-04       $77,566
            Cont. Adim.
2004-3-00026 National Asian Pacific Center on Aging        03-FEB-04
2004-3-00027 National Asian Pacific Center on Aging        03-FEB-04      $151,942
2004-3-00028 Pennsylvania,  Commonwealth of                29-JAN-04
2004-3-00029 New Mexico Environment Department,  State of   29-JAN-04
2004-3-00030 Calumet, Charter Township of                 29-JAN-04
2004-3-00031 Southeastern States Air Resource Managers Inc 29-JAN-04
2004-3-00032 Association of Metropolitan Sewerage  Agency   29-JAN-04
2004-3-00033 Jasper, County of                           29-JAN-04
2004-3-00034 Howard University                           29-JAN-04
                                                              51

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                                                                                                                      Recommended
                                                                           	Questioned Costs	 Efficiencies
                                                           Final Report    Ineligible     Unsupported    Unreasonable  (Funds  Be Put
Report Number	Title	Issued	Costs	Costs	Costs	To  Better Use)

2004-3-00035 New Jersey,  State of                          30-JAN-04
2004-3-00037 Michigan-Department of Agriculture, State of  30-JAN-04
2004-3-00038 Alaska,  State of                              03-FEB-04
2004-3-00039 Chautauqua,  County of                         06-FEB-04
2004-3-00040 Austin,  City of                               06-FEB-04
2004-3-00041 Hawaii Department of Health, State of         09-FEB-04
2004-3-00042 Vermont, State of                             09-FEB-04       $56,643            $0            $0
2004-3-00043 Pennsylvania, University of                   09-FEB-04
2004-3-00044 delaware River Basin Commission               12-FEB-04
2004-3-00045 Alaska Inter-Tribal Council                   12-FEB-04
2004-3-00046 The Pacific American Foundation               12-FEB-04
2004-3-00047 Association of Farmworker Opportunity Program 12-FEB-04
2004-3-00048 Alabama, University of                        19-FEB-04
2004-3-00049 Otoe-Missours Tribe of Indians                19-FEB-04
2004-3-00050 National Alliance for Hispanic Health         19-FEB-04
2004-3-00051 Sherwood Valley Band of Porno Indians          19-FEB-04
2004-3-00052 Yukon River Inter-Tribal Watershed Council    19-FEB-04
2004-3-00053 Cuyapaipe Band of Mission Indians             19-FEB-04
2004-3-00059 United States Virgin Islands, Government of   27-FEB-04
2004-3-00060 United States Virgin Islands, Government of   27-FEB-04
2004-3-00061 United States Virgin Islands, Government of   27-FEB-04
2004-3-00062 Illinois, State of                            03-MAR-04      $951,659            $0            $0
2004-3-00063 Inter-Tribal Council of Michigan, Inc.        04-MAR-04
2004-3-00064 Vermont State Colleges                        04-MAR-04
2004-3-00065 Blackfeet Tribe of the Blackfeet Indian       04-MAR-04
             Reservation
2004-3-00066 Lovelock, City of                             04-MAR-04
2004-3-00067 Lovelock, City of                             04-MAR-04
2004-3-00068 Academy of Natural Science of Philadelphia    04-MAR-04
2004-3-00069 Tyrone,  Borough of                            04-MAR-04
2004-3-00070 West Virginia, State of                       ll-MAR-04      $347,518
2004-3-00071 West Virginia, State of                       ll-MAR-04
2004-3-00072 Florida, State of                             16-MAR-04        $4,806            $0            $0
2004-3-00073 Florida, State of                             16-MAR-04       $36,413            $0
2004-3-00074 New Mexico - Department of Health, State of   18-MAR-04
2004-3-00075 New Mexico - Department of Health, State of   18-MAR-04
2004-3-00076 Puerto Rico - Department of Health,           23-MAR-04
             Commonwealth of
2004-3-00077 Clark Atlanta University                      24-MAR-04

         TOTAL  SINGLE AUDIT REPORTS =  72                                  $2,962,753           $000



         TOTAL  OIG ISSUED CONTRACT REPORTS  =0                                  $000              0



2004-1-00001 OMNIPLEX World Services Corp.-FY1999 Incurred Ol-OCT-03
             Cost
2004-1-00002 Acurex Environmental c/o Arcadis Geragh-      Ol-OCT-03
             FY2000 Incurred Cost
2004-1-00003 CET Environmental Services Inc.-FY2001        Ol-OCT-03
             Incurred Cost
2004-1-00004 Tetra Tech EMI-FY2002 Labor Internal Control  10-OCT-03
2004-1-00005 Northbridge Envtl Mgmt Consultant-FY2001      30-OCT-03        $3,985
             Incurred Cost


