;* .,**
«*..»». > ?* * •* ' *
f.,* ,
t
rftfT.r -**s"
-
^ > f/T
k * ?', I
I *w
*.* Jr *
-------
On the cover: Photo by Steve Delaney
EPA Photographer
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
-------
Foreword
I he combination of effective audit and investigative work
during the past six months, along with a strong Agency
management partnership for improvement has enhanced the
environment for change and resulted in significant progress. By
communicating with our audit customers frequently and assisting
Agency management to recognize opportunities for cost saving and
solving problems, the OIG is helping EPA achieve greater
accountability and productivity from its resources. The OIG has also
developed a more streamlined organization and strategic plan for
applying a greater proportion of its resources directly to audits and
investigations in environmental programs.
This report highlights some of our most significant audits,
investigations and concerns along with Agency action to implement
our recommendations. Subjects discussed in this report include
the threat of contaminated drinking water in schools, the need for
better air quality emission standards, the need for more reliable budget and accounting practices,
wasteful and improper contracting practices by the Agency and its grantees, distortions in the value of
real property in the financial statements, and Agency success in reducing administrative time cleaning
up Superfund sites. Also, our investigations have resulted in a significant number of civil settlements
that have returned funds to the government.
Agency management is actively pursuing improved accountability throughout its programs and
operations as one of its major strategic objectives and for compliance with the Government
Performance And Results Act. Although we are encouraged by EPA's commitment to this initiative,
much still needs to be done. We will continue working to strengthen our partnership with Agency
management to promote the changes and actions necessary to improve the accountability for its
resources and environmental results.
r
• 1
-------
EPA's Progress in Improving Areas of Significant OIG Concern 1
Executive Summary 4
Major Laws Administered by EPA 6
Profile of Activities and Results 7
Establishment of the OIG in EPA-lts Role and Authority 8
Purpose and Requirements of the Office of Inspector General
Semiannual Report 8
Who's Who in the Office of Inspector General 9
Section 1-Significant Findings and Recommendations
Government-Wide Issues 10
Program Management 12
Extramural Resources Management 18
Financial Management 22
Construction Grants 27
Section 2-Report Resolution
Status Report on Perpetual Inventory of Reports in Resolution Process
for the Semiannual Period Ending September 30,1996 32
Status of Management Decisions on IG Reports 32
Resolution of Significant Reports 35
Section 3-Prosecutive Actions
Summary of Investigative Activities 36
Description of Selected Prosecutive and Administrative Actions 37
Civil and Administrative Actions to Recover EPA Funds 39
Section 4-Fraud Prevention and Management Improvements
Review of Legislation and Regulations 41
Suspension and Debarment Activities 42
OIG Management Initiatives 42
Committee on Integrity and Management Improvement 44
Personnel Security 45
Appendices
Appendix 1-Reports Issued 46
Appendix 2-Reports Issued Without Management Decisions 53
-------
'.-14'* *..
lifV- '«!
kVjf;.
** »-s „,.- • \
W"» %
K O * v V
-------
EPA's Progress in Improving Areas of Significant OIG Concern
This section of our report presents
the Office of Inspector General's
(OIG) perspective on significant
problems requiring additional
Agency attention to ensure its
programs are conducted
effectively, efficiently, and
economically. OIG and EPA
personnel have cooperated
extensively to address these
problems. The Agency has also
taken a number of actions either
independently or in prompt
response to our reports to
improve its operations. However,
EPA's most significant problems
were created over a long period of
time, and resolution will require
long term commitments and
constant attention. Therefore, it is
too soon to determine whether
EPA management's corrective
actions will fully solve these
problems.
The following presents the areas
of significant current concern to
the OIG, and some of EPA's
actions taken during the last year
to address them.
AIR PROGRAMS
OIG Concerns
Emission factors are used to
estimate emissions from a source
when more reliable emissions
data are not available. Without
reliable emissions factors, EPA,
states and industry who rely upon
them cannot be sure that their air
pollution control strategies target
the right industries or products
and permitting programs include
all required sources and establish
proper emission limits. Our 1996
audit found that the large majority
of published emission factors
were rated low for reliability, and
many emission factors were not
updated since 1988. EPA's use of
industry partnerships to assist in
the development of emission
factors increased the risk that
non-representative or inaccurate
factors will be developed.
Industries have an inherent
incentive to use emission factors
that indicate lower than actual
pollutant emissions. Accordingly,
we nominated emissions factor
development as a material
weakness candidate for fiscal
1996.
In reviews of enforcement and
compliance assistance activities,
we found that state enforcement
programs have a limited deterrent
effect because of little publicity
and not always assessing the
economic benefit of violations.
Our audit of EPA's regional
processing of State
Implementation Plans (SIP) found
that parts of the SIP program
needed to be improved nationally
through better guidance and
communication with states, and
by resolving processing delays.
Agency Actions
The Agency will re-examine the
program for any management or
financial integrity weaknesses and
review the appropriateness of
funding the Adopt-A-Factor
program. In addition, the Agency
will use a peer review with
industry, state and local personnel
to ensure that a balanced
perspective is presented in
industry partnership. EPA agreed
to improve communications with
states and work with air quality
program partners to streamline
and simplify the SIP process.
FINANCIAL MANAGEMENT
OIG Concerns
The Agency team that conducted
a National Performance Review of
EPA's financial management
reported three weaknesses:
insufficient time and fundy; '.he
complex financial management
systems and processes; and a
wide disparity in expertise and
attention paid to financial
management among EPA
managers. In addition, the OIG
has repeatedly reported that
EPA's accounting systems had
not provided complete, consistent,
reliable and timely data. Although
the Agency has made a number
of significant improvements in
financial management, additional
actions are needed to ensure that
EPA has trained staff, policies,
procedures and systems to carry
out these responsibilities
effectively.
An audit showed that a pattern of
errors in EPA's budgeting and
accounting practices for personnel
resources made financial
management information
unreliable for ensuring that EPA
complied with congressional
intent, and in developing budget
requests.
Another audit identified that
although the Agency has initiated
results oriented management
direction to implement the
Government Performance and
Results Act (GPRA), reliable
financial and performance
information was not always
available to effectively manage
EPA's programs.
A review of EPA's property
disclosed that the Agency
overstated deprecation, may not
have correctly accounted for
leased real property, and did not
perform lease-versus-buy
comparisons for all leases. As a
result, Agency financial
statements are inaccurate and
opportunities to achieve millions in
savings were missed.
An audit of EPA's fiscal 1995
financial statements identified
problems in recording
APRII 1 IQqSTHRODRHSFPTFMRFR-Vl 1QQR
-------
reimbursable Superfund oversight
costs as assets, accounting for
grants from more than one
appropriation, allocating expenses
to show the cost of the fund in the
financial statements and
accounting for property and
contractor-held equipment.
Agency Actions
The Agency recently took actions
to correct some of the reporting
budgeting and accounting
problems, and plans to redesign
the program element structure as
part of its Planning, Budgeting and
Accountability system. EPA has
agreed to correct the issues
identified in our fiscal 1995
financial statements audit report.
The Agency, for various reasons
such as staffing and budget
constraints, has not taken action
on all of our concerns and much
more work is necessary to
address the problem areas we
have identified.
LEAKING UNDERGROUND
STORAGE TANKS
OIG Concerns
Leaking underground storage
tanks (LUST) pose significant
environmental risks throughout
the country. Although States
have made progress cleaning up
LUST sites, we found that
oversight and enforcement were
inadequate on some of the most
hazardous sites. Cost recoveries
were often not pursued and state
activity reports were misleading.
Agency Actions
The Agency generally disagreed
with our observations and
conclusions, but either agreed
with the audit's recommendations
or presented acceptable
alternative actions to ensure
States provide adequate oversight
and enforcement on high risk
sites, and states develop and
implement cost recovery
programs.
SUPERFUND
OIG Concerns
An audit found that despite
identification between 12 and 15
years ago, three Superfund sites
we reviewed were still not cleaned
up. The prolonged time spent
studying sites and designing
remedies resulted in higher
cleanup costs and continued risks
to public health and the
environment. The requirements
of the Comprehensive
Environmental Response,
Compensation, and Liability Act
and its 1986 amendments
resulted in more focus and
achieving process steps rather
than cleanups of sites. In 1988,
an on-site vault containing about 4
million pounds of hazardous
waste was targeted for a time-
critical removal action, since
extremely high concentrations of
arsenic were in the soil, ground
water and surface water
surrounding the vault. However,
the vault and its contents were still
on-site as of June 1995.
Another 1996 audit showed that
EPA Region 8 responded to the
Summitville, CO, Superfund site
emergency in a wide-spread but
remote area, by reducing
hazardous waste risks. However,
the Region did not adequately
oversee Interagency Agreements
with the Department of Interior's
Bureau of Reclamation resulting in
seven costs overruns totaling
nearly $7.3 million and inefficient
cleanup implementation.
An audit of Superfund site
laboratory data found that EPA
spent nearly $2 million overseeing
the Aerojet General Corporation
Superfund site, but had not
evaluated the quality of laboratory
data used for making public health
risk assessments, developing
cleanup public health risk
assessments, developing cleanup
alternatives, and designing the
remedy.
Agency Actions
The Agency is acting to improve
its oversight and enforcement of
interagency agreements. Also,
EPA will require Aerojet to submit
a revised quality assurance
project plan and will enhance its
oversight of Aerojet.
INFORMATION RESOURCES
MANAGEMENT (IRM)
OIG Concerns
EPA's IRM program is critical to
the success of all program
activities. This year we reported
that the year 2000 problem could
cause failure of major EPA
systems because computers store
years in two digit numeric fields
and the "00" could cause inverse
dates resulting in incorrect
assumptions and computations.
The upcoming century change is
one of the most critical problems
in data processing and industry.
Although the Office of IRM
(OIRM) had raised Agency
awareness of data processing
problems associated with the year
2000, OIRM needed to accelerate
its actions to reduce the imminent
threat of major systems failure.
Agency Actions
The Agency recognized that the
Year 2000 issue is a material
problem with potentially serious
consequences, and developed a
comprehensive plan to identify
and implement needed
modifications throughout Agency
systems.
During the past year, EPA made
major structural changes to
address long standing IRM
issues. For example, EPA
reorganized the Office of
Information Resources and
appointed a separate Chief
Information Officer (CIO).
OFFICE OF INSPECTOR GENERAL
-------
MANAGEMENT OF
EXTRAMURAL RESOURCES
OIG Concerns
EPA relies extensively on
contractors and other outside
entities to assist in: cleaning up
pollution, setting the
environmental agenda for the
future, and providing goods and
services. EPA funds public
organizations, such as universities
or state and local organizations,
and other Federal agencies, to
pursue areas of mutual
environmental concern through
assistance agreements and
interagency agreements. EPA
needs to continue improving its
extramural resources
management and to emphasize
that Agency officials are
accountable for their actions.
While we commend and support
the Agency's initiatives,
management problems continue
in this area as identified by our
recent work. We proposed grants
administration as a material
weakness candidate for fiscal
1996. The deficiencies remain a
serious concern because EPA is
initiating a major Performance
Partnership Grants program under
which recipients will have even
more latitude.
•ASSISTANCE AGREEMENTS
In July 1996, we testified before
the House Subcommittee on
National Economic Growth,
National Resources and
Regulatory Affairs, that some
recipients of assistance
agreements have wasted
taxpayers' dollars, and at times,
EPA did not get what it paid for.
These conditions occurred not
only because recipients did not
fulfill their responsibilities, but also
because EPA did not fulfill its
obligation to adequately monitor
assistance agreement activities
and apply available sanctions
when recipients did not perform.
Project officers and grants
specialists did not throughly
review grant applications, perform
site visits, review payment
requests, obtain single audit
reports, provide final certifications
or complete timely closeouts.
Basically, EPA has been awarding
assistance agreements and
paying the recipients' claims
without knowing whether the costs
were allowable and reasonable, or
the work was being performed.
An audit of congressionally
earmarked assistance to selected
universities showed that EPA
accepted earmarked funding and
implemented nonstatutory
earmarks with unclear scopes and
no specific authorizing statutes.
As a result, millions of dollars in
EPA assistance funds were
expended by this recipient for
unauthorized purposes.
During fiscal 1996, an audit found
that EPA had not adequately
defined the Superfund Technical
Assistance Grant program needs,
goals or performance measures.
The program was inconsistently
implemented and publicized,
resulting in only a small number of
grants being awarded since the
program's inception.
Another audit revealed that EPA
improperly awarded a grant to pay
ineligible expenses including
ineligible travel, catering services,
and entertainment previously
incurred by an EPA contractor for
a 1995 symposium.
•CONTRACTING
During fiscal 1996, an audit of
EPA's third largest contractor
showed that EPA's ineffective,
inefficient planning and
inadequate oversight of a major
contractor's performance resulted
in some of the products and
services procured being
inadequate, untimely, or of
questionable value.
Another audit found that EPA
acquired hundreds of passenger
vehicles without statutory
authority. EPA reported $138
million in government property,
including passenger and vehicles,
held by contractors despite
regulatory requirements that
contractors furnish all necessary
property.
We also identified that EPA
circumvented GSA, violated
several laws, and acted without
legislative authority by using a
contractor to acquire a building
independently. If EPA had used
GSA's services and purchased
the building, EPA may have saved
$3.8 million over the five-year
lease.
Agency Actions
Since 1992, improving the
administration of contracts has
been a major area of focus for
EPA. And, in fact, EPA has made
positive changes in its contract
management practices. Now, the
Agency needs to devote the same
attention to grants and other types
of assistance agreements. EPA
has initiated and is continuing to
initiate a number of efforts to
improve grants management
including an expanded project
officer training curriculum,
updating obsolete policies and
improving post award grant
management. EPA has
established an Agency-wide task
force to develop guidance and
training materials to clarify the
complexities of using contracts
and assistance
agreements to support
conferences.
APRIL 1,1996THROUGH SEPTEMBER 30,1996
-------
Executive Summary
Section 1-
Significant Findings and
Recommendations
1. Application Software
Maintenance Requires OMB
Attention
Federal departments and agencies do
not properly identify and account for
software maintenance costs. Also,
controls and oversight of software
maintenance contracts, contractors,
and software changes were
inadequate, (page 10).
2. Inadequate Oversight of
Drinking Water Programs Puts
Children at Risk
Region 3 did not require states to provide
information about their lead and copper
monitoring of small public water systems,
which delayed the enforcement actions
intended to require removal of excessive
lead from drinking water consumed by
children and infants. Also, reviews of
states' drinking water programs were
ineffective (page 12).
3. State LUST Programs Need To
Focus More On Most Hazardous
Sites
Although States have made progress
cleaning up Leaking Underground
Storage Tank (LUST) sites, oversight and
enforcement were inadequate on some of
the most hazardous sites. In addition,
cost recoveries were often not pursued
and State activity reports were misleading
(page 13).
4. Air Program Goals Impaired by
Limited Emission Factor
Development
While EPA has significantly increased the
number of emission factors for sources of
air pollution, many have still not been
developed, while others are outdated and
unreliable, thereby reducing the
effectiveness of government and industry
efforts to control air pollution (page 14).
5. Improvements Needed in EPA
and State Air Enforcement
Programs
Although Regions 5 and 6 and the states
we reviewed had effective aspects of their
air enforcement programs, penalties often
lacked an economic benefit component,
enforcement actions were seldom
publicized, and air enforcement data were
incomplete, inconsistent, and untimely
(page 15).
6. Clear and Timely EPA Guidance
Needed for State Air
Implementation Plans
Without timely, organized, or consistent
Agency guidance, EPA and States did not
always meet Clean Air Act deadlines for
submitting and processing State
Implementation Plans. Thus, it may take
longer to achieve desired air quality
results (page 16).
7. Initiatives Proved Successful at
Superfund "Mega-Site"
Region 9 accelerated the cleanup
process and made more consistent site
decisions at the South Indian Bend Wash
Superfund site by using the Agency's
Presumptive Remedy and Plug-in ROD
Superfund reform initiatives (page 17).
8. Establishment of
Supercomputing Center Violated
Laws and Potentially Wasted
Millions
EPA violated laws, manipulated the
procurement process, and may have cost
the government an additional $3.8 million
by having an Agency contractor lease a
building for the National Environmental
Supercomputing Center instead of
acquiring a facility through the General
Services Administration (page 18).
9. Lack of Oversight Resulted In
Millions of Assistance Funds Being
Misspent
As a result of EPA's lack of oversight and
failure to implement requirements for
earmarked assistance agreements,
center objectives were not attained and
millions of dollars were expended on
unauthorized or questionable projects
(page 19).
10. Sole Source Procurement Was
Improper and Cosltly
EPA awarded a sole source contract for
Geographical Information System
software without adequate support or
justification that cost EEPA $1.9 million
more than originally estimated (page 20).
11. Hazardous Materials Grantee
Did Not Obtain Best Prices or
Share Discounts
The Center for Hazardous Materials
Research (CHMR) disregarded Federal
procurement regulations for all
purchases made under two assistance
agreements by not obtaining adequate
competition. In addition, CHMR did not
satisfy cost sharing of nearly $500,000,
as required by the agreements
(Page 21).
12. EPA Needs More Reliable
Budgeting and Accounting
A pattern of errors in EPA's budgeting
and accounting practices for personnel
resources made financial management
information unreliable for ensuring that
EPA complied with congressional intent.
As a result, Agency managers relied on
inaccurate information in developing
budget requests (page 22).
13. More Decisive Action Needed
in Planning Goals and Assessing
Results
Although the Agency has initiated a
results-oriented management direction to
implement the Government Performance
and Results Act, (GPIRA), EPA still needs
to finalize environmental goals,
develope a clear and complete mission
statement, and update its strategic plan.