2004-1-00006 Foster Wheeler Envtl. Corp.-FY2003 Accounting 16-OCT-03
             System
2004-1-00007 TAMS Consultants, Inc.-FY 1999 Incurred Cost  20-OCT-03
2004-1-00008 DynCorp Inc.-FY2001 Incurred Cost             20-OCT-03
2004-1-00009 FEV Engine Technology-FY2002 Incurred Cost    03-NOV-03
2004-1-00010 Welso Federal Services LLC-FY2002 Incurred    03-NOV-03
             Cost
2004-1-00011 Malcolm Pirnie, Inc.-FY 1998 Incurred Cost    03-NOV-03
2004-1-00012 ManTech Environmental Tech, Inc.  (METI)-      03-NOV-03
             FY2001 Incurred Cost
2004-1-00013 Black & Veatch Special Projects Corp.-FY2000  06-NOV-03
             Incurred Cost
2004-1-00014 Stratus Consulting Inc-FY2000 Incurred Cost   06-NOV-03
2004-1-00015 Parsons Engineering Science-FYs 2000-2001     07-NOV-03
             Incurred Cost
2004-1-00016 WRS Infrastructure & Environmental Inc-FY2001 07-NOV-03
             Incurred Cost
2004-1-00017 Omni-Cube(OMNIPLEX World Services Corp)-      07-NOV-03
             FY2001 Incurred Cost
2004-1-00018 Tetra Tech EM,Inc.-CAS 410-Alloc of Bus Unit  10-NOV-03
                                                                   52

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                                                                                                                       Recommended
                                                                           	Questioned Costs	 Efficiencies
                                                           Final Report    Ineligible    Unsupported     Unreasonable (Funds Be Put
Report Number	Title	Issued	Costs	Costs	Costs	To Better Use)

2004-1-00019 Eastern Research Group-FY2001 Incurred Cost   10-NOV-03
2004-1-00020 Acurex Environmental c/o Arcadis, Gerap-      10-NOV-03
             FY2001 Incurred Cost
2004-1-00022 Computer Based Systems-FY2000 Incurred Cost   24-NOV-03         $3,958
2004-1-00023 Tetra Tech EMI, Inc.-FY2002 Estimating System 24-NOV-03
              Internal Contr
2004-1-00024 SAIC-Closeout #68-D4-0098                     17-DEC-03
2004-1-00025 Industrial Economics Inc-FY2003 System Review 17-DEC-03
2004-1-00026 Resource Management Concepts, Inc.-FY2001     17-DEC-03
             Incurred Cost
2004-1-00027 RS Information Systems, Inc.-FY2001 Incurred  17-DEC-03
             Cost
2004-1-00028 Tetra Tech EM, Inc. (TTEMI)- FY2001 Incurred  29-DEC-03
             Cost
2004-1-00029 URS Group, Inc.-FY 2003 Billing Practices on  31-DEC-03
             EPA 68-W-98-228
2004-1-00030 Black & Veatch Spec Proj Corp (BVSPC)-FY 2000 31-DEC-03         $8,781
             68-W9-9043
2004-1-00031 Consol. Safety Services, Inc.-FY 2002 I/C     31-DEC-03
             (Included FYs 00-01
2004-1-00032 Environmental Quality Management (EQM)-FY2000 31-DEC-03
             Incurred Cost
2004-1-00033 SoBran, Inc. - CFY2002 Incurred Cost (FYE     06-JAN-04
             9/30/02)
2004-1-00034 SAIC-Closeout 68-D3-0030                      16-JAN-04
2004-1-00035 Environmental Health & Engineering-FY2000     21-JAN-04
             Incurred Cost
2004-1-00036 Great Lakes Environmental-FY2002 Incurred     30-JAN-04
             Cost
2004-1-00037 IT Group-FY2002 Incurred Cost                 02-FEB-04
2004-1-00038 SECTEK, Inc.--FY 2000 Incurred Cost           09-FEB-04
2004-1-00039 WRS Infrastructure & Environ., Inc. - FYE     09-FEB-04
             12/31/2000 I/C
2004-1-00040 ESE (Harding ESE,  Inc.)- FYE 10/31/2001       25-FEB-04
             Incurred Cost
2004-1-00041 Metcalf & Eddy Inc-FYE 9/30/2001 Incurred     02-MAR-04
             Cost
2004-1-00042 Weston Solutions,  Inc. - Preaward PR-CI-03-10 02-MAR-04
             595
2004-1-00043 Lockheed Martin Svc.- Preaward REAC PR-CI-03- 03-MAR-04       $414,160
             10595
2004-1-00044 Environmental Management Support (EMS)-CY2001 03-MAR-04
             Incurred Cost
2004-1-00045 Environmental Quality Management (EQM- FY2001 04-MAR-04
             Incurred Cost
2004-1-00046 DPRA,  Inc. - FYE 3/31/2003 Incurred Cost      08-MAR-04
2004-1-00047 Perrin Quarles Associates, Inc.- FYE 12/31/02 18-MAR-04
             Incurred Cost
2004-1-00048 Metcalf & Eddy Inc.-  FYE 2001 RAC 68-W6-0042  18-MAR-04
2004-2-00001 Alpha-Gamma Technologies Inc.-FY1998 Incurred Ol-OCT-03
             Cost
2004-2-00002 Alpah-Gamma Technologies Inc.-FY1999 Incurred Ol-OCT-03
             Cost
2004-2-00003 Malcolm Pirnie, Inc.-FY1999 Incurred Cost     Ol-OCT-03
2004-2-00004 Lockheed Martin Services, Inc.-CAS 401 & 402  30-OCT-03
2004-2-00005 FEV Engine Tech -  FY2003 Material Purch/      03-NOV-03
             Consumptio  (MAAR 13)
2004-2-00006 FEV Engine Technology - FY 2003 Floorcheck    03-NOV-03
             (MAAR 6)
2004-2-00007 ManTech Environmental Tech Inc.(METI) - CACS  03-NOV-03
             68-D5-0057
2004-2-00008 Metcalf & Eddy Inc.-Floorcheck                04-NOV-03
2004-2-00009 CH2M Hill Inc.-FYs 2000-2001 Annual RAC       05-NOV-03
             Close-out 68-W9-8225
2004-2-00010 Arrowhead Contracting Inc.-Financial Cap.     06-NOV-03
             Risk Assessment
2004-2-00011 Stratus Consulting, Inc-FY2001 Incurred Cost  06-NOV-03
2004-2-00012 Integrated Laboratory Systems-FY2003          10-NOV-03
             Floorcheck  (MAAR 6)
2004-2-00013 CH2M Hill Inc.-FY1996 through 2000 RAC        10-NOV-03
             68-W6-036
2004-2-00014 Tetra Tech,  Inc.-Quick Closeout CACS 68-W8-   21-NOV-03
             00-92 FYS1988-2000
2004-2-00015 Foster Wheeler Environmental Corp.-FY2001     26-NOV-03
             RAC 68-W9-8214
2004-2-00016 Kerr & Associates, Inc-FY1994-1998 Assist     18-DEC-03
             Audit I/C Subcontr
2004-2-00017 Tetra Tech NUS, Inc.-FYs 1996-1998 RAC        18-DEC-03
             Close-out 68-S6-3003
                                                                   53

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                                                                                                                       Recommended
                                                                           	Questioned Costs	 Efficiencies
                                                           Final Report    Ineligible    Unsupported    Unreasonable (Funds Be Put
Report Number	Title	Issued	Costs	Costs	Costs	To Better Use)


2004-2-00019 Weston Solutions, Inc. -DACA45-98-D-0004      03-MAR-04
             Delivery Order ttl
2004-2-00020 Tetra Tech EM, Inc.  (EMI)- Preaward PR-CI-03- 03-MAR-04
             10595
2004-2-00021 URS Operating Svcs & URS Group, Inc.-Preaward 03-MAR-04
             PR-CI-03-10595
2004-2-00022 Tetra Tech, Inc. A&E Div  (TTI Div)-Floorcheck 04-MAR-04
             thru 3/2003
2004-2-00023 Versar, Inc.-CACS 68-01-7053 & Follow-up      08-MAR-04
             Audit complet 2/2004
2004-2-00024 Tetra Tech Inc./B&V SPC Joint Venture-FY2000  16-MAR-04
             RAC 68-S7-3002
2004-2-00025 Universe Technologies, Inc.-FYE 12/31/2001    16-MAR-04
             Incurred Cost
2004-2-00026 Ricardo, Inc. -  CFY 2003 Incurred Cost        16-MAR-04
             (6/30/03)
2004-2-00027 Marasco Newton Group Ltd.- FYE 12/31/2001     18-MAR-04
             Incurred Cost
2004-2-00028 GE Energy & Environmental Research Corp.-     18-MAR-04
             FY2001 I/C Review
2004-4-00001 Sierra Research Inc.-FY 2002 Incurred Cost    17-DEC-03
2004-4-00002 Scientific Consulting Group, Inc.-FYFY2003    18-DEC-03
             Floorcheck
2004-4-00003 Eastern Research Group- FY 2003 Floorcheck    31-DEC-03
2004-4-00004 Environmental Quality Management-FY2003 Time/ 31-DEC-03
             Floorcheck
2004-4-00005 Bionetics Corporation - FY2002 Incurred Cost  06-JAN-04
2004-4-00006 Limno-Tech, Inc.-FY 2003 Incurred Cost        06-JAN-04
2004-4-00007 Clean Air Vehicle Tech Center- CFY 2002       06-JAN-04
             Incurred Cost(FYE3/31/02)
2004-4-00008 Clean Air Vehicle Technology Center - FY 2003 06-JAN-04
             Incurred Cost
2004-4-00009 CH2M Hill, Inc.-FY 2004 CAS D/S Revision lla, 07-JAN-04
             effective 1/1/04
2004-4-00010 DPRA,  Inc.- Financial Capability Assessment   07-JAN-04
             as of 9/30/2004
2004-4-00011 Eastern Research Group- CAS 412/413           07-JAN-04
             Compliance FYE 12/31/02
2004-4-00012 Automotive Testing Laboratories Inc.-FY2002   13-JAN-04
             Incurred Cost
2004-4-00013 SECTEK, Inc.--FY 2001 Incurred Cost           09-FEB-04