In addition, reliable financial and
performance information was not always
available to manage EPA's programs
effectively (page 23)
14. Further Improvements Needed
in Financial Reporting
During fiscal 1995, EPA continued to
make improvements in its financial
systems and processes. However, some
OFFICE OF INSPECTOR GENERAL
-------
remaining weaknesses continue to
prevent us from issuing unqualified
opinions on all of the Agency's financial
statements (page 24).
15. Improper Accounting for Real
Property Distorts Financial
Statements
Although the Agency made progress in
accounting for buildings it owns, it
overstated depreciation, may not have
correctly accounted for leased real
property, and did not perform lease-
versus-buy comparisons for all leases
As a result, the Agency prepared
inaccurate financial statements and
missed opportunities to save millions of
dollars (page 25).
16. $184 Million of Questioned
Costs Claimed for San Francisco
Projects
The City and County of San Francisco,
California, claimed $19.9 million of
ineligible architectural engineering costs,
project costs allocable to other Federal
facilities, and costs outside the scope of
the approved project for the design and
construction of wastewater treatment
facilities. An additional $164.2 million of
unreasonable costs were questioned
(page 28).
17. Over $18 Million of Questioned
Costs Claimed by WSSC
The Washington Suburban Sanitary
Commission (WSSC) claimed $7,481,336
of ineligible construction, engineering,
and administrative costs for modifications
to wastewater treatment facilities. An
additional $10.7 million of unreasonable
and unsupported costs were questioned
(page 28).
18. Over $11 Million of Questioned
Costs Claimed by Wallingford,
Connecticut
Wallingford, Connecticut, claimed
ineligible administrative, construction, and
engineering costs of $9,692,205 for the
expansion and upgrading of its
wastewater treatment facilities. An
additional $1,621,321 of unsupported and
unreasonable costs were questioned
(page 29).
19. Seattle Claimed Over $10
Million of Questioned Costs
Seattle, Washington, claimed $3,481,818
of ineligible equipment, construction and
engineering costs for a wastewater
treatment facility and sewer project. An
additional $7,102,524 of unsupported
costs were questioned (page 29).
20. Nearly $9 Million of
Questioned Costs Claimed for
Baltimore Projects
Baltimore, Maryland, claimed $8,331,723
of ineligible construction, engineering,
and administrative costs for
improvements at a wastewater
treatment facility. An
additional $499,744 of unsupported costs
were questioned (page 30).
Section 2-Report Resolution
This section, required by the IG Act,
reports on the status and results of
Agency management actions to resolve
audit reports. At the beginning of the
semiannual period, there were 217
reports for which no management
decision had been made. During the
second half of fiscal 1996, the Office of
Inspector General issued 248 new
reports and closed 247. At the end of the
reporting period, 218 reports remained
in the Agency followup system for which
no management decision had been
made. Of the 218 reports, 110 reports
remained in the Agency followup system
for which no management decision was
made within 6 months of issuance
(page 31).
For the 121 reports closed that required
agency action, EPA management
disallowed $17.7 million of questioned
costs and agreed with our
recommendations that $12.3 million be
put to better use (page 31). In addition,
cost recoveries in current and prior
periods included $2.0 million in cash
collections, and at least $46.9 million in
offsets against billings (page 7).
Section 3-
Prosecutive Actions
During this semiannual reporting period,
our investigative efforts resulted in 6
convictions and 10 indictments. Also, our
investigative work led to $1.6 million in
fines and recoveries (page 36).
Section 4-Fraud Prevention
and Management
Improvements
During this semiannual period, we
reviewed seven legislative and 37
regulatory items. Our most significant
comments concerned the Regulatory
Warning Act, the General Accounting
Office Management Reform Act, the
proposed EPA order on the Safety,
Health, and Environmental Employment
Program, and the response to a GAO
report on water pollution (page 41).
The EPA Office of Grants and Debarment
completed action on OIG-generated
suspension and debarment cases during
this reporting period resulting in two
debarments, one compliance agreement,
and one notice of proposed debarment
(page 42).
The EPA Committee on Integrity and
Management Improvement (CIMI),
chaired by the Inspector General,
developed an awareness document to
highlight the importance of effective
contract administration. CIMI also
coordinated EPA's Public Service
Recognition Week program and activities
(page 44).
An OIG Office of Audit survey of many of
its Agency and Congressional customers
provided positive results about the value
and effectiveness of OIG work (page 43).
APRIL1,1996 THROUGH SEPTEMBER 30,1996
-------
Major Laws Administered by EPA
Statute
Pollution Prevention Act
Toxic Substances Control Act
Federal insecticide, Fungicide*
and Rodentitide Act
Federal Food, Drug and Cosmetic Act
Resource Conservation and Recovery Act
and Solid Waste Disposal Act
Comprehensive Environmental Response,
Compensation, and Liability Ad
Clean Air Act
Ctean Water Act
Safe Drinking Water Act
Marine Protection, Research and
Sanctuaries Ad
Asbestos School Hazard Abatement Ad
and Asbestos Hazard Emergency Response
Emergency Planning and Community Right-
to-KnowAct
Oil Pollution Ad of t990
Environmental Research, Development, and
Demonstration Authorization Ad
National Environmental Education Ad
National Environmental Policy Ad of 1969
Provisions
Provides that pollution should be prevented or reduced at the source,
recycled safely when not preventable, treated safely when not
preventable or recyclable, or disposed of in a safe manner.
Requires EPA notification of any new chemical prior to its manufacture
and authorizes EPA to regulate its production, use, or disposal..
Authorizes EPA to register all pesticides* specify the terms and
conditions of their use, and remove unreasonable hazardous pesticides
from the marketplace.
Authorizes EPA io cooperation with FDA to establish tolerance levels
for pesticide residues on food.
Authorizes EPA to identify hazardous wastes and regulate their
generation, transportation, treatment storage, and disposal.
Requires EPA to designate hazardous substances that can present
substantial danger and authorizes the cleanup of contaminated sites.
Authorizes EPA to set emission standards to limit the release of criteria
pollutants and hazardous air pollutants.
Requires EPA to establish a list of water pollutants and set standards.
Requires EPA to set drinking water standards to protect public health
from hazardous substances.
Regulates ocean dumping of toxic contaminants.
Authorizes EPA lo establish a comprehensive regulatory framework for
controlling asbestos hazards in schools.
Requires States to develop programs for responding to hazardous
chemical releases and require* industries to report on the presence
and release of certain hazardous substances.
Makes EPA responsible for oil spill prevention, preparedness,
response, and enforcement adMties associated with non->
transportation-related onshore oil facilities.
Authorizes all EPA research and development programs.
Provides for a program of education on the environment through
adivities in schools and related educational adivities, and to encourage
students to pursue careers related to the environment.
Provides a national policy requiring environmental impad statements
describing potentially adverse effects of, and alternatives to, any major
Federal adion, Established the Council on Environmental Quality,
-------
Profile of Activities and Results
April 1,1996 to Fiscal 1996
September 30,1996
(dollars in millions)
Audit Operations
OIG Managed Reviews:
- Reviews Performed by EPA, Independent
Public Accountants and State Auditors
- Questioned Costs*
- Total $251.6 $287.5
- Federal Share $179.6 $205.2
- Recommended Efficiencies*
(Funds be Put to Better Use)
- Total $5.5 $18.2
- Federal Share $5.5 $18.2
- Costs Disallowed to be Recovered
- Federal Share (costs which EPA
management agrees are unallowable
and is committed to recover or
offset against future payments) $17.2 $57.6
- Costs Disallowed as Cost Efficiency
- Federal Share (funds made available
by EPA management's commitment to
implement recommendations in OIG
performance and preaward audits) $0.0 $0.4
Other Reviews:
- Reviews Performed by Another
Federal Agency or Single Audit Act Auditors
- Questioned Costs*
- Total $1.0 $3.9
- Federal Share $1.0 $3.9
- Recommended Efficiencies*
- Total $11.7 $44.0
- Federal Share $11.7 $44.0
- Costs Disallowed to be Recovered
- Federal Share $0.5 $1.5
- Costs Disallowed as Cost Efficiency
- Federal Share $12.3 $19.6
Agency Recoveries:
Recoveries from Audit Resolutions of
Current and Prior Periods (cash collections
or offsets to future payments.)**
Reports Issued:
April 1,1996 to
September 30,1996
(dollars In millions)
Fiscal
1996
$16.2M $48.9M
- OIG Managed Reviews:
- EPA Reviews Performed by the OIG 69 119
- EPA Reviews Performed by Independent Public
Accountants 9 13
- EPA Reviews Performed by State Auditors 3 6
- Other Reviews:
- EPA Reviews Performed by
another Federal Agency 128 262
- Single Audit Act Reviews 39 98
Total Reports Issued 248 498
Reports Resolved (agreement by
Agency officials to take satisfactory
corrective action)*** 121 321
Investigative Operations
- Fines and Recoveries (including civil) $1.6 $5.0
- Investigations Opened 45 116
- Investigations Closed 71 142
- Indictments of Persons or Firms 10 11
- Convictions of Persons or Firms 6 11
- Admin. Actions Against EPA Employees 12 23
- Civil Judgments 3 6
Fraud Detection and Prevention Operations
- Debarments, Suspensions, and
Compliance Agreements 4 9
- Hotline Cases Opened 11 21
- Hotline Cases Processed and Closed 15 30
- Personnel Security Investigations Adjudicated 218 602
*Questioned Costs (Ineligible, Unsupported, and Unnecessary/Unreasonable) and Recommended Efficiencies (Funds be Put to
Better Use) are subject to change pending further review in the audit resolution process.
"Information on recoveries from audit resolution is provided from the EPA Financial Management Division and is unaudited.
***Reports resolved are subject to change pending further review.
APRIL1,1996 THROUGH SEPTEMBER 30,1996
-------
Establishment of the OIG in EPA~lts Role And Authority
The Inspector General Act of
1978 (Public Law 95-452), as
amended, created Offices of
Inspector General to consolidate
existing investigative and audit
resources in independent
organizations headed by
Inspectors General.
EPA established its Office of
Inspector General (OIG) in
January 1980. As an agency
with a massive public works
budget, EPA is vulnerable to
various kinds of financial abuses.
The OIG's role is to review EPA's
financial transactions, program
operations, contracts, and
administrative activities;
investigate allegations or
evidence of possible criminal and
civil violations; and promote
economic, efficient, and effective
Agency operations. The OIG is
also responsible for reviewing
EPA regulations and legislation.
The EPA Inspector General
reports directly to the
Administrator and the Congress
and has the authority to:
• Initiate and carry out
independent and objective
audits and investigations,
• Issue subpoenas for
evidence and information,
• Obtain access to any
materials in the Agency,
• Report serious or flagrant
problems to Congress,
• Select and appoint OIG
employees,
• Fill Senior Executive Service
positions,
• Administer oaths, and
• Enter into contracts.
The Inspector General is
appointed by, and can be
removed only by, the President.
This independence protects the
OIG from interference by Agency
management and
allows it to function as
the Agency's fiscal and
operational watchdog.
Organization and Resources
The Office of Inspector General
functions through three major
offices, each headed by an
Assistant Inspector General:
Office of Audit, Office of
Investigations, and Office of
Management. Nationally, there
are nine Divisional Inspectors
General for Audit and four
Divisional Inspectors General for
Investigations who direct staffs of
auditors and investigators and
who report to the appropriate
Assistant Inspector General in
Headquarters.
During fiscal 1996, the Agency
operated under a series of
Continuing Resolutions and
suspended operations twice for a
total of 18 work days because of
two separate breaks in funding.
Despite operating under these
conditions, along with only partial
incremental funding through May,
the OIG did accomplish what was
planned. Additionally, the OIG
operated with an Agency-
imposed freeze on all personnel
actions until July. This freeze
prevented the OIG from
maintaining a workforce above
388 Full-Time Equivalent (FTE)
positions. For fiscal 1996, the
Agency was appropriated $6.5
billion including $40 million (.6%)
for the OIG.
Purpose and Requirements
of the Office of Inspector
General Semiannual Report
The Inspector General Act of
1978, as amended, requires the
Inspector General to keep the
Administrator and Congress fully
and currently informed of
problems and deficiencies in the
Agency's operations and to
recommend corrective action.
The IG Act further specifies that
semiannual reports will be
provided to the Administrator by
each April 30 and October 31,
and to Congress 30 days later.
The Administrator may transmit
comments to Congress along
with the report, but may not
change any part of it.
The specific reporting
requirements prescribed in the
Inspector General Act of 1978, as
amended, are listed below.
Source Section/Page
Inspector General Act, as amended,
Section 4(a)<2)
Section 5(a)(1)
Section 5
-------
Headquarters
Office of Inspector General-Who's Who as of October 1,1996
Office of Au*
Kenneth A. Kara
Assistant Inspector General
James O. Raich
Principal Deputy
SssaRKapf
Deputy for Acquisition &
Assistance Audits
. Svrvnons
Deputy for Internal &
Performance Audrts
Inspector General
John C. Martn
Deputy Inspector General
NkU L Tnstey
Office of Management
John C. Jonss
Assistant Inspector General
Offico of Invostagstions
AfenP.Fatn
Assistant Inspector General
EmmettD. DasNel, Jr.
Deputy Assistant Inspector General
John T. Walsh
Program Management Division
Asa Frost
Information Resource Management Division
Michael J. Binder
Budget & Reports Staff
Kenneth D. Hockman
Policy & Resources Mgmt
Robert F. Eagen
Engineering & Scientific Assistance
Patricia H. Hill
ADP Audits and Assistance
Divisional Inspectors General for Audit
Divisional Inspectors General for Investigations
Regions 1 & 2
Paul D. McKechnie
Region 3
Paul R. Gandolfo
Region 4 & RTP
Mary M. Boyer
Region 5
Anthony C. Carrollo
Region* 6,7 & 8
Bennie S. Salem
Regions 9 & 10
Truman R. Beeler
Headquarters:
HQ Audit Division
Edward Gekosky
Financial Audit Division
Melissa M. Heist
Washington Contract Division
Gordon C. Milbourn III
Regions 1,28.3
Thomas L Papineau
Regions 4, 5,6 & 7
Ailverdes Cornelious
Regions 8,9, & 10
Mark Vallerga
Washington Field Division
David Sermos
APRIL 1,1996 THROUGH SEPTEMBER 30,1996
-------
Section 1 -- Significant Findings and Recommendations
As required by sections 5(a)(1) and (2) of
the Inspector General Act of 1978, as
amended, this section identifies
significant problems, abuses, and
deficiencies relating to the Agency's
programs and operations along with
recommendations for the current period.
The findings described resulted from
audits performed by or for the Office of
Audit. Findings are open to further review
but are the final position of the Office of
Inspector General. This section is divided
into five areas: Governmentwide Issues,
Program Management, Extramural
Resources Management, Financial
Management, and Construction Grants.
Performance Indicators
This box appears throughout our report to
identify Hems that may be used as
indKators of economy, efficiency, or
effectiveness in the measurement of Agency
programs and operations.
Governmentwide Issues
In September 1986, the President's
Council on Integrity and Efficiency
(PCIE) initiated the Computer
Systems Integrity Project. The
project is a multi-task effort
focusing on controls, security, and
other integrity issues of the data
processing systems life cycle. The
objectives of the overall project are
to assess the integrity of Federal
computer systems and develop
recommendations for
governmentwide improvements in
standards, procedures,
documentation, and operations
affecting computer systems
integrity.
PCIE Task 4, which focuses on
application software maintenance,
was coordinated by the EPA OIG
and included participation by six
other Inspectors General offices.
This area was selected because (1)
controls over application software
modifications are vital to
maintaining the reliability and
integrity of sensitive and mission-
critical application systems in all
Federal agencies, and (2) Federal
managers have historically
undervalued the economic
importance of a sound,
comprehensive software
maintenance program.
Application Software
Maintenance Requires
OIVIB At&rrtiort
Findings in Brief
Federal departments and agencies
do not properly identify and
account for software maintenance
costs. Also, controls and oversight
of software maintenance contracts,
contractors, and software changes
were inadequate.
Background
The primary objectives of PCIE Task 4
were to identify common software
maintenance problems across Federal
agencies and make government-wide
recommendations to oversight
agencies. The EPA OIG had overall
responsibility for coordinating this task
with the Department of Housing and
Urban Development, Department of
State, National Aeronautics and
Space Administration, National
Science Foundation, Railroad
Retirement Board, and the Social
Security Administration's Inspectors
General offices.
We Found That
Federal departments and agencies do
not properly identify and account for
software maintenance costs. For
example, agencies do not consistently
include the costs of administrative and
clerical salaries, materials, computer
usage, telecommunications, overhead
costs, and Federal employee salaries.
In addition, agencies do not and in
some cases cannot accurately
distinguish software maintenance
costs from development and
operations. Further, agencies
reported cost-benefit analyses are not
consistently prepared, updated, or
maintained for application systems.
For many systems, contractor
estimates to determine the level of
effort and costs involved with a
proposed modification, if performed at
all, were solicited after the requested
modification had been approved. As
a result, agencies are not in a position
to make informed budgeting and
planning decisions regarding systems
operations and maintenance, and
software maintenance expenses are
being inaccurately reported to OMB.
The types of contracts used by
agencies for software maintenance do
not adequately protect the
government's interests. Agencies are
not awarding performance-based
contracts on a regular basis for
10
OFFICE OF INSPECTOR GENERAL
-------
software maintenance work, but
instead are using labor hour contracts
which place the government at higher
risk because of the lack of adequately
defined work requirements. Use of
these contracts as the sole contracting
vehicle minimizes the contractor's
incentive to perform well and control
costs. In addition, the monitoring of
these contracts resulted in
unstructured, poorly controlled
management of maintenance for
critical government applications.
Some Contracting Officer
Representatives had not received
appropriate training, some failed to
adequately monitor the technical
performance of contractors, and
others did not know how to assure the
government received what it needed
through its software maintenance
contracts. Consequently, agencies
lack control over software
maintenance activities and rely too
heavily on contractors.
Federal departments and agencies
are not adequately managing the
software change control and
configuration management processes.
Specifically, weaknesses were cited
with the change request process,
change review and approval, and
testing. For example, (1) agencies
were not using standardized change
control request forms, or used no form
at all; (2) there was minimal evidence
to support that software changes were
formally reviewed, approved, or
closed; and (3) test plans were not
developed, test results were not
analyzed, and proper test
methodologies were not followed. As
a result, agencies lack assurance that
applications will perform as intended,
and management controls will
adequately safeguard the integrity of
the applications.
We Recommended That
The Office of Management and
Budget:
• Emphasize to Federal agencies the
need to accurately identify and
account for all software maintenance
costs.
• Emphasize the need for using
performance-based contracting
methods; developing formal,
measurable performance standards;
and monitoring software maintenance
contractors.
• Encourage Federal agencies to
consistently follow Federal and
agency software maintenance
policies, standards, and procedures
for change control management.
What Action Was Taken
The final report was issued to OMB on
September 26, 1996. OMB plans to
circulate the report to Agency heads
and to the Chief Information Officers
Council. The actions prescribed for
OMB, together with the agency-
specific actions recommended by the
respective individual Inspectors
General reports, should substantially
strengthen application software
maintenance governmentwide.
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
11
-------
Program Management
The Inspector General Act requires
the OIG to Initiate reviews and
other activities to promote
economy and efficiency and to
detect and prevent fraud, waste,
and mismanagement in EPA
programs and operations. Internal
and performance audits and
reviews are conducted to
accomplish these objectives largely
by evaluating the economy,
efficiency, and effectiveness of
operations. During this semiannual
reporting period, the OIG
conducted a number of major
reviews of EPA programs. The
following are the most significant
internal audit, performance audit,
and special review findings and
recommendations pertaining to
Agency management resulting from
our efforts during this semiannual
reporting period.
Inadequate Oversight of
Dwifclng Water Programs
CNf tefrert at &!sfe
Findings in Brief
Region 3 did not require states to
provide information about their
lead and copper monitoring of
small public water systems (PWS)
which delayed the enforcement
actions intended to require removal
of excessive lead from drinking
water consumed by children and
infants. Also, reviews of states'
drinking water programs were
ineffective.
Background
The Safe Drinking Water Act of 1974
(SDWA) required EPA to establish
drinking water standards that the
nation's water systems must meet.
States are required to report all
violations of monitoring requirements
and drinking water standards to EPA.
SDWA's Lead and Copper Rule (LCR)
requires states to report each PWS
that exceeded the prescribed lead and
copper standard.
We Found That
EPA did not require the states to
provide information about small
schools and day care centers with
excessive lead in their drinking water.
In total, 40 percent of the small
schools and day care centers we
reviewed did not comply with various
aspects of the LCR, yet the states did
not inform EPA until almost two years
later. Without this information, EPA
was unaware of the violations and that
smaller PWSs did not complete
actions to remove excessive lead and
copper from their drinking water. As a
result, the Agency was not able to
take enforcement action or to apply
pressure to require states to enforce
the SDWA.
EPA also could not evaluate whether
PWSs were reducing lead in their
drinking water. One school provided
more than 500 children, teachers, and
others with drinking water that had
more than four times the lead allowed
by the LCR. The state informed EPA
about the excessive lead in the
drinking water, but EPA did not know if
the school completed the corrosion
control treatment study to eliminate
the excessive lead. In addition, states
did not inform EPA that several PWSs
had excessive copper in drinking
water.
Region 3's reviews of the states'
drinking water programs need to be
improved. We identified several
adverse conditions with the states'
drinking water program that EPA
should have addressed during its
reviews. For example, Pennsylvania
issued guidance and used testing
procedures for monitoring lead and
copper that differed from the
procedures required by the LCR.
Also, both Maryland and Pennsylvania
did not provide EPA information
concerning violations, enforcement
actions, and the dates that PWSs
completed corrective measures, and
quarterly grant reports were not
sufficiently detailed or timely.
12
OFFICE OF INSPECTOR GENERAL
-------
Petfomidnce
Indicators
- % of PWSs with too much lead/copper
-Number of PWSs violating IhoLCR
-Number and timeliness of actions
taken to attain compfiance
We Recommended That
The Regional Administrator, Region 3:
• Require states to submit the
necessary information for all small
PWSs, as required by the SDWA.
• Require Region 3 employees to take
enforcement action when states
provide information concerning
violations.
• Monitor the corrective actions taken
by the states to eliminate the
discrepancies.
What Action Was Taken
The final report (6100310) was issued
to the Regional Administrator, Region
3, on September 30, 1996. In
response to the draft report, the
Agency generally agreed with most of
our findings and recommendations.
Region 3 did not agree that states
were required to provide information
concerning small PWSs. A response
to the final report is due by December
29, 1996.
State LUST Programs Need
to Focus More On Most
Hazardous Sites
I
Findings in Brief
Although states have made
progress cleaning up Leaking
Underground Storage Tank (LUST)
sites, oversight and enforcement
were inadequate on some of the
most hazardous sites. In addition,
cost recoveries were often not
pursued and state activity reports
were potentially misleading.
Background
Leaking underground storage tanks
pose significant environmental risks
throughout the country. The
Superfund Amendments and
Reauthorization Act of 1986 created a
$500 million LUST Trust Fund, which
had grown to more than $1.5 billion by
1995, to finance the cleanup of
petroleum releases from underground
storage tanks. States operate the
LUST Program under cooperative
agreements with EPA. As of the end
of fiscal 1995, states had spent $361
million of the more than $545 million of
Trust Fund monies which had been
appropriated to EPA by Congress.
We Found That
Enforcement and oversight of
corrective action to protect human
health and the environment was not
adequate at 126 (one-half) of the 249
high risk sites reviewed, including
those with petroleum-contaminated
groundwater. Most states had
procedures focusing corrective action
on high risk sites, but they did not
always follow them. For example, one
state was aware of a leaking
underground tank but took no action
for 12 years. The state then
discovered that the site was near a
public water supply and posed a
significant threat. Another state did
not identify some sites that were the
most environmentally threatening to
groundwater.
There were major differences in
results among state cost recovery
programs, which primarily provide
incentives for owners and operators to
clean up releases from their own
tanks. Of the states reviewed, two
had effective programs that recovered
significant amounts from owners and
operators, three achieved partial
recoveries, and two did not have cost
recovery programs. When states do
not recover costs from responsible
parties, the states relieve the
responsible parties of their financial
obligation and shift the burden of
clean-up costs to the Federal
government.
State activity reports were generally
unreliable, potentially misleading, and
usually overstated program results.
For example, one state overstated
cleanups completed by 47 percent.
The reports are used to make
nationwide funding decisions, to report
program results to Congress, and to
report performance measures in
EPA's financial statements.
P&fotiiiance
-% at high risk sites cleaned up
-Daflars recovered
-Number of enforcement actions
We Recommended That
The Assistant Administrator for Solid
Waste and Emergency Response
implement management controls to
ensure that:
• States provide adequate oversight
and enforcement at high risk sites.
• States develop and implement cost
recovery programs.
• Reliable and timely information is
obtained, maintained, reported, and
used for decisionmaking.
What Action Was Taken
The final report (6100264) was issued
to the Assistant Administrator for Solid
Waste and Emergency Response on
August 6, 1996. In responding to the
draft report, the Assistant
Administrator generally disagreed with
our findings, but either agreed with the
recommendations or presented
alternative actions that met the intent
of our recommendations. A response
to the final report is due by
November 4, 1996.
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
13
-------
Air Program Goals
Impaired by Limited
imfeslon Factor
Development
Findings In Brief
While EPA has significantly
increased the number of emission
factors for sources of air pollution,
many have still not been
developed, while others are
outdated and unreliable, thereby
reducing the effectiveness of
government and industry efforts to
control air pollution.
Background
Emission factors are used to estimate
a source's air pollutant emissions
when more reliable data are not
available. These estimates play a key
role in planning and implementing air
pollution control programs at the
Federal, state, local, and industry
level. The Clean Air Act, as amended
in 1990 (CAA), required EPA to review
and revise all emission factors for
ozone precursors, develop factors for
sources where factors did not exist,
and establish a public participation
process for factor development.
We Found That
EPA's Office of Air Quality Planning
and Standards (OAQPS), Office of Air
and Radiation (OAR), has increased
the number of emission factors for
stationary and area sources from
2,073 in 1985 to over 16,000 in 1996.
However, 7,840 factors were not rated
and the vast majority were not
published. Also, 4,865 published
factors were rated below average or
poor for reliability. Further, EPA has
not published emission factors for
specific activities within the wood
products, food processing, agricultural
related, and chemical processes
industries. Significant funding
reductions to the emission factor
development program, and air
programs in general ( available
resources have steadily decreased
since 1992), have materially affected
EPA's ability to meet the increased
demand for quality emission factors.
As a result, air pollution control
programs may not achieve their goals.
OAQPS initiated an Adopt-a-Factor
program to supplement its factor
development program and offset
reduced resources. OAR allocated
grant funds to state air pollution
control agencies for emission factor
development. However, the majority
of the states did not use the funds
allocated by OAR for factor
development because EPA grant
guidance was not timely or specific
enough to implement the program. In
addition, the amount of money going
to one state would not normally be
enough to completely develop new or
revised emission factors for a
particular source category, and there
is no guarantee that states would
receive future grant money to
complete these long-term projects.
OAQPS also initiated partnerships
with interested industries to obtain
assistance in emission factor
development even though such
partnerships present an increased risk
that biased or unrepresentative
emission factors may be developed.
Industries have a financial motive to
use emission factors that produce low
emission estimates, since such factors
may allow a source to avoid obtaining
a permit or pay lower annual fees. In
addition, funding cuts have diminished
OAQPS' ability to provide oversight of
these partnerships.
Performance
Indicators
- Number of factors developed, rated, and
published
-% of factors rated avenige or bettor for
rslisbilrty
-%offactorsupdatsdvcithin5years
We Recommended That
The Assistant Administrator for Air and
Radiation:
• Report emission factor development
as an Agency material weakness,
unless adequate resources are
assigned to this function.
• Evaluate the process for issuing
Section 105 grant allocation guidance
to determine whether the guidance
can be issued before EPA Regions
and states begin their grant
negotiation process.
• Work with EPA Regions, states, and
state and local organizations to
develop a flexible grant system while
ensuring that important national
priorities are completed.
What Action Was Taken
We issued the final report (6100318)
to the Assistant Administrator for Air
and Radiation on September 30,
1996. In the October 11, 1996,
response to our draft report, the
Agency agreed with our conclusion
that the emission factor development
program is critical for air programs at
all levels of government and private
industry. The Assistant Administrator
agreed to reexamine the emission
factor development program for any
management or financial integrity
weaknesses, as part of the Agency's
decisionmaking process for reporting
under the Federal Managers Financial
Integrity Act. Also, the Agency agreed
to work toward improving the process
for grant allocations, including
14
OFFICE OF INSPECTOR GENERAL
-------
increased involvement in this process
by key stakeholders. A response to
the final report is due by December
29, 1996
Improvements Needed in
EPA and State Air
Enforcement Programs
Findings in Brief
Although Regions 5 and 6 and the
states we reviewed had effective
aspects of their air enforcement
programs, penalties often lacked an
economic benefit component,
enforcement actions were seldom
publicized, and air enforcement
data were incomplete, inconsistent,
and untimely.
Background
The Clean Air Act, as amended in
1990 (Act), gives EPA authority to set
national standards to protect human
health and the environment from
emissions that pollute the air. The Act
also defines EPA's air enforcement
authority and includes both civil and
administrative remedies. If an EPA
region, a state, or a local authority
learns a company has violated a
regulation, it can bring an enforcement
action against the company.
We Found That
The Air and Radiation Division (ARD),
Region 5, and Michigan assessed the
economic benefit violators gained from
noncompliance. In marked contrast,
Indiana, Illinois, and Wisconsin usually
did not recover the economic benefit
because: (1) Indiana and Illinois
officials did not have information
request authority; and (2) Illinois and
Wisconsin officials did not have
administrative penalty authority.
In Region 6, neither Texas nor
Louisiana generally computed
economic benefits when assessing
fines due to a lack of procedures
(Texas) or because of an
Administrative Law Judge ruling
(Louisiana). Penalties lacking an
economic benefit component are not
effective, since it may be less
expensive for a company to violate the
law than to comply with it. Also,
recovering the economic benefit for a
violation serves as a deterrent to
companies that may contemplate
violating the law.
Enforcement actions were seldom
publicized by Region 5, Indiana, and
Michigan to deter companies from
violating air pollution regulations. The
Office of Public Affairs (OPA) did not
issue many press releases because
they were not approved timely by the
Region. Also, press releases may not
have been used by the news media
because the press releases lacked
clear explanations of the violations or
the impact on the community. Indiana
and Michigan enforcement officials
were reluctant to publicize
enforcement actions to avoid drawing
attention to their programs from state
legislators. Region 6 did not
adequately publish the results of
enforcement actions since the Air
Enforcement Section was not in the
habit of issuing press releases, and
because External Affairs had not
decided on a press release format.
Only two of the ten cases we reviewed
were published by Texas, and
Louisiana did not issue any press
releases. Consequently, companies
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
15
-------
may have had less incentive to
achieve or maintain compliance with
regulations without the pressure of
public opinion generated by publicity.
The Aerometric Information Retrieval
System Facility Subsystem (AFS) was
not used by Region 5 or its states.
They developed their own systems
because AFS was difficult to use,
resource intensive, and there were
differences in how Region 5 and the
states defined and tracked
enforcement data. As a result,
enforcement data in AFS for Region 5
were incomplete, duplicative, or
internally inconsistent with data from
states. Region 6 air enforcement data
were also incomplete, inconsistent,
and untimely. Region 6 and the states
did not correctly identify significant
violators and used inconsistent
definitions. Consequently, the
reported data in Region 6 were
unreliable and program staff relied on
manual reports from separate,
duplicate databases and supplemental
information rather than the AFS.
Region 5 had reorganized, in part, to
emphasize compliance assistance,
and had conducted some compliance
assistance activities such as
educational outreach. However, the
Region had not yet developed a core
program infrastructure of clear
direction, priorities, or performance
measures, and was unable to
communicate a consistent compliance
assistance approach. Region 6
worked with states to develop and
maintain active compliance assistance
programs, but did not complete
enforcement actions timely against
significant violators. The Region and
Texas took an average of 635 and 651
days, respectively, to complete
enforcement actions, which far
exceeded EPA's timeliness goal of
180 days. When enforcement actions
are not timely, the Region and its
states do not send out a strong
message to other potential violators.
Performance
Indicators
- % of penalties with economic benefit
component
-% of enforcement actions publicized
-Number of violations and enforcement
actions taken
We Recommended That
The Regional Administrator, Region 5,
direct the:
• Enforcement and Compliance Team
to develop a compliance assistance
program infrastructure, with a clear
program direction, priorities, and
performance measures.
• ARD and OPA to work together to
develop a policy for air enforcement
press releases.
• ARD to discuss their AFS concerns
with Office of Enforcement and
Compliance Assurance officials, to
begin the process of trying to change
the data requirements.
The Regional Administrator, Region 6,
direct the Compliance Assurance and
Enforcement Division to:
• Encourage states to document,
compute, and recover the economic
benefit of non-compliance.
• Place more emphasis on publicizing
the results of Region 6 and state
enforcement actions.
• Coordinate with the Multimedia
Planning and Permitting Division to
continue to work with states to assure
the accuracy and completeness of
AFS data, as well as to ensure that
Region 6 lead cases are properly
coded and accurate in AFS.
What Action Was Taken
The final report (6100284) was issued
to the Regional Administrator, Region
5, on September 13, 1996. In
response to the draft report, the
Agency agreed with all of our findings
and recommendations. The final
report (6100309) was issued to the
Regional Administrator, Region 6, on
September 26, 1996. The Acting
Assistant Regional Administrator for
Management and the Director,
Compliance Assurance and
Enforcement Division, responded that
they basically accepted the principal
findings and agreed with the
recommendations, with comments,
since the recommendations were
consistent with the Region's
implementation of the air enforcement
program. A response to the final
report is due by December 26, 1996.
Clear and Timely EPA
Guidance Needed for State
Afr Implementation Plans
Findings in Brief
Without timely, organized, or
consistent Agency guidance, EPA
and states did not always meet
Clean Air Act deadlines for
submitting and processing State
Implementation Plans (SIP). Thus,
it may take longer to achieve
desired air quality results.
Background
EPA, states, and local governments
are required under the Clean Air Act to
implement measures to prevent and
control air pollution, with the majority
of responsibility resting with the states.
The major mechanism used to attain
the standards in individual areas is a
SIP, which is a collection of the
regulations a state will use to clean up
polluted areas.
16
OFFICE OF INSPECTOR GENERAL
-------
We Found That
Of the 56 SIPs we reviewed, the lack
of EPA guidance was the cause
mentioned most often for late SIP
submission and processing along with
delays in bringing policy issues to
closure, extended state regulatory
review processes, and limited regional
resources. As a result, states faced
sanctions for submitting SIPs after
statutory deadlines, and the Agency
faced potential lawsuits for not
processing SIPs within 18 months.
EPA's SIP guidance was not timely or
organized, and continually changed.
State officials could not determine if
they had all applicable guidance for
developing a SIP because several
different EPA offices issued guidance
in numerous forms without any
centralized listing or numbering
system. In addition, the Agency
continually changed guidance to
address policy and technical issues.