         TOTAL  DCCA CONTRACT REPORTS  =  87                                     $430,884         $0               $0       $0



2004-1-00021 FY 2003 Agency F/S Preparation & Reporting    21-NOV-03
             (sub)

         TOTAL  FINANCIAL STATEMENT REPORTS  =1                                      $0         $0               $0       $0



2004-S-00001 ENFORCEMENT RESOURCES AND ACCOMPLISHMENTS     10-OCT-03

         TOTAL  SPECIAL REVIEW REPORTS  =1                                           $0         $0               $0       $0
            TOTAL REPORTS ISSUED  =  177                                     $8,119,863          $0               $0       $0
                                                                   54

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                OIG Mailing  Addresses and Telephone  Numbers
Headquarters
Environmental Protection Agency
Office of Inspector General
1200 Pennsylvania Ave. NW (2410T)
Washington, DC 20460
(202) 566-0846
Dallas
Environmental Protection Agency
Office of Inspector General (6OIG)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Audit: (214) 665-6621
Investigations: (214)665-2790
Philadelphia
Environmental Protection Agency
Office of Inspector General
1650 Arch Street, 3rd Floor
Philadelphia, PA  19103-2029
Audit: (215) 814-5800
Investigations: (215) 814-5820
Atlanta
Environmental Protection Agency
Office of Inspector General
61 Forsyth Street, SW
Atlanta, GA 30303
Audit: (404) 562-9830
Investigations: (404) 562-9857
Denver
Environmental Protection Agency
Office of Inspector General
999 18th Street, Suite 300
Denver, CO 80202-2405
Audit: (303) 312-6872
Investigations: (303) 312-6868
Research Triangle Park
Environmental Protection Agency
Office of Inspector General
Mail Drop N283-01
Research Triangle Park, NC 27711
Audit: (919) 541-2204
Investigations: (919) 541-0517
Boston
Environmental Protection Agency
Office of Inspector General
One Congress St.
SuitellOO(Mailcode)
Boston, MA 02114-2023
Audit: (617) 918-1470
Investigations:(617) 918-1481
Kansas City
Environmental Protection Agency
Office of Inspector General
901 N. 5th Street
Kansas City, KS 66101
Audit: (913) 551-7878
Investigations: (312) 353-2507 (Chi.)
Sacramento
Environmental Protection Agency
Office of Inspector General
80II Street, Room 264
Sacramento, CA 95814
Audit: (916) 498-6530
Investigations: (415) 947-8711 (SF)
Chicago
Environmental Protection Agency
Office of Inspector General
77 West Jackson Boulevard
13th Floor (IA-13 J)
Chicago, IL 60604
Audit: (312) 353-2486
Investigations: (312) 353-2507
Los Angeles
Environmental Protection Agency
Office of Inspector General
P.O. Box 826
La Miranda, CA 90627-0826
Investigations: (714) 521-2189
San Francisco
Environmental Protection Agency
Office of Inspector General
75 Hawthorne St. (IGA-1)
7th Floor
San Francisco, CA 94105
Audit: (415) 947-4521
Investigations: (415) 947-8711
Cincinnati
Environmental Protection Agency
Office of Inspector General
MS : Norwood
Cincinnati, OH 45268-7001
Audit: (513) 487-2360
Investigations: (312) 353-2507 (Chi.)
New York
Environmental Protection Agency
Office of Inspector General
290 Broadway, Room 1520
New York, NY 10007
Audit: (212) 637-3080
Investigations: (212) 637-3041
Seattle
Environmental Protection Agency
Office of Inspector General
1200 6th Avenue, 19th Floor
Suite 1920, M/S OIG-195
Seattle, WA 98101
Audit: (206) 553-4033
Investigations: (206) 553-1273
                                       OIG Public  Liaison  Hotline:
                                  1-888-546-8740 or (202)  566-2476

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