State officials, confused and
frustrated, delayed submission of
SIPs.
State officials also believed that
inequities existed in how EPA
administered its SIP program, and that
some states were held to less
stringent standards. We were not able
to substantiate these concerns, but
determined that a lack of
communication between regions and
states caused the perceived inequities
which resulted in strained
relationships, lost credibility, and state
legislatures changing or delaying
SIPs.
We Recommended That
The Assistant Administrator for Air and
Radiation:
• Establish a forum to allow states to
address concerns of inequities in
EPA's treatment of states. This may
include working with already
established state organizations.
• Request that Regional air directors
coordinate early on those SIPs that
span regional or state lines.
• Build in extra time for developing
and reviewing complex SIPs, when
EPA has some authority in setting
deadlines.
• Develop a centralized numbering
system for all SIP guidance and, as
recommended by the Workgroup,
develop a computerized listing of
specific types of SIPs, with cross
references to guidance, policies, and
regulations.
What Action Was Taken
We issued the final report (6400100)
to the Assistant Administrator for Air
and Radiation on September 30,
1996. In responding to the draft
report, Agency officials agreed in
principle with many of the audit
recommendations and provided
information on activities which was
responsive to the recommendations.
A response to the final report is due by
December 29, 1996.
Initiatives Proved
Successful at Superftind
Findings in Brief
Region 9 accelerated the cleanup
process and made more consistent
site decisions at the South Indian
Bend Wash (SIBW) Superfund site
by using the Agency's Presumptive
Remedy and Plug-in ROD
Superfund reform initiatives.
Background
The Superfund Program: The
traditional procedure for cleaning up
Superfund hazardous waste sites
involves a series of steps, including a
feasibility study to evaluate alternative
cleanup remedies and costs, and
issuance of a record of decision
(ROD) detailing the selected remedy
for the site.
South Indian Bend Wash: SIBW
covers a three square mile area in
Tempe, Arizona. Ground water was
contaminated with volatile organic
compounds (VOCs) coming from
contaminated soil at several
businesses.
Presumptive Remedy. Presumptive
remedies are the result of EPA
analyses showing the same remedies
have been repeatedly selected for
certain categories of sites. The
Agency has identified presumptive
remedies for several site categories,
including landfills, wood-treating
facilities, and soils contaminated with
VOCs. If a site currently under
investigation falls within one of these
categories, then the Agency presumes
what the appropriate remedy will be
instead of considering clean up
alternatives for each site.
Plug-in ROD: Plug-in ROD is a
technique developed by Region 9 for
use at Superfund sites that contain
many contamination sources ("mega-
sites"), such as SIBW. Each source is
considered a "subsite."
Under the Plug-in approach, EPA
selects a specific remedy for the entire
site regardless of the number of
subsites. If a subsite meets
predetermined contamination and risk
related criteria established in the
ROD, then it plugs-in to the remedy
selected in the ROD for immediate
cleanup.
We Found That
Using the Presumptive Remedy of Soil
Vapor Extraction for VOCs-
contaminated soils, Region 9
minimized redundant investigative
steps and made more consistent site
decisions.
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
17
-------
The Plug-in approach to mega-site
remediation accelerated the cleanup
process at SIBW by eliminating the
need for a feasibility study and ROD
for each subsite. EPA investigated
the subsites individually and
simultaneously, so no single site held
up the overall cleanup.
Extramural Resources
Management
Over the past several years, the
OIG has frequently identified
problems in the Agency's award
and administration of contracts,
interagency agreements, and
assistance agreements at various
offices and facilities. During this
semiannual reporting period, the
OIG conducted major reviews to
examine EPA's programs for
overseeing research funds
provided to un
iversities, controlling assistance
agreements, and overseeing
grants. We audited the records and
performance of individual
contractors and assistance
recipients. These audits determine
whether costs claimed by
contractors and assistance
recipients are eligible, supported
by documentation, necessary, and
reasonable. The following section
summarizes the most significant
findings and recommendations
reported during this semiannual
period.
Establishment of
Supercomputlng Center
Violated Laws and
Potentially Wasted Millions
Findings in Brief
EPA violated laws, manipulated the
procurement process, and may
have cost the government an
additional $3.8 million by having an
Agency contractor lease a building
for the National Environmental
Supercomputing Center (NESC)
instead of acquiring a facility
through the General Services
Administration (GSA).
Background
In 1990, Congress authorized the EPA
to acquire a supercomputer and
stipulated that it would be located in
the vicinity of Bay City, Michigan. In
fiscal 1991, Congress earmarked $8.7
million for the supercomputer, but did
not grant authority or funds for EPA to
acquire a facility to house it. The
Agency tasked a contractor to
establish and staff the supercomputer
center. In 1995, Congress rescinded
the provision that required the
supercomputer to be located in the
vicinity of Bay City.
We Found That
EPA circumvented GSA, violated
several laws, and acted without
legislative authority by using a
contractor to acquire a building for the
NESC independent of GSA. If the
Agency had used the services of GSA
and purchased the building, EPA
could have saved approximately $3.8
million over the five-year lease.
The Agency pre-selected a
supercomputer site in Bay City which
was twice as large as needed, and
then manipulated the procurement
process to have its contractor lease
the building. This action resulted in
the Agency excluding from
competition a second building located
in the Bay City vicinity which may
have been acquired at far less cost.
The Agency stated that the
Conference Report contained
contradictory language regarding the
supercomputer location. However, the
Appropriation Act stipulated very
clearly that the supercomputer would
be located in the Bay City vicinity.
Also, EPA violated acquisition
regulations by disclosing source
selection data five months before the
procurement was advertised for
competition, and dealing directly with
a real estate agent representing the
building owner.
EPA exceeded its authority and
violated Federal law by obligating the
government to reimburse its
contractor $3.7 million for a lease that
ran over four and one-half years
longer than the Agency's available
appropriation. The Antideficiency Act
prohibits government employees from
involving the government in a contract
before money is appropriated to pay
for that contract.
The building selected to house the
NESC required significant renovation
to meet current building codes, as well
as additional improvements necessary
to accommodate the computer. In
effect, the Agency gave government
property to the developer by approving
permanent improvements to the
NESC building as part of lease costs
charged to the contract. The
developer, who had purchased the
building only one day after EPA's
contractor signed the lease, recouped
the initial investment early in the
lease, a factor that contributed heavily
to the $3.8 million in excess lease
costs.
The Agency's administration of the
NESC subcontract also violated
Federal laws and regulations. The
subcontract contained a provision
prohibited by law stipulating that the
lease price would be adjusted by cost
plus 82.5 percent for material
modifications to the renovation
specifications. In addition, the
Contracting Officer and Project Officer
did not ensure that $5 million of
government equipment, including the
supercomputer, that was furnished to
the contractor was recorded on
property records. The Project Officer
promptly added the equipment to the
records during the audit.
The Agency did not create and
preserve documentation of significant
decisions and activities related to the
18
OFFICE OF INSPECTOR GENERAL
-------
establishment of the NESC, as
required by Federal laws to protect the
legal and financial rights of the
government. The majority of records
we used during the audit were
provided through subpoenas issued to
contractors, subcontractors, and other
organizations.
We Recommended That
The Deputy Administrator:
• Coordinate with EPA's Office of the
Comptroller to meet the reporting
requirements for a violation of the
Antideficiency Act. The Administrator
must report all relevant facts and a
statement of the action taken to the
Congress and to the President
through the Director, Office of
Management and Budget.
• Review whether any employee
conduct violations occurred and
whether disciplinary action is
warranted.
• Provide training to the Agency's
senior level managers on the
applicable statutes, regulations and
Agency policies and procedures.
• Hold senior managers accountable
for proper implementation of statutory
and regulatory requirements, including
ensuring that adequate management
controls are in place and followed
pursuant to OMB Circular A-123.
What Action Was Taken
The final report (6100306) was issued
to the Deputy Administrator on
September 30, 1996. In responding to
the draft report, the Acting Assistant
Administrator for Administration and
Resources Management (OARM)
disputed many of our findings, but
agreed to implement the majority of
recommendations. Most of the
disputed areas concerned
interpretations of laws and regulations,
and documents that should have been
used for final Agency decisions.
Specifically, OARM disagreed that
GSA was a viable option for obtaining
space. OARM believes that tasking a
contractor to establish the
supercomputer center was a legally
viable option and that EPA lacked the
legal authority or appropriation to
lease or purchase a building. OARM
also disagreed that the subcontract for
the lease of the building resulted in a
violation of the Antideficiency Act,
since the Agency is not a party to or
bound by the subcontract. A
response to the final report is due by
December 30, 1996.
tack of Oversight Resulted
in Millions of Assistance
Funds Being Misspent
I
Findings In Brief
As a result of EPA's lack of
oversight and failure to implement
requirements for earmarked
assistance agreements, center
objectives were not attained and
millions of dollars were expended
on unauthorized or questionable
projects.
Background
Each fiscal year, EPA receives funds
earmarked by Congress for specific
academic institutions. Between fiscal
1991 and 1995, EPA academic
earmarks (primarily for research)
totaled over $171 million. Although
the Agency normally uses competition
in assistance awards to university
centers to ensure the quality of
recipient staffs and work products,
earmarks are implemented by
establishing centers that fund
individual projects through a
competitive, second-order grant
process.
We Found That
The Agency and/or university had not
fully implemented assistance
agreement requirements that related
to the establishment of a working
second-order grant process for the
center at four of the five university
centers we reviewed. EPA awarded
the earmarked assistance
noncompetitively, as directed by
Congress, but did not always ensure
that university proposals were
consistent with applicable laws, since
key terms and conditions in the
assistance agreements differed
significantly from those for
competitively awarded research
centers. Also, the Agency assigned
insufficient resources to oversee
center operations properly. As a
result, center objectives were not
always attained and $5 million was
spent on questionable projects.
Further, we identified projects at two
Superfund centers that did not relate
to Superfund.
EPA accepted and implemented
nonstatutory earmarks (five of the six
earmarks reviewed were only included
in congressional conference reports)
that had unclear scopes and no
specific authorizing statutes, and
attempted to match them with existing
authorized programs. However,
significant inconsistencies existed
between the earmark awards and the
selected authorizing statute in at least
two instances. In addition, EPA based
earmark awards to one university on
proposals and workplans that were
outside the scope of the applicable
appropriation and authorizing statutes.
As a result, this recipient expended
millions of dollars in EPA assistance
for unauthorized purposes. The
Agency also continued to fund one
earmark, included in an authorizing
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
19
-------
statute, up to $11 million in excess of
the statutory funding limit based on
subsequent nonstatutory earmarked
funding.
EPA elected to use cooperative
agreements for earmarked assistance
awards without the required level of
Agency involvement. Project officers
of the earmarked agreements did not
monitor recipient progress, assess
recipient compliance with agreement
conditions, and ensure proper use of
assistance, largely contributing to the
deficiencies of earmarked recipients.
We Recommended That
The Acting Assistant Administrator for
Administration and Resources
Management, in coordination with
other appropriate Assistant
Administrators:
• Ensure that second-order grant
processes for earmarked centers are
fully implemented.
• Model the structure and
requirements for earmarked centers
after similar competitive centers.
• Seek rescission of earmarks with
unclear scopes and no relevant
authorizing statutes.
• Ensure that authorizing statutes and
recipient proposals are consistent with
the earmark purpose and applicable
appropriation.
• Require project officer involvement
and oversight that matches the
assistance instrument selected and is
sufficient to determine recipient
compliance and proper use of Agency
funds.
What Action Was Taken
The final report (6100313) was issued
to the Acting Assistant Administrator
for Administration and Resources
Management on September 30, 1996.
In responding to the draft report,
Agency officials agreed that
improvements in the management of
earmarked assistance agreements are
needed. Also, the Agency generally
agreed with the intent of our
recommendations and had either
initiated or completed substantive
corrective actions, or agreed to initiate
appropriate actions, in response to the
recommendations. A response to the
final report is due by December 30,
1996.
Sate Source Procurement
Was Improper and Costly
Findings in Brief
EPA awarded a sole source
contract for Geographical
Information System (CIS) software
without adequate support or
justification that cost EPA $1.9
million more than originally
estimated.
Background
The OIG received an allegation that
the Enterprise Technology Services
Division (ETSD), Office of
Administration and Resources
Management, was trying to steer a
purchase of GIS software to the
incumbent contractor and that the
Agency's past GIS software
procurement practices may not have
been cost-effective.
We Found That
EPA awarded a $3.7 million sole
source GIS software contract for ARC-
INFO® without adequate support that
the contractor was the only source
that could satisfy the procurement
requirements. The Agency did not
issue a Request for Comment or
Proposal and other GIS vendors were
not given a chance to compete or to
demonstrate their software products.
The specifications were unduly
restrictive and unnecessary which
inhibited competition. EPA had no
assurance that it acquired the most
cost- and job-effective GIS system
available, especially since the cost
was subsequently increased by $1.9
million to $5.6 million.
In addition, the Agency inappropriately
modified the existing contract to non-
competitively acquire a separate
desktop mapping system called ARC-
VIEW® without adequate justification.
The Agency contended that ARC-
VIEW® was a technical upgrade to
ARC-INFO®. However, the contractor
said they were two separate software
products.
The Agency plans to use a "tier
approach" for the next GIS
procurement which may limit
competition. This approach would
result in a sole source award since the
highest tier could be v/on only by the
incumbent contractor. Further, EPA
does not use benchmarking (live
demonstration testing) to determine
the capability of a software product,
even though it is standard procedure
within the GIS community and all
Federal agencies we contacted use it
as their main technical evaluation tool.
We Recommended That
The Acting Assistant Administrator for
Administration and Resources
Management:
• Direct that all future GIS
procurements follow full and open
competitive procedures, as required
by the Federal Acquisition Regulation.
• Involve the GIS user community in
the procurement process, as
appropriate.
20
OFFICE OF INSPECTOR GENERAL
-------
• Use benchmarking of vendor
products during the procurement
process
What Action Was Taken
The Agency agreed to conduct future
GIS procurements as full and open
competitive procurements and to
include benchmarks. However, the
Agency disagreed that there was
inadequate justification for not
conducting the original procurement to
obtain full and open competition. We
issued our final report (6400096) on
September 18, 1996. An Agency
response to the final report is due by
December 17, 1996.
Hazardous Materials
Grantee Did Not Obtain
Best Prices ar Share
Discounts
Findings In Brief
The Center for Hazardous Materials
Research (CHMR) disregarded
Federal procurement regulations
for all purchases made under two
assistance agreements by not
obtaining adequate competition. In
addition, CHMR did not satisfy
cost sharing of nearly $500,000, as
required by the agreements.
Background
EPA awarded a $1,083,000 grant and
cooperative agreement to CHMR, a
nonprofit entity, for a comprehensive
pollution prevention program in
Pennsylvania, and for testing a system
for removing heavy metals from
contaminated soils and solids.
We Found That
CHMR completed more than 100
procurements valued at about
$500,000 under both agreements.
None of the 50 procurements we
reviewed (totaling $255,000) complied
with Federal regulations or CHMR's
procurement procedures requiring
competitive price quotations or
analysis. Therefore, it appeared that
obtaining a specific contractor was the
priority rather than getting the best
competitive prices. Moreover, CHMR
provided erroneous procurement
certifications to EPA.
In addition, CHMR did not satisfy the
cost sharing requirements for the two
agreements reviewed. As a standard
practice, CHMR used vendor
discounts as their cost share, instead
of extending the benefit to EPA.
Federal regulation specifies that
recipients must credit all purchase
discounts to the government. Further,
CHMR improperly billed EPA for
ineligible meals, entertainment, and
travel under the agreements.
We Recommended That
The Director, Grants Administration
Division:
• Determine whether the prices paid
by CHMR. were reasonable. If this
cannot be determined, EPA should
recover costs for the procurements
awarded under these agreements.
• Instruct CHMR that discounts are
not reimbursable and that benefits
received from discounts must be
credited to EPA.
What Action Was Taken
We issued the final report (6400064)
to the Director, Grants Administration
Division, on June 20, 1996. The
Agency response was due by
September 20, 1996. As of
September 30, 1996, a response had
not been received.
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
21
-------
Financial Management
Over the years, the OIG has
expressed serious concerns about
financial management in EPA.
Historically, EPA did not give
financial management the attention
it needed. In response to these
concerns, EPA has taken a number
of corrective actions. Since the
1994 OIG/Agency review of EPA's
financial management, the OIG has
focused on identifying problems
related to those issues needing
attention to improve financial,
budget, and performance
management in the Agency. During
this reporting period, the OIG
reviewed financial statements for
EPA's trust funds and requirements
under the Chief Financial Officier's
(CFO) Act, and Agency
performance data established
under the Government
Performance and Results Act. We
also reviewed budget and
accounting practices for regional
personnel resources, and
accounting procedures for EPA's
leased real properties. The
following section summarizes the
most significant findings and
recommendations during this
period.
EPA Needs More Reliable
Budgeting and Accounting
Findings in Brief
A pattern of errors in EPA's
budgeting and accounting
practices for personnel resources
made financial management
information unreliable for ensuring
that EPA complied with
congressional intent. As a result,
Agency managers relied on
inaccurate information in
developing budget requests.
Background
The Chief Financial Officers Act of
1990 provides for improved financial
management and internal controls to
ensure accurate, reliable, and timely
financial information. The
Government Performance and Results
Act (GPRA) holds program managers
accountable for program results and
ties program budgeting and spending
to results. EPA is developing a
Planning, Budgeting, and
Accountability system to link strategic
planning, annual performance
planning, budgeting, and performance
reporting.
We Found That
EPA's budget practices and
procedures were generally effective at
the appropriation level and ensured
compliance with statutory
requirements for funds control.
However, the Agency used outdated
workload models to allocate personnel
resources resulting in the regions not
receiving resources where they
planned to use them, nor were
resources reprogrammed by the
regions for their planned needs.
Regional personnel costs were
inaccurately accumulated and
reported. The five regions we
reviewed did not always correctly
charge workyears and personnel
costs to the program element directly
supporting the employee's activities.
We noted significant errors in two of
the regions' charging of personnel
costs causing misstatements used to
develop subsequent program budgets.
For example, Regions 4 and 7
mischarged more than 41.7 workyears
and $2.1 million of management and
support costs to environmental
programs in fiscal 1994. In addition,
Region 4 also mischarged 21.6
workyears and $1.06 million in fiscal
1995.
Although the Agency had
comprehensive reprogramming
procedures, it did not require central
National Program Manager (NPM)
notification for changes to program
budgets for which the NPM had
overall responsibility. Regions
overspent personnel resources for
some programs and underspent for
others, and reconciled the differences
at the end of the fiscal year by
reprogramming personnel resources
to reflect actual spending. We noted
several errors in implementing the
fiscal 1994 and 1995 reprogrammings,
and justifications did not consistently
identify the program impact on the
losing program. These errors
diminished the usefulness of the
related program information. Further,
EPA did not obtain required
congressional approval of one fiscal
1994 reprogramming for $730,000.
The Agency's ad hoc creation of
program elements over time reduced
the consistency and comparability of
budget and financial data for internal
management purposes. Also, EPA
has not developed a common
definition of management and support
activities for consistent accounting and
evaluation of those costs across the
Agency. The current budget structure
cannot efficiently capture the
information required to implement
GPRA because the activities, for
which goals and related measures are
being proposed, do not always align
with existing program elements.
EPA held $53 million in reserve for
contingencies and as fiduciary
reserves in the initial fiscal 1995
operating plan. Of this amount, $28
million, in 11 accounts ranging from
$71,000 to $6.6 million, remained in
reserve at the end of fiscal 1995. The
Budget Division was unable to provide
support that Congress was notified of
the contingency reserves as required
by the Impoundment Control Act. The
Budget Division also was not able to
provide support for the rationale and
methodology for specific reserve
calculations.
22
OFFICE OF INSPECTOR GENERAL
-------
We Recommended That
The Acting Chief Financial Officer
(CFO) ensure that:
• Program budget and cost
information used for budgeting and
performance measurement is
accurate, timely, and useful.
• EPA's budget practices and
procedures address the need for
accurate and reliable program
information, are consistently
implemented, and include controls to
identify procedures not followed.
What Action Was Taken
The final report (6100300) was issued
to the Acting CFO on September 25,
1996. In responding to the draft
report, Agency officials agreed with
most of the recommendations. The
Budget Division has taken actions to
correct some of the procedural
problems. The Agency plans to
redesign the program element
structure as part of its Planning,
Budgeting, and Accountability system
design. A response to the final report
is due by December 26, 1996.
More Decisive Action
Needed in Planning Goals
and Assessing Results
Findings in Brief
Although the Agency has initiated a
results-oriented management
direction to implement
Government Performance and
Results Act (GPRA), EPA still
needs to finalize environmental
goals, develop a clear and
complete mission statement, and
update its strategic plan. In
addition, reliable financial and
performance information was not
always available to manage EPA's
programs effectively.
Background
GPRA was enacted in 1993 to provide
for strategic planning and performance
measurement in the Federal
government. It requires agencies to
develop strategic plans, reach a
reasonable degree of consensus on
desired goals with key stakeholders,
and measure and report progress
toward achieving those goals. EPA
has created a planning, budgeting,
and accountability organization to help
meet the GPRA requirements by
linking long-term environmental
planning, resource management, and
accountability.
We Found That
The Agency's current mission
statement does not clearly establish
Agency-wide direction, guidance, and
focus. Also, the Agency has missed
deadlines for finalizing the National
Environmental Goals and has not
developed Agency goals to effectively
plan, budget for, implement, and
assess the results of its environmental
programs. Finalization of the Goals
has been delayed due to extensive
comments received on drafts, and the
need to obtain agreement from major
stakeholders. The Agency is working
with OMB to clear the goals for full
government review. Finalizing the
Agency's goals and revising its
mission statement are also critical to
the development of the revised
strategic plan that must be submitted
to OMB and Congress by September
30, 1997.
Performance plans for three of EPA's
five GPRA pilots (LUST, Superfund,
and Water) did not include sufficient
means to verify and validate
performance data. Prior OIG audits
have also identified problems with
performance data for these program
areas. For two of the pilots
(Chesapeake Bay and Acid Rain),
EPA managers have developed ways
to verify and validate reported
performance measurement data. In
addition, the Agency terminated its
Program Evaluation Division without
an alternative for obtaining evaluative
information necessary for important
policy and resource decisions.
Program officials participating in the
GPRA performance pilots are tracking
program costs in the Agency's
accounting system by using program
elements which do not provide
accurate and complete cost data for
specific activities. Also, performance
partnership grant recipients are not
required to track funding to specific
media sources, so it is not clear how
the Agency will relate these costs to
Agency goals. Agency officials are
aware that the accounting structure
needs revision to more closely link
budget, plans, and results, and are
planning to make these changes.
We Recommended That
The Assistant Administrator for Policy,
Planning, and Evaluation:
• Finalize and publish the Agency's
National Environmental Goals.
The Acting Chief Financial Officer:
• Revise the Agency-wide strategic
plan to incorporate GPRA
requirements, finalize the Planning,
Budgeting, and Accountability System
and Organization Development Draft
Workplan, and periodically monitor
ongoing efforts to accomplish the
scheduled activities by the targeted
milestone dates.
• Work with the Agency's Chief
Information Officer to issue an
Agency-wide policy requiring GPRA
performance to include a discussion of
how performance data will be verified
and validated, and develop and issue
an Agency-wide policy requiring
managers to conduct program
evaluations when goals are not being
accomplished.
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
23
-------
• Develop and issue Agency-wide
cost accounting policies and
procedures which meet Federal cost
accounting requirements and allow for
the collection of cost information at a
level to support GPRA and CFO Act
requirements.
• In collaboration with the Acting
Assistant Administrator for
Administration and Resources
Management, reevaluate the Agency's
financial reporting requirements for
Performance Partnership Grants to
ensure that states and Tribes are
required to provide the financial
information needed for the Agency to
implement GPRA.
What Action Was Taken
The final report (6100297) was issued
on September 25, 1996. In response
to the draft report, Agency officials
generally agreed with our findings and
recommendations. A response to the
final report is due by December 14,
1996.
Fvrtner Improvements
Nseaecl In Financial
Reporting
I
Findings in Brief
During fiscal 1995, EPA continued
to make improvements in its
financial systems and processes.
However, some remaining
weaknesses continue to prevent us
from issuing unqualified opinions
on all of the Agency's financial
statements.
Background
The Chief Financial Officers (CFO)
Act of 1990 requires EPA to prepare
financial statements for the Superfund,
Leaking Underground Storage Tank
(LUST), and Oil Spill Trust Funds, the
Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) and
Tolerance Revolving Funds, and the
Asbestos Loan Program. The CFO
Act also requires the Inspector
General, or an independent public
accounting firm selected by the
Inspector General, to audit the
financial statements.
We Found That
Following are the results of our work
related to the fiscal 1995 financial
statements for these funds.
Superfund Trust Fund. We
disclaimed an opinion on the financial
statements primarily due to
weaknesses in the areas of
accounting for property, components
of net position, reimbursable
Superfund oversight costs, grants
funded from more than one
appropriation, and expenses to show
the full cost of the fund. In addition,
grantees are not required to provide
EPA with information on the amount of
expenses they have incurred, but for
which they have not requested
reimbursement by September 30.
Therefore, we could not assess the
reasonableness of EPA's estimate of
accrued liabilities for grantee
expenses.
LUST Trust Fund. We qualified our
opinion on the Statement of Financial
Position because we could not assess
the reasonableness of EPA's estimate
of accrued liabilities for grantee
expenses. We disclaimed an opinion
on the Statement of Operations and
Changes in Net Position because we
could not assess the reasonableness
of EPA's estimate of accrued liabilities
for grantee expenses, and because of
weaknesses in the area of allocating
expenses to show the full cost of the
fund.
Oil Spill Trust Fund. We disclaimed
an opinion on the financial statements
primarily due to weaknesses in the
areas of contractor-held equipment,
grants funded from more than one
appropriation, and allocating expenses
to show the full cost of the fund. In
addition, we could not assess the
reasonableness of EPA's estimate of
accrued liabilities for grantee
expenses.
Asbestos Loan Program. In our
opinion, the Statement of Financial
Position is fairly presented. We
qualified our opinion on the Statement
of Operations and Changes in Net
Position due to weaknesses in the
area of allocating expenses to show
the full cost of the loan program. We
qualified our opinion on the Statement
of Operations and Changes in Net
Position because the allocation of
expenses is less significant for the
Asbestos Loan Program than it is for
the other audited funds.
FIFRA Fund. In our opinion, the
Statement of Financial Position is
fairly presented. We disclaimed an
opinion on the Statement of
Operations and Changes in Net
Position due to weaknesses in the
area of allocating expenses to show
the full cost of the fund.
Tolerance Fund. In our opinion, the
Statement of Financial Position is
fairly presented. We disclaimed an
opinion on the Statement of
Operations and Changes in Net
Position due to weaknesses in the
area of allocating expenses to show
the full cost of the fund.
Material Internal Control
Weaknesses
Superfund Oversight Costs. The
Agency does not record as assets
Superfund oversight costs recoverable
from potentially responsible parties
until billings are prepared. Our audit
work in Regions 3, 5, 6 and 9
identified $6.7 million in reimbursable
oversight costs for 37 active sites that
were not recorded as assets. The
understatement could be considerably
higher if oversight costs for all active
sites in all regions were analyzed.
Property. Further improvements are
needed in accounting for the Agency's
property. We found leases that had
24
OFFICE OF INSPECTOR GENERAL
-------
not been capitalized, inventories had
not been completed at some locations,
and some contractors did not provide
reports on the value of EPA property
in their possession. In addition, we
found items that had not been
recorded in the Agency's Personal
Property Accountability System
(PPAS), and differences existed
between the PPAS and the Integrated
Financial Management System values
for capitalized property.
Grant Payments. EPA makes
payments for grants funded from more
than one appropriation using a first-in
first-out (FIFO) method when it does
not have information from the recipient
showing which appropriation
benefitted from the work performed.
Under this method, the oldest
available funding is used first
regardless of which appropriations
benefitted from the work performed
under the grant. This could result in a
material misstatement of expenses for
the Agency's various appropriations.
Expense Allocation. As required by
the Office of Management and
Budget, EPA allocates expenses from
its other appropriations to its various
funds to show the full cost of these
funds. In reviewing these allocations,
we found that the information
documenting decisions made was
minimal. Input on how costs should
be allocated was obtained from only
one Headquarters program office and
none of the regional offices. Policies
and procedures identifying which
costs should be allocated and the
affected funds had not been
formalized.
Superfund Net Position. The
components of Superfund net position
continued to be unreconcilable.
Historically, accounting transactions
for the Superfund Trust Fund were
processed in a manner consistent with
accounting for appropriated authority.
Thus, when finance officials recorded
various transactions for non-
appropriated budget authority, the
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
affected relationships that should exist
between the components of net
position were distorted.
We Recommended That
The Acting Chief Financial Officer
(CFO):
• Implement policies and procedures
to accrue Superfund reimbursable
oversight costs.
• Expedite the revision of the
Agency's capitalization procedures,
and value all capitalized property at
historical cost to the extent possible.
• Obtain a legal opinion from the
Office of General Counsel on whether
it is proper to use the FIFO grant
disbursement method, and if it is,
whether adjustments are needed at
year-end, and use the opinion to
implement policies and procedures for
accounting for grant disbursements.
• Develop policies and procedures for
the expense allocation performed to
show the full cost of funds and obtain
input from regional and Headquarters
program offices to help ensure that
expenses are accurately and
consistently allocated, and complete
the necessary analyses and
reconciliations of accounts, so the
components of net position are
auditable.
The Acting Assistant Administrator for
Administration and Resources
Management:
• Ensure that annual physical
inventories of capitalized property are
completed.
• Ensure that property accountable
officers timely and accurately record
capitalized property in the PPAS.
• Ensure that Agency contractors
timely submit annual inventory reports.
What Action Was Taken
The final report (6100200) was issued
on May 3, 1996. In response to our
final report, the Acting CFO concurred
with most of our report
recommendations or identified
alternative corrective actions that EPA
would take to resolve the issues
discussed in the report. However, on
three of the above issues
(components of net position,
payments for grants funded from more
than one appropriation, and EPA's
expense allocation method), we
expressed concerns to the Acting
CFO about the failure to provide
milestones for completing corrective
actions. We are continuing to work
closely with the Acting CFO's staff on
these matters. Additionally, the OIG
initiated special projects to work with
EPA officials on making improvements
in two areas, property and the
expense allocation process, which
should help EPA reach its goal of
receiving an unqualified opinion on the
Superfund financial statements.
froproper Aceoiiritfng for
Rml Property Distorts
Financial Statements
Findings In Brief
Although the Agency made
progress in accounting for
buildings it owns, it overstated
depreciation, may not have
correctly accounted for leased real
property, and did not perform
lease-versus-buy comparisons for
all leases. As a result, the Agency
prepared inaccurate financial
statements and missed
opportunities to save millions of
dollars.
Background
The OIG performed this audit at the
request of the Acting Chief Financial
Officer.
25
-------
We Found That
Fiscal 1995 was the first year EPA
showed the value of its buildings in its
financial statements. However, by
applying an arbitrary 25 year useful
life to all of its buildings rather than
evaluating the useful lives of each
building, the Agency overstated the
accumulated depreciation for the 46
buildings in our sample by $19 million.
Future financial statements will
understate the value of EPA's real
property and give the appearance that
EPA uses fewer resources to
accomplish its mission annually than it
actually needs.
The Agency could not be sure it
accounted for its leased real property
correctly because it did not apply OMB
criteria for categorizing operating or
capital leases. We applied the OMB
criteria to six of EPA's real property
leases and found that EPA needed to
reclassify at least one with an
unrecorded value of $10.8 million.
Agency personnel did not perform
lease-versus-buy comparisons for four
leases because they believed that
only leases requiring congressional
approval needed a lease-versus-buy
analysis, and that they could not get
the necessary funding to construct a
building. Although the four leases fell
below criteria that specifically required
such an analysis, three fell within
OMB suggested criteria for doing an
analysis. Without doing the
comparisons to obtain the lowest cost
method of acquisition, EPA is missing
opportunities for significant savings.
EPA may have saved over $3.9 million
by purchasing rather than leasing one
building.
Performance
Indicators
-Number of teis&versu&buy
comparisons
- Dollars savedtost
We Recommended That
The Acting Assistant Administrator for
Administration and Resources
Management:
• Provide the Acting Chief Financial
Officer with revised building useful life
estimates.
• Ensure that supporting
documentation for each real property
lease provides information needed for
proper lease classification.
• Perform applicable lease-versus-
buy analyses.
The Acting Chief Financial Officer:
• Recalculate accumulated
depreciation for all buildings based on
revised useful life estimates and make
any needed adjustments to accounting
records.
• Reclassify one lease from an
operating lease to a capital lease, and
evaluate the lease category of all real
property leases and make any needed
^classification and accounting
adjustments.
What Action Was Taken
The flash report (6400066) was issued
to the Acting Chief Financial Officer
and the Acting Assistant Administrator
for Administration and Resources
Management on July 1,1996. In
responding to our report, they stated
that they generally agreed with our
recommendations and have begun to
take action to resolve these issues.
However, the Agency is evaluating the
practicality of applying the proposed
policy on real property leases to
existing leases.
26
OFFICE OF INSPECTOR GENERAL
-------
Construction Grants
Since EPA was established, the
construction grants program has
been one of its largest and most
successful undertakings. The
program was established under the
provisions of Public Law 92-500, as
amended, and has provided over
$52 billion in financial assistance to
thousands of communities all over
the country. The Agency is now in
the process of completing the
construction grant program. The
goal is to substantially close out
the program by September 30,
1997. Fiscal year 1990 was the last
year funding was authorized for the
program.
The Agency developed, in
consultation with the OIG, a
Completion/Close-Out Strategy for
the program. The goal of the
Agency's strategy is to bring the
program to a successful
completion as expeditiously as
possible to assure that the
environmental benefits of the
program are fully realized and its
fiscal and technical integrity are
protected.
To assist the Agency in this effort,
the OIG, in consultation with the
Agency, implemented a revised
audit strategy in October 1994 that
focuses effort on the most
vulnerable grants, based on a risk
analysis of each remaining grant
subject to audit. As of September
30,1996, there were 239 grants
valued at $4.1 billion which are
expected to receive OIG review
during the next two and a half
years. Summaries of some audits
of construction grants with
significant issues follow.
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
27
-------
1184 Million of Questioned
Costs Claimed for San
Francisco ftrojesfe
Findings in Brief
The City and County Of San
Francisco, California, claimed $19.9
million of ineligible architectural
engineering costs, project costs
allocable to other Federal facilities,
and costs outside the scope of the
approved project for the design and
construction of wastewater
treatment facilities. An additional
$164.2 million of unreasonable
costs were questioned.
We Found That
EPA awarded San Francisco nine
construction grants totaling
$414,711,579 for the design and
construction of wastewater treatment
facilities pertaining to the Southwest
Ocean Outfall Project, the Southeast
Water Pollution Control Plant, the
Oceanside Water Pollution Control
Plant, and Bayside pump stations,
force mains, and outfall consolidation
projects. The grantee claimed
$19,907,586 of ineligible costs under
the grants, including:
• $7,328,179 of construction,
engineering, and other costs
that were outside the scope of the
approved project;
• $6,868,100 of construction,
engineering, and other costs
claimed in excess of the State Water
Resources Control Board's approved
amount;
• $3,040,102 of engineering and other
costs allocable to the ineligible portion
of the projects;
• $2,467,345 of construction,
engineering, and other costs
allocable to Federal facilities; and
• $203,860 of engineering overhead
costs claimed in excess of the
incurred amount.
We also questioned as unreasonable
$164,198,771 of project costs related
to underused facilities. Although the
Southwest Ocean Outfall Project
(SWOOP) and the Oceanside Water
Pollution Control Plant were designed
with a 450 million gallons per day
capacity, only 5 percent of the
capacity was being used due to a
failure to construct a Crosstown
Transport Project to convey
wastewater effluent to SWOOP.
We Recommended That
The Regional Administrator, Region 9,
not participate in the Federal share of
ineligible costs ($13,465,054), assess
the grant eligibility of the Federal
share of the unreasonable costs
($123,149,078), and recover the
applicable amount from the grantee.
What action was taken
Two audit reports (6200011 and
6200014) were issued to the Regional
Administrator, Region 9, on May 30
and July 16, 1996. Responses were
due by August 30 (6200011) and
October 15, 1996 (6200014). As of
September 30, 1996, a response to
6200011 had not been received.
Over $18 Mi (lion of
Questioned Casts Claimed
by WSSO
Findings in Brief
The Washington Suburban Sanitary
Commission (WSSC) claimed
$7,481,336 of ineligible
construction, engineering, and
administrative costs for
modifications to wastewater
treatment facilities. An additional
$10,723,814 of unreasonable and
unsupported costs v/ere
questioned.
We Found That
EPA awarded two construction grants
totaling $45,053,170 to WSSC for the
construction of modifications to the
existing facility to provide an advanced
wastewater treatment plant, and
additions to the Western Branch
wastewater treatment plant for
additional solids and liquid handling
facilities. WSSC claimed $7,481,336
of ineligible costs under the grants,
including:
• $3,837,980 of administrative and
architectural engineering fees incurred
prior to the grant award or after the
contract/construction completion date;
• $1,596,524 of indirect costs applied
to ineligible force account costs;
• $1,553,923 of construction costs
claimed in excess of the eligible bids
and change orders;
• $345,733 of engineering costs that
exceeded the engineering agreement
upset limits;
• $147,175 of costs outside the scope
of the project, force account costs
which duplicated services provided by
the construction management
engineer, and costs applicable to
ineligible portions of the project.
We also questioned as unsupported
$8,897,656 of construction change
orders that had not received an
eligibility determination, delay costs
that could not be verified, and
miscellaneous costs for which the
grantee could not provide
documentation. Additionally, we
questioned $1,826,158 as
unreasonable costs related to facility
segments and equipment that had
been abandoned.
28
OFFICE OF INSPECTOR GENERAL
-------
We Recommended That
The Regional Administrator, Region 3,
not participate in the Federal share of
ineligible costs ($6,189,595),
determine the eligibility of the Federal
share of unsupported and
unreasonable costs ($7,566,823), and
recover the applicable amount from
the grantee.
What Action Was Taken
We issued the final reports (6300037
and 6300038) to the Regional
Administrator, Region 3, on
September 23, 1996. A response to
the audit reports is due by November
5, 1996.
Over $11 Million of
CHresf fotra
-------
ineligible costs under the grants,
including:
• $1,891,750 in salvage value for
tunnel boring equipment purchased
under the grant but which had not
been offset against the grant
expenses;
• $966,624 for ineligible construction
costs; and
• $623,444 of engineering costs that
were outside the scope of the
approved project.
We also questioned $7,102,524 of
unsupported planning and force
account costs that were not supported
by source documentation.
We Recommended That
The Regional Administrator, Region
10, not participate in the Federal share
of ineligible costs ($1,915,000),
determine the grant eligibility of the
Federal share of unsupported costs
($5,210,026), and recover the
applicable amount from the grantee.
What Action Was Taken
We issued the final audit report
(6300024) to the Regional
Administrator, Region 10, on July 8,
1996. A response to the audit report is
due by October 8, 1996.
Hearty $0 Million of
Questioned Costs Claimed
for Baltimore Projects
Findings in Brief
Baltimore, Maryland, claimed
$8,331,723 of ineligible
construction, engineering, and
administrative costs for
improvements at a wastewater
treatment facility. An additional
$499,744 of unsupported costs
were questioned.
We Found That
EPA awarded Baltimore, Maryland,
two construction grants totaling
$31,673,100 for the construction of
filtration and nitrification facilities at the
Back River Wastewater Treatment
Plant. The grantee claimed
$8,331,723 of ineligible costs under
the grants, including:
• $6,023,745 of construction costs
that exceeded eligible bid and change
order amounts;
• $1,151,958 of administrative,
engineering, and construction costs
allocable to ineligible portions of the
projects, and indirect costs that were
not supported by an indirect cost rate
agreement;
• $499,922 for costs applicable to an
indexing factor where the grantee did
not reduce its claim to account for
incremental costs due to delays in
awarding subagreements more than
12 months after the grant award;
• $447,408 for costs incurred after the
approved cutoff dates, and
miscellaneous unallowable
administrative and engineering costs;
• $208,690 of engineering costs that
exceeded the engineering agreement,
and costs determined to be outside
the scope of the project or normal
operating expenses not allocable to
the grants.
In addition, we questioned $499,744
of unsupported engineering and
construction costs.
We Recommended That
The Regional Administrator, Region 3,
not participate in the Federal share of
ineligible costs ($6,248,792),
determine the eligibility of the Federal
share of unsupported costs
($374,808), and recover the applicable
amount from the grantee.
What Action Was Taken
The final reports were issued to the
Regional Administrator, Region 3, on
August 19 (6300027) and September
3, 1996 (6300033). Responses to the
audit reports are due by October 21
and November 6, 1996, respectively.
30
OFFICE OF INSPECTOR GENERAL
-------
Section 2 -- Report Resolution
As required by the Inspector
General Act, as amended, this
section contains information on
reports in the resolution process
for the semiannual period. This
section also summarizes OIG
reviews of the Agency's follow-up
actions on selected reports
completed in prior periods. In
addition, information is presented
on the resolution of significant
reports issued by the OIG involving
monetary recommendations.
Current Period
As of September 30, 1996, EPA had
218 OIG reports requiring resolution,
which was one more than the
beginning balance of 217 reports six
months ago. The number of past due
responses (over six months from
report issue date) dropped 13 percent
from 126 to 110 during this six-month
reporting period. At the end of March
1996, the number of past due
responses was 58 percent of the
reports to be resolved compared to 50
percent of the reports in the follow-up
system as of the end of this reporting
period. The costs questioned on the
OIG reports for which management
decisions were past due as of
September 30, 1996, represented 41
percent of total questioned costs to be
resolved. This represents a 42
percent decrease from the March
1996 report.
These reports need to be resolved
and the funds recovered more
expeditiously. While the OIG
recognizes that it takes time to reach
a management decision on some
reports, swift, appropriate resolution
allows the government to run better
and saves taxpayers the added cost of
financing Agency operations through
borrowing.
As of September 30, 1996, Agency
management has made no decision
on over 70 percent (61 of 87) non-
preaward reports over one to nine
years old. Two EPA offices-Office of
Acquisition Management and Grants
Administration Division-accounted for
55 percent (48 of 87) on which no
management decision had been
made.
About 21 percent (23 of 110) of the
past due reports were preaward
audits. This is a 43 percent
improvement over the previous 12-
month period. EPA is one of the few
agencies that reports on resolution of
audits conducted on preaward
contract proposals. There may be
multiple pre-award audits for any
particular EPA contract solicitation.
Resolution of these audits occurs
when the contracting officer makes
the contract award. When lengthy
negotiations are required or when
there is a series of proposals required
from the contractor, it is common for
these audits to remain in the
"unresolved" pre-award stage for
longer than 180 days. It is, therefore,
crucial for EPA to take every step
possible to ensure that pre-award
audits are resolved quickly.
Trends
Analyses of the Agency's unresolved
reports from March 31, 1994 (94 -1)
through September 30, 1996 (96-2)
show that the percentage of reports
180 days past due has remained
constant. Currently, these reports
represent 50.4 percent of reports
needing resolution compared to 49.8
percent three years ago. However,
the percentage of questioned costs of
these reports has dropped to an all-
time low of 41.5 percent as of
September 30, 1996. Three years
ago, the questioned costs of the past
due reports needing resolution was 84
percent. Therefore, it appears that
EPA management is actively pursuing
resolution of the audits with the
highest amount of questioned costs.
(See graph below)
We encourage EPA to resolve all
audits timely. Only through diligent,
timely followup action can
deficiencies noted in audit reports be
corrected and more responsible
recovery of funds be made.
Comparison of Unresolved Reports and Related Costs Questioned
(Past the 180-Day Time Frame for Resolution)
100%
80%
60%
94-1
94-2
95-1
95-2
96-1
96-2
% Questioned Costs
% Over 180 Days
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
31
-------
Status Report On Perpetual Inventory of Reports in Resolution Process For The Semiannual Period Ending
September 30,1996 (Dollar Values in Thousands)
Number
A. For which no management decision
has been made by the commencement
of the reporting period 217
B. Which were issued during the
reporting period 248
C. Which were issued during the
reporting period that required
no resolution 126
Subtotals (A + B - C) 339
D. For which a management decision
was made during the reporting
period 121
E. For which no management decision
decision has been made by the end
of the reporting period 218
Reports for which no management
decision was made within six months
of issuance 110
Report Issuance
Questioned Recommended
Costs Efficiencies
Report Resolution
Costs Sustained
To Be As
Recovered Efficiencies
159,891
180,590
0
340,481
308,551
128,046
186,776
17,207
0
203,983
31,930 141,561
17,694
12,320
62,422
45,662
* 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,
Status of Management
Decisions on IG 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. In order to provide
uniformity in reporting between the
various agencies, the President's
Council on Integrity and Efficiency
issued guidance on reporting the costs
under required statistical tables of
sections 5(a)(8) and (9) of the Act, as
amended.
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 counted were performed by
other Federal auditors or independent
public accountants under the Single
Audit Act. EPA OIG staff does not
manage or control such assignments.
In addition, amounts shown as costs
questioned or recommended to be put
to better use contain amounts which
were at the time of the review
unsupported by adequate
documentation or records. Since
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
will not be sustained.
EPA OIG controlled reports resolved
during this period resulted in $49.2
million being sustained out of $56.8
million considered ineligible in reports
under OIG control. This is an 87
percent sustained rate.
32
OFFICE OF INSPECTOR GENERAL
-------
Table 1 - Inspector General Issued Reports With Questioned Costs
Semiannual Period Ending: September 30, 1996
A. For which no management decision has been made by
the commencement of the reporting period**
B. New Reports issued during period
Subtotals (A + B)
C. For which a management decision was made during
the reporting period
Number
88
39
127
39
Dollar Value in thousands
Questioned Unsupported
Costs*
159,891
180,590
340,481
31,930
Costs
67,322
17,356
84,678
14,166
(i) Dollar value of disallowed costs
(ii) Dollar value of costs not disallowed
D. For which no management decision has been made by
the end of the reporting period
Reports for which no management decision was
made within six months of issuance
30
22***
88
58
17,694
14,236
308,551
128,046
1,910
12,256
70,512
53,156
Questioned costs include the unsupported costs.
Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this
report and our previous semiannual report results from corrections made to data in our audit tracking system.
9 audit reports totaling $1,059 were not agreed to by management.
Audit Followup
Oilier Actions ir> Response
toi®r6 Reports
The OIG's reports and cooperative
efforts with program officials frequently
have positive results that reach beyond
the implementation of specific report
recommendations. These results are
not normally verified by formal OIG
followup reviews. For example, during
this reporting period the OIG learned
that an OIG report, Environmental
Data Quality at POD Superfund Sites
in Region 9. issued on September 26,
1995, is being used by the State of
California to reshape its laboratory
quality system. The State formed a
quality action team as a result of major
laboratory fraud, and the team's
mission is to improve the State's ability
to detect and deter laboratory fraud
and avoid making decisions based on
faulty analysis. The State team is
planning on using many of the OIG's
recommendations to improve its
programs resulted by laboratory
analysis. The OIG report was also
used by the U.S. Army Corps of
Engineers to improve its national
guidance for laboratory data quality.
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
33
-------
Table 2 - Inspector General Issued Reports With Recommendations That Funds Be Put To Better Use
Semiannual Period Ending: September 30,1996
Dollar Value
Number (in thousands)
A.
B.
C.
D.
For which no management decision has been
made by the commencement of the reporting period*
Which were issued during the reporting period
Subtotals (A + B)
For which a management decision was made during
the reporting period
(i) Dollar value of recommendations that
were agreed to by management
- based on proposed management action
- based on proposed legislative action
(ii) Dollar value of recommendations that were not
agreed to by management
(Hi) Dollar value of non-awards or unsuccessful
bidders
For which no management decision has been made by
the end of the reporting period
Reports for which no management decision was
made within six months of issuance
28
13
41
14
6
n/a
n/a
6**
5
27
15
186,776
17,207
203,983
141,562
12,320
n/a
n/a
127,853
1,384***
62,422
45,662
* 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.
** Six reports were included in C(i) and C(ii). Only the related dollars disallowed were included in C(i), whereas the
dollars which were not disallowed were included in C(ii).
*** This amount represents the dollar value of recommendations that funds be put to better use.
34 OFFICE OF INSPECTOR GENERAL
-------
Resolution of Significant Reports
Report Number
Report Issuance
FS Questioned/
Recommended
Report Resolution
Federal Share
to be Recovered/
Sustained
Efficiency
D9AGL5-01-0180 NOB IS ENGINEERING NH
6100067
REPORT DATE 11/28/95
P2CWL3-02-0128 HUDSON COUNTY UA NJ
5100231
REPORT DATE 3/28/95
P2CWL4-02-0198 WESTCHESTER CO
6100076 MAMARONECK NY
REPORT DATE 12/ 6/95
D9AKL5-06-0054 BROWN & ROOT
6100071 ENVIRONMENTAL TX
REPORT DATE 11/29/95
D9AGL5-08-0055 CH2MHILL INC CO
6100075
REPORT DATE 12 / 2/95
E2CWM4-09-0092 LOS ANGELES CITY
6200002 CA
REPORT DATE ll/ 7/95
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
0
0
0
2,388,583
0
13,064,288
0
0
1,647,757
0
0
0
0
0
0
10,586,670
0
0
0
3,874,743
10,487,352
0
0
0
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
0
0
0
2,144,912
0
1,723,932
0
0
1,634,744
0
0
0
0
0
0
5,040,731
0
0
0
3,874,743
9,989,214
0
0
0
NOTE:
INEL
UNSP
UNUR
RCOM
SUST
INELIGIBLE COST
UNSUPPORTED COST
UNNECESSARY/UNREASONABLE COST
RECOMMENDED EFFICIENCIES
RECOMMENDED EFFICIENCIES SUSTAINED
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
35
-------
Section 3 -- Prosecutive Actions
The following is a summary of
investigative activities during this
reporting period. These include
investigations of alleged criminal
violations which may result in
prosecution and conviction,
investigations of alleged violations
of Agency regulations and policies,
and OIG personnel security
investigations. The Office of
Investigations tracks
investigations in the following
categories: preliminary inquiries
and investigations, joint
investigations with other agencies,
and OIG background
investigations.
Summary Of Investigative
Activities
Pending Investigations as
of March 31, 1996 181
New Investigations
Opened This Period 45
Investigations Closed
This Period 71
Pending Investigations as
of September 30, 1996 155
Prosecutive and
Administrative Actions
In this period, investigative efforts
resulted in 6 convictions and 10*
indictments. Fines and recoveries,
including those associated with civil
actions, amounted to $1.6 million.
Twelve administrative actions** were
taken as a result of investigations.
Reprimands 6
Resignations/Removal 3
Reassignments 1
Restitutions 2
TOTAL 12
* Does not include indictments obtained in
cases in which we provided investigative
assistance.
** Does not include suspensions and
debarments resulting from Office of
Investigations activities or actions resulting
from reviews of personnel security
investigations.
Profiles of Pending Investigations by Type
General EPA Programs
Total Cases = 103
44
Superfund/LUST
Total Cases = 52
30
11
[^Construction •Procurement Fraud ^Employee Integrity
K Prog ram Integrity K Other
36
OFFICE OF INSPECTOR GENERAL
-------
Description of Selected
Prosecutive and
Administrative Actions
Below is a brief description of some
of the prosecutive actions which
occurred during the reporting period.
Some of these actions resulted from
investigations initiated before
April 1, 1996.
Engineering Firm
J
On April 15,1996, Tenney Pavoni
Associates, Inc. (TPA), a Midwest
engineering firm, was fined $474,048
and ordered to pay restitution of
$372,771. On April 4, 1996, TPA
vice-president Gary T. Boblitt was
sentenced to three years probation,
fined $2,000, and ordered to pay
restitution of $19,463 and a special
assessment of $50. In February
1995, TPA was charged with
submitting false and inflated claims to
the EPA for its engineering and
inspection services on the
construction of a nitrification project
through the Hammond, Indiana,
Sanitary District, and to the U.S.
Department of Transportation on a
federally-funded bridge project in
Hammond, Indiana. Boblitt was
charged with and pleaded guilty to
filing a false and inflated claim to the
Hammond Sanitary District, which
was submitted to EPA for
reimbursement.
TPA was the primary engineering firm
on over $17 million of EPA-funded
grant work at the Hammond Sanitary
District, Hammond, Indiana.
According to the criminal information,
Mark W. Tenney, chief executive
officer, and Joseph L. Pavoni,
company president, established
policies and practices which resulted
in the falsification of time sheets to
reflect inflated hours worked by their
employees on cost-reimbursement
contracts that TPA received from EPA
and the U.S. Department of
Transportation. Further, the
information charged that persons
supervised by Tenney and Pavoni
reviewed time sheets of engineers
and others and also boosted the
amount of hours reflected for these
government contracts, resulting in the
company submitting invoices seeking
payment for work that had not been
performed. Vice-president Gary T.
Boblitt was charged with submitting
an inflated invoice to the Hammond
Sanitary District.
As previously reported, Mark W.
Tenney pleaded guilty of making a
false claim and aiding and abetting.
He was sentenced to five months
incarceration, five months home
detention, 300 hours of community
service, restitution of $372,771, a fine
of $250,000, and a special fee of $50.
Joseph L. Pavoni pleaded guilty of
making a false claim and was
sentenced to three years probation,
500 hours of community service,
restitution of $372,771, a fine of
$250,000 and a special fee of $50.
The restitution of $372,771 and fine of
$250,000, were imposed jointly and
severally on co-defendants Mark
Tenney, Joseph Pavoni and TPA.
This case was investigated jointly by
the EPA OIG, FBI, and the
Department of Transportation OIG.
Florida Export Company
Anil Official Sentenced
On July 11,1996, Marman USA, Inc.
(Marman), a Florida pesticide export
company, and its vice president,
Robert T. Renes, were sentenced
after each pleaded guilty to charges
of forging a government seal. The
corporation was sentenced to two
years probation, a fine of $350,000,
and a special assessment of $1,200.
Renes was sentenced to three years
probation, a fine of $150,000, and a
special assessment of $300.
Marman falsified documentation that
was included in a package submitted
for a pesticide product registration in
Ecuador, along with notarized
documents signed under the official
seal of the EPA, with the signatures of
EPA employees. Renes asked a
Marman employee to sign the name
of an EPA employee on certificates of
registration and sign certificates of
chemical analysis, although she was
not a chemist. Another employee
signed illegible names to certificates
of origin, and Renes told him to use
rubber stamps from Chambers of
Commerce in England on these
certificates, which were then sent to
Latin American countries.
This case was investigated by the
EPA OIG with the assistance of the
EPA Criminal Investigations Division
and the U.S. Customs Service.
Training Provider Guilty of
'"'' "leases-
On July 15,1996, Robert G. Cooley,
former owner and operator of I.P.C.
Chicago, Inc., a business authorized
to provide certified asbestos
abatement training, pleaded guilty to
mail fraud. In June 1996, Cooley was
charged with defrauding the Illinois
Department of Public Health (IDPH)
and EPA by selling training
certificates to workers and
contractors, without requiring class
attendance. These certificates were
used to obtain the initial and renewal
state licenses to work on various
state and federally-funded projects,
including asbestos abatement
projects in public schools. Depending
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
37
-------
on the course, Cooley charged $75 to
$550 for the training certificates.
Federal laws and regulations require
workers who remove asbestos from
schools and other public buildings to
be accredited and delegate the
authority to states to administer the
training programs. Before students
receive a state license in the form of a
photo identification card, IDPH
requires the private trainers to provide
a list of students completing the
courses and the students to submit
the certificates.
This investigation was conducted
jointly by the EPA OIG, the FBI, the
General Services Administration OIG,
and the EPA Criminal Investigations
Division.
EPA Employee Spouse
Guilty of
-I;
On July 31,1996, Gregory
Chambers, the spouse of an EPA
employee, pleaded guilty of
intentionally using a government
credit card to make unauthorized
charges at different retail stores
totaling $3,039. Chambers was
indicted in June 1996, after the
investigation revealed that he made
14 unauthorized charges to an EPA
Government bankcard. Chambers
admitted that he had stolen the
bankcard from the desk of his wife in
early December 1995.
This investigation was conducted
jointly by the EPA OIG and the U.S.
Secret Service.
J
On May 2,1996, William Foss,
president of Loyalty Environmental,
Inc. (Loyalty), of Skokie, Illinois, a
private company engaged primarily in
asbestos abatement, was indicted for
conspiracy and making false
statements. Also charged were Mark
Zander, a Loyalty estimator and
salesman; Michael Cahill, an
estimator and salesman employed by
Eau Claire Mechanical Insulation of
Orland Park, Illinois; and David
Shewmake, an insurance agent from
Crestwood, Illinois.
In 1991, under the Asbestos School
Hazard Abatement Act (ASHAA),
EPA approved the spending of
Federal funds by the Chicago Board
of Education for asbestos abatement
at Kennedy High School in Chicago.
The Chicago Board of Education
solicited bids from contractors to
perform the abatement, including
required bid bonds. Bid bonds
accepted by the Chicago Board of
Education were frequently
accompanied by a power of attorney
certifying that an agent of the surety
was authorized to commit the surety
to the promises made in the bid bond.
In March 1991, the Chicago Board of
Education accepted Loyalty's bid of
$1,290,132, but the bid package did
not include a bid bond. In May 1991,
a second round of bids were
accepted on the same job, including
one from Loyalty of $1,444,015. The
indictment charged that Loyalty's bid
package contained a fraudulent bid
bond and power of attorney.
The indictment charges that David
Shewmake obtained a power of
attorney form reflecting authorization
of a bid bond on behalf of Indiana
"Lumberman's" Mutual Insurance
Company and an embossing device
bearing the name of the insurance
company from a local printer. It is
further charged that Mark Zander
signed the fraudulent documents with
the fictitious name "George McLena"
as an authorized representative of the
insurance company along with
William Foss.
This investigation was conducted by
the EPA OIG.
Contractor Employee
cted for Soliciting
On September 24,1996, Keith
McCullough, a contractor employee in
EPA Region 3, was indicted for
allegedly soliciting a kickback related
to a government contract. According
to the indictment, McCullough entered
into an agreement with Cabletron
Systems, Inc., Rochester, New
Hampshire, for a ten-percent kickback
on the value of a Local Area Network
contract that he would facilitate EPA's
awarding to Cabletron. McCullough
was an employee of Management
Technology, Inc., which was
contracted by General Services
Administration to run the computer
room in EPA Region 3.
This investigation was conducted
jointly by the EPA OIG and the FBI.
Corporate President
Pleads Guilty to
On April 19,1996, Robert Feller,
president of Non Hazardous
Incineration (NHI), a non-hazardous
waste broker in the state of New
Jersey, pleaded guilty to conspiracy
38
OFFICE OF INSPECTOR GENERAL
-------
to create and distribute a phony EPA
approval letter.
Under EPA regulations, once the date
of transdermal nicotine patches
expires, they are classified as
hazardous wastes and cannot be
sold. Feller knew that one of NHI's
major clients produced transdermal
nicotine patches and attempted to
persuade several people at the EPA
to reclassify the patches as non-
hazardous waste. When EPA
refused Feller's request, Feller
conspired to create and distribute a
phony EPA letter stating that
transdermal nicotine patches were
not classified as hazardous wastes.
This case was investigated by the
OIG Office of Investigations.
Civil and Administrative
Actions to Recover EPA
Funds
Investigations and audits conducted
by the Office of Inspector General
provide the basis for civil and
administrative actions to recover
funds fraudulently obtained from EPA.
Through the Inspector General
Division (IGD) of the Office of General
Counsel (OGC), the OIG uses a
variety of tools to obtain restitution.
These include cooperative efforts with
the Department of Justice in filing civil
suits under the False Claims Act, the
Program Fraud Civil Remedies Act,
and other authorities; working with
grantees using their own civil litigation
authorities; invoking the restitution
provisions of the Victim and Witness
Protection Act during criminal
sentencing; using the Agency's
authority to administratively offset
future payments and to collect debts;
and negotiating voluntary settlements
providing for restitution in the context
of suspension and debarment
actions. Civil and administrative
actions to recover funds usually
extend over several semiannual
reporting periods.
Former ERGS Contractor
Agrees to $589,000
Settlement
On May 6, 1996, OHM Remediation
Services, a former EPA Emergency
Response Cleanup Service (ERCS)
contractor, agreed to pay $589,000
as part of a civil settlement with the
government. This agreement was
reached after an investigation on
information that OHM and some of its
subcontractors had allegedly double-
billed and overbilled costs relative to
the cleanup at the Fike Superfund
Site in Nitro, West Virginia. Waste-
Tron, Inc. (WT), a subcontractor,
double-billed some costs, was paid
twice in some instances and billed
unsubstantiated off-specification
charges for disposal of hazardous
wastes. Also, OHM double-billed and
overbilled WT costs and other
subcontractor costs to the
government.
This investigation was conducted by
the EPA OIG.
Judgment Against Former
Asbestos Contractor
On June 3,1996, the U.S. District
Court for the District of Nebraska
granted summary judgment for the
United States and awarded $480,428
in damages and civil penalties to the
United States under the False Claims
Act for Stanley Peters' role in
defrauding EPA under the Asbestos
School Hazard Abatement Act
(ASHAA).
Stanley L. Peters Associates (SLPA)
assisted the Fairbury Public Schools
(FPS) in applying to EPA for grants
under the ASHAA for removal of
asbestos. On April 28,1989, EPA
awarded the FPS a grant of $281,176
and a no-interest loan of $319,630 for
asbestos removal. SLPA
subsequently entered into an
agreement with FPS to design and
oversee the asbestos abatement
procedure. On February 28,1990,
Brad's Asbestos Removal, Inc.
(BAR), owned and managed by
Russell and Dean Curtis, was
awarded the asbestos removal
contract.
Between 1989 and 1991, Peters
conspired with the Curtis brothers to
submit claims to EPA for
reimbursement for asbestos removal
work that had not been performed,
resulting in overpayment of $153,476.
On December 21,1993, Peters was
convicted, and on June 28,1994, he
was sentenced to 24 months
imprisonment, and ordered to pay
restitution of $153,476. This case
was investigated by the EPA OIG and
the FBI.
Company Settles Imputed
Interest Claims
J
On September 24,1996, Versar, Inc.
(Versar), entered into a settlement
agreement with EPA and the United
States Attorney's Office, Middle
District of North Carolina, to resolve
allegations that Versar prematurely
billed the Agency for subcontractor
costs. Versar agreed to reimburse the
government $47,941 for the imputed
interest on the use of the prematurely
billed costs and the administrative
costs of the investigation. Versar
further agreed to ensure that all
current and future officers, managers,
and contracts management and billing
employees receive required training
regarding proper implementation of
billing policy and procedures; to
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
39
-------
monitor on a monthly basis its
government contracts to ensure
compliance with the Federal
Acquisition Regulation; and to submit
to EPA annual certifications that all
terms and conditions of the
agreement have been met.
Settlement Of CM* False
Claims
On September 20, 1996, the United
States Attorney's Office for the
District of Columbia and Glenn H.
Lovin, Director of the Small
Community Environmental Council,
reached an agreement under which
Lovin paid $14,700 to settle a civil
False Claims Act case. The
agreement was the culmination of an
OIG investigation of Lovin for alleged
false claims under an EPA
assistance agreement, which was
awarded in September 1990 to the
Small Community Environmental
Council to develop a one-day
education workshop addressing safe
drinking water requirements for public
water systems in small communities.
On September 27, 1990, Lovin
requested a reimbursement of
$15,000, which EPA paid under the
assistance agreement, for distributing
hundreds of EPA information packets
on safe drinking water to various
governments, organizations, and
individuals. The government alleged
that Lovin never performed any of the
services.
pPA Scientist Resigns
Minus Twa Degrees
An EPA Region 4 environmental
scientist resigned after investigation
revealed that he falsified the
education claimed on his application
for employment and various
appointment documents. The
employee claimed to have received
two Bachelor of Science degrees and
an Associate in Business
Administration degree. The employee
provided copies of a transcript and a
diploma which were fictitious.
J
40
OFFICE OF INSPECTOR GENERAL
-------
Section 4 -- Fraud Prevention And Management Improvements
This section describes several
activities of the Office of Inspector
General to promote economy and
efficiency and to prevent and detect
fraud, waste, and abuse in the
administration of EPA programs
and operations. This section
includes information required by
statute, recommended by Senate
report, or deemed appropriate by
the Inspector General.
Review of Legislation and
Regulations
Section 4(a)(2) of the Inspector
General Act of 1978, as amended,
directs the Office of Inspector General
to review existing and proposed
legislation and regulations relating to
Agency programs and operations to
determine their effect on economy and
efficiency and the prevention and
detection of fraud and abuse. During
this semiannual period, we reviewed
seven legislative and 37 regulatory
items. The most significant items
reviewed are summarized below.
.R» 3307 * Regulatory Fair
Warning Act
We expressed concern that certain of
the bill's provisions would restrict
auditors from questioning any costs
previously "approved" by Federal or
state officials.
In its statement before the House
Judiciary Committee's Commercial
and Administrative Law
Subcommittee, the Agency addressed
our concern in more inclusive terms.
The Agency stated that the bill would
bar civil or criminal sanctions where
the defendant committed a violation in
"reasonable reliance upon a written
statement by an authorized Federal or
State official" and that the bill would
invite defendants to seek the most
lenient interpretation of a regulation.
MM* 38$4 - General
Accounting Office (GAO)
Management Reform A&l
Inspectors General of Executive
Branch agencies. We also
recommended deletion of the clause
preventing GAO's Inspector General
from reviewing the methodology GAO
used in preparing a report. Such a
restriction would severely hamper the
effectiveness of GAO's Inspector
General.
Proposed Order - Safety
Health, and Environmental
Employment Program
We expressed concern that the
provision delegating authority for
"direction and oversight of EPA
contractors" inferred that EPA
employees should direct the work of
contractor employees. The Order was
revised to address our concern.
Response to GAO Report-
Water Pollution: Many
Violations Have Not
Received Appropriate
Enforcement Attention
We did not concur in the Agency's
proposed response because it did not
directly respond to GAO's
recommendation. The draft response
largely discussed penalty flexibility,
rather than penalty equity for
comparable violations. Also, the draft
response referred to an Agency
workgroup which would address
options for providing equity, but
contained no timeframe for completing
this work.
The response was revised to reflect
our concerns.
We recommended that the bill be
revised to require that GAO's
Inspector General be appointed with
the "advice and consent of the
Senate," a provision applicable to the
APRIL 1,1996 THROUGH SEPTEMBER 30,1996
41
-------
Suspension and
Debarment Activities
EPA's policy is to do business only
with contractors and assistance
recipients who are honest and
responsible. EPA enforces this policy
by suspending or debarring
contractors, assistance recipients, or
individuals within those organizations,
from further EPA contracts or
assistance if there has been a
conviction of, or civil judgment for,
specific offenses, including the
commission of any offense indicating
a lack of business integrity or
business honesty that seriously and
directly affects the present
responsibility of an entity or individual.
An entity or individual may also be
debarred for any other cause of so
serious or compelling a nature that it
affects its present responsibility.
Thus, an entity or individual need not
have committed fraud or been
convicted of an offense to warrant
being debarred. Debarments are to
be for a period commensurate with the
cause, but generally do not exceed 3
years.
The EPA Suspension and Debarment
(S&D) Division in the Office of Grants
and Debarment operates the S&D
program at EPA. The O/G assists the
EPA S&D program by providing
information from audits, investigations,
and engineering studies; and
obtaining documents and evidence
used in determining whether there is a
cause for suspension ordebarment.
During this period, cases with direct
OIG involvement led to two
debarments, one compliance
agreement, and one notice of
proposed debarment.
The actions are summarized below:
• On June 10,1996, EPA debarred
Scott R. Rippey, a Commissioned
Officer of the U.S. Public Health
Service, and William Burkhardt, a
Food and Drug Administration
employee, for knowingly filing false
confidential statements of employment
and financial interest. Both failed to
disclose their ownership and
employment interest in Biosearch
Limited, New England Scientific, and
Biological Analytical Laboratories
(BAL). EPA contracted with BAL for
work on the Narragansett Bay project.
Our March 31,1996, semiannual
report discussed their suspensions.
• On July 24,1996, EPA entered into
a compliance agreement with National
Environmental Testing, Inc., Santa
Rosa Division (NET SR). Our March
31,1996, semiannual report
discussed NET SR's suspension
pending the outcome of an
investigation involving the propriety of
laboratory practices.
EPA agreed to terminate NET SR's
suspension and any further debarment
proceeding provided that NET SR (1)
implements a corporate compliance
program to review complaints of
employee violations of law and NET
SR's laboratory protocols, Quality
Assurance Plan, or Code of Ethics, (2)
conducts ethics training,
(3)implements an annual certification
program for all analytical/technical
employees in appropriate test
methods and procedures, (4) institutes
controls, including improvements to
operating procedures and conducting
internal audits, to ensure the quality of
the work product, and (5) terminates
from working on federal government
contracts any employee found to have
committed an improper act. Prior to
the agreement, NET SR had taken
various remedial actions, including
terminating or suspending all
employees who falsified analytical
data.
• On May 23,1996, EPA issued a
notice of proposed debarment to
Revet Environmental & Analytical
Laboratory, Inc.; its president, Dr.
Virginia Taylor; and Edward Taylor,
laboratory director, for unsatisfactory
performance under the Contract
Laboratory Program. Revel's work did
not meet EPA standards for quality
and timeliness. Revet had also
misrepresented work conducted by a
subcontractor as its own to the State
of Massachusetts.
OIG Management Initiatives
The OIG participates as a full partner
in implementing EPA's National
Environmental Performance
Partnership System (MEPPS) to
ensure the success of the program.
We participated in Agency workgroups
to rewrite federal regu ations that
affect performance partnership grants
and we identified OIG divisional staff
members to work directly with regional
staff on NEPPS issues. Also, we
reviewed two demonstration grants to
identify lessons learned from these
early endeavors. EPA awarded two
OIG auditors a Certificate of
Exceptional Achievement, signed by
the Deputy Administrator, for their
outstanding personal contribution to
the success of the EPA/State
Performance Partnership Program.
In addition, OIG staff participated as
panel members at EPA's National
Grants Management Conference, and
the EPA's All States Conference .
Two members of the Office of Audit
have taken on a leadership role in
helping Agency staff better manage
assistance agreements and contracts.
Specifically, staff gave presentations
at the Assistant Agreement Project
Officer Training courses sponsored by
the Agency's program offices. EPA
has mandated that all project officers
must successfully complete this
course and be certified by October 1,
1996. EPA has invited our staff to
42
OFFICE OF INSPECTOR GENERAL
-------
several of these courses to discuss
the deficiencies highlighted in our
audit reports. The presentations
make these new certified project
officers aware of past problems and of
proper procedures that they must
follow. The presentations also allow
the participants to ask questions about
topics of concern to them.
Tiered Oversight for
Corrective Action: an
OIG/OECA Cooperative
Review
At the request of the Office of
Enforcement and Compliance
Assurance (OECA), Office of Site
Remediation Enforcement, Policy and
Program Evaluation Division, we
reviewed the "tiered oversight"
concept for corrective action under the
Resource Conservation and Recovery
Act (RCRA). This was a special
limited-scope review, to find out if
tiered oversight was working in RCRA,
to assess regional consistency with
the tiered oversight guidance, and to
see if the concept had applications to
the Superfund program.
Corrective action addresses
hazardous waste releases at RCRA
facilities through permits and
enforcement to help keep the sites
clean and risk free. It is similar to
cleanups in the Superfund program.
Oversight is the process of EPA
monitoring corrective action activities
at a site or facility. Tiered oversight is
the concept of varying the levels of
EPA oversight to better allocate
resources based on risk, public
concern, and need.
We reported back to OECA that the
guidance issued by Headquarters in
1992 apparently formalized the
concept of tiered oversight that was
already being applied by the regions.
Regional officials agreed with the
need to consider all factors for
determining the level of oversight
listed in the guidance including other
factors such as the National
Corrective Action Priority System
(NCAPS) ranking of a site.
This review will contribute to
managing future RCRA corrective
action oversight activities, and
promulgating oversight guidance for
the Superfund program.
Joint Review * Contract
Audit Report Process
The OIG and Office of Acquisition
Management (OAM) jointly reviewed
EPA's contract audit process to
identify any deficiencies.
Specifically, the review addressed
whether EPA contracting officers use
financial contract audit reports to
effectively manage EPA contracts,
and whether the audit reports provide
EPA contracting officials with sufficient
timely data to negotiate contract
awards and final rates, close out
contracts, and resolve audit findings
disputed by contractors.
The review disclosed that increased
communication between the OIG and
OAM is necessary to improve the
contract audit process and help
eliminate issues which are barriers to
a more efficient, effective process.
Joint action on improving the process
should result in higher quality work
products which will further protect the
government's interests.
Customer Survey on Audit
Contribution
In July 1996, the OIG's Office of Audit
(OA) surveyed 32 EPA program
managers who had been closely
involved with responding to important
reports issued during the last year,
and congressional staff members from
five committees and subcommittees.
The survey's objectives were to
provide information on OA's
contributions to EPA, help us measure
organizational performance and
achievements, and identify (from a
customer perspective) areas for
improvement in OA's operations and
products.
The survey covered the most
significant reports issued in final and
highlighted in the OIG's Semiannual
Reports to the Congress between
April 1,1995, and March 31,1996.
The survey sent to Agency managers
consisted of 13 questions about audit
field work, the final report, and other
assistance provided by OA staff. The
survey conducted with congressional
staff addressed the final report,
testimony, and responses to
congressional correspondence.
Survey respondents were asked to
assess the importance of each issue
to their work and how well our office
performed the functions.
All congressional staff responses
indicated that our audit reports,
testimony, and correspondence were
of high importance to them in carrying
out their work. Further, in almost
every instance, they accorded the
highest marks to the quality of our
work.
Seventy-eight percent of the EPA
program managers surveyed
responded, and 80 percent agreed
that OA does a better than average
job of communicating with the
auditees. Overall, OA was given high
marks on its final products.
Respondents believed our final reports
were clear, easily understood, logically
arranged, and that report
presentations were balanced, fair,
neutral, gave credit to Agency efforts,
APRIL 1,1996 THROUGH SEPTEMBER 30,1996
43
-------
were factually accurate, complete,
timely, and contained practical
recommendations with workable
solutions. The survey also showed
that in instances where Agency
managers were familiar with our
advice and assistance, we received
high marks.
In summary, the results suggest that
OA is performing work which is of
importance to Agency managers and
congressional staff managers.
Overall, OA is performing at a high
level in the field work phase and, with
few exceptions, the final report phase
which has four areas in need of review
for possible improvement. The results
also indicated that OA needs to
provide better information on its
availability to assist Agency managers
in improving their operations and
programs.
Degree of Agreement that Audits Provide
Workable Recommendations
8
7
6
Is
1
543
Strongly Agree
2 1 NR
Strongly Disgree
Committee on Integrity and
Management Improvement
The Committee on Integrity and
Management Improvement (CIMI) was
established in 1984 by EPA Order
1130.1 to coordinate the Agency's
effort to minimize the opportunities for
fraud, waste, and mismanagement in
EPA programs and activities. CIMI
strives to continually increase
employee awareness and
understanding of various Agency
policies and procedures. The
Committee is composed of senior EPA
program and regional officials and is
chaired by the Inspector General.
j
EPA awards and administers a large
number of contracts each year. With
millions of dollars being expended,
close monitoring of the contractors'
work is essential. Effective contract
administration is a substantial
challenge that requires a coordinated
effort by all EPA employees. For
EPA to get what it pays for in a timely
manner, Agency employees must
clearly define the scope of work and
closely monitor each project, identify
inadequate performance, take
appropriate action to enforce contract
requirements, and be alert for
indicators of fraud. At the same time,
EPA employees must avoid common
pitfalls, such as directing contractors
to perform "inherently governmental"
functions or interacting with contractor
personnel in such a manner that a
"personal service" relationship
develops.
CIMI developed an awareness
document to highlight the importance
of effective contract administration and
to emphasize key requirements and
Agency policies.
44
OFFICE OF INSPECTOR GENERAL
-------
Public Service Recognition
Week
Personnel Security
To show appreciation for EPA
employees and to acknowledge their
significant contributions to the
Agency's mission and excellence in
government, CIMI sponsored a series
of events during the tenth annual
observance of Public Service
Recognition Week. A special
ceremony was held to honor the 57
recipients of the EPA Employee
Recognition Award for outstanding
community service. Inspector General
John Martin was master of
ceremonies and Administrator Carol
Browner presented the awards. I.J.
Hudson, a news anchor at a local
television station, gave the keynote
address, which focused on the
importance of personal commitment
and community service. Following the
ceremony, the Administrator and the
Inspector General hosted a reception
for the award winners.
The Personnel Security Program is
one of the Agency's first-line defenses
against fraud. The program uses
background investigations and
National Agency Checks and Inquiries
to review the integrity of EPA
employees and contractors.
During this semiannual reporting
period, the Personnel Security Staff
reviewed and adjudicated 218
investigations. The following
administrative actions were taken as a
result of investigative findings:
• Two employees resigned prior to
being terminated for material
falsification of their SF-171s by
claiming educational degrees that
were not awarded.
• Three contractor employees were
terminated by their employer for
falsifying the security
questionnaire, one by failing to list
prior convictions and a 19-year
incarceration for murder, the
second for continuous and current
drug usage, and the third for a
recent termination, 3 judgements,
delinquent accounts, and unpaid
collection accounts.
• An employee received a written
reprimand for failure to provide
complete information on the
security questionnaire regarding
the circumstances of a previous
termination and conviction for
driving while intoxicated.
John Martin with Card Browner and guest speaker I.J. Hudson.
APRIL 1,1996 THROUGH SEPTEMBER 30,1996
45
-------
Appendix 1 - Reports Issued
APPENDIX 1 - REPORTS ISSUED
THE INSPECTOR GENERAL ACT REQUIRES A LISTING, SUBDIVIDED ACCORDING TO SUBJECT HATTER, OF EACH REPORT ISSUED BY
THE OFFICE DURING THE REPORTING PERIOD AND FOR EACH REPORT, WHERE APPLICABLE, THE DOLLAR VALUE OF QUESTIONED
COSTS AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE.
QUESTIONED COSTS
ASSIGNMENT CONTROL NUMBER
TITLE
FINAL REPORT
ISSUED
INELIGIBLE
COSTS
UNSUPPORTED
COSTS
UNNECESSARY/
UNREASONABLE
COSTS
RECOMMENDED
EFFICIENCIES
(FUNDS BE PUT
TO BETTER USE
1. INTERNAL AND MANAGEMENT ASSIGNMENTS
Office of the Administrator
E1FAF5-13-0075-6100228 EPA'S RELATIONSHIP WITH ASHRAE
8/H/96
E1XMF5-13-0076-6100301
Deputy Administrator
E1BMF4-22-0359-6100306
ENVIRONMENTAL EDUCATION: MIXED
RESULTS AT EPA
ESTABLISHMENT OF THE NATIONAL
SUPERCOMPUTING CENTER, BAY CITY,
MICHIGAN
FMD Cincinnati Account Operations Office
E1SFP5-23-8000-6400057 CFO ACT FY 95 FMD-CINCINNATI
CHIEF FINANCIAL OFFICER
E1AMF5-07-0026-6100300 EPA'S CHANGING BUDGET PROCESS:
OPPORTUNITY FOR IMPROVED
FINANCIAL MANAGEMENT
E1AMF6-11-0003-6100246
E1SFL5-20-8001-6100200
E1AMF5-20-0013-6100297
E1AMP5-20-7011-6400066
EPA'S BUDGET STRUCTURE NEEDS
REVISION
FY 95 FINANCIAL STATEMENTS
EPA'S IMPLEMENTATION OF THE
GOVERNMENT PERFORMANCE AND
RESULTS ACT
SURVEY AGENCYWIDE FINANCIAL
STATEMENTS
Assistant Administrator for Air and Radiation
E1KAE6-05-0044-6400100 AIR STATE IMPLEMENTATION PLANS
E1KAF6-24-0008-6100318 EMISSION FACTOR DEVELOPMENT
9/30/96
9/30/96
5/31/96
9/25/96
7/ 9/96
5/ 3/96
9/25/96
6/27/96
9/30/96
9/30/96
Assistant Administrator for Administration & Resources Management
E1FBE4-04-0261-6100313
E1AMF6-11-0005-6100275
CAPPING REPORTS-CONGRESSIONALLY 9/30/96
EARMARKED ASSISTANCE TO SELECTED
UNIVERSITIES
ACCURACY OF EPA'S INTEGRATED 8/15/96
PAYROLL AND PERSONNEL SYSTEM
(EPAYS)
46
OFFICE OF INSPECTOR GENERAL
-------
E1AMF5-11-0020-6100304 AMERICAN EXPRESS CARD AUDIT 9/26/96
E6BDG5-24-0014-6400096 GEOGRAPHICAL INFORMATION SYSTEM 9/18/96
PROCUREMENTS
Office of Information Resources Management
9/26/96
Assistant Administrator for Solid Waste & Emergency Response
E1NMF6-15-0002-6100311 SECURITY AND USE OF ELECTRONIC
DATA INTERCHANGE (EDI)
E1LLF5-10-0021-6100264 STATE LEAKING UNDERGROUND 8/ 6/96
STORAGE TANK (LUST) PROGRAMS
Division Director Policy & Proaam Evaluation
E1DSB6-11-0006-6300036 TIERED OVERSIGHT FOR CORRECTIVE 9/23/96
ACTION PROGRAM UNDER RCRA
Regional Administrator - Region 1
ElFMF6-01-0020-6100314 REGIONS 1'S OVERVIEW OF SMALL 9/30/96
GRANTEES
E1FMG6-01-0031-6400102 NEW HAMPSHIRE GRANT-FLEXIBILITY 9/30/96
DEMONSTRATION PROGRAM
Regional Administrator - Region 3
E1HWF4-03-0511-6100310 REGION 3'S OVERSIGHT OF THE 9/30/96
SAFE DRINKING WATER ACT ACTIVITIES
Regional Administrator - Region 4
E1AMF5-04-0112-6100249 REGION 4'S BUDGET EXECUTION 7/12/96
Comptroller - Region 5
E1SFP5-05-8000-6400058 CFO ACT FY 95 R5 5/31/96
Regional Administrator - Region 5
E1GAF5-05-0045-6100284 REGION 5'S AIR ENFORCEMENT AND 9/13/96
COMPLIANCE ASSISTANCE ACTIVITIES
Regional Administrator - Region 6
E1GAF5-06-0056-6100309 REGION 6'S AIR ENFORCEMENT AND 9/26/96
COMPLIANCE ASSISTANCE ACTIVITIES
Regional Administrator - Region 7
E1HUF6-07-0017-6100312 AG WASTE WATER POLLUTION 9/30/96
E1SGB6-07-0016-6400067 REGION 7 IAG OVERSIGHT 6/19/96
Director Superfund Division - Region 7
E1SGG4-14-0019-6400054 WAVERLY GW RI/FS REVIEW 5/ 7/96
Regional Administrator - Region 8
E1FMG6-08-0019-6400069 NORTH DAKOTA BLOCK GRANT DECREASES 7/24/96
ADMINISTRATIVE COSTS & DISCLOSED
POTENTIAL BARRIERS
Regional Administrator - Region 9
E1HWG5-09-0101-6400101 REGION 9'S SMALL DRINKING WATER 9/27/96
SYSTEMS
Director Superfund Division - Region 9
E1SGG5-14-0010-6400061 INDIAN BEND RI/FS REVIEW 6/10/96
APRIL 1. 1996 THROUGH SEPTEMBER 30, 1996
47
-------
TOTAL
31
2. CONSTRUCTION GRANT ASSIGNMENTS
E2CUL5-01-0197-6100299
P2CWL4-01-0142-6100229
S2CUL5-01-0006-6100214
S2CWL2-01-0366-6100222
FALL RIVER
UALLINGFORD
MURA-CLINTON
HURA-NUT ISLAND
TOTAL OF REGION 01 = 4
P2CUL4-02-0175-6100255 CAMDEN COUNTY HUA
TOTAL OF REGION 02 = 1
E2CWM3-03-
P2CUN4-03-
P2CWN5-03-
P2CWN5-03-
P2CWN4-03-
P2CWN2-03-
P2CWN2-03-
0085-6200015
0434-6300026
0202-6300027
0037-6300028
0496-6300033
0499-6300037
0601-6300038
FREDERICK CITY OF
BALTIMORE CITY
BALTIMORE CITY
BALTIMORE CITY
BALTIMORE CITY
WSSC
USSC
TOTAL OF REGION 03 = 7
P2CUN5-04-0053-6300035 COLLIER COUNTY
TOTAL OF REGION 04 = 1
E2CUM4-09-0101-6200011 SAN FRANCISCO, CITY & CO CA
E2CUM5-09-0052-6200012 LOS ANGELES, COUNTY OF
E2CWM2-09-0252-6200014 SAN FRANCISCO, CITY & CTNY CA
TOTAL OF REGION 09 = 3
E2CUN4-10-0120-6300018 EDMONDS, CITY OF UA
E2CUN4-10-0045-6300024 MUNICIPALITY OF METRO SEATL UA
TOTAL OF REGION 10 - 2
MA
CT
MA
MA
NJ
MD
MD
MO
MD
MD
MD
MD
FL
CA
CA
CA
9/23/96
6/12/96
5/13/96
5/17/96
7/25/96
9/24/96
8/ 8/96
8/20/96
8/20/96
9/ 3/96
9/24/96
9/24/96
9/20/96
5/30/96
6/ 4/96
7/16/96
0
5,337,562
42,015
0
5,379,577
676,210
676,210
593,262
314,090
1,283,363
691,843
4,965,429
4,170,342
1,440,660
13,458,989
0
0
8,872,758
280,679
4,592,296
0
869,728
0
0
869,728
749,080
749,080
386,510
129,590
192,756
241,810
182,052
5,731,132
2,311,729
9,175,579
0
0
0
43,970
0
4/ 3/96
71 8/96
13,745,733
69,357
1,915,000
1,984,357
43,970
0
5,210,026
5,210,026
0
29,999
0
0
29,999
0
0
0
0
0
0
0
0
0
0
0
0
0
0
123,149,078
123,149,078
0
0
TOTAL CONSTRUCTION GRANT ASSIGNMENTS
= 18
35,244,866 16,048,383
123,179,077
3. OTHER GRANT ASSIGNMENTS
D3BML6-01-0073-6100218 AERODYNE RESEARCH INC. MA
G3HVK6-01-0052-6500066 MWRA MA
G3HVK6-01-0062-6500070 BENNINGTON VT
G3HUK6-01-0064-6500071 KEEP AMERICA BEAUTIFUL INK CT
N3HVK6-01-0007-6500069 INDIAN TOWNSHIP TRIBAL GOVT ME
N3HUK5-01-0154-6500082 TUFTS UNIVERSITY MA
N3HVJ6-01-0045-6500083 MAINE STATE OF ME
N3HVJ5-01-0155-6500084 CONNECTICUT STATE OF CT
TOTAL OF REGION 01 =
8
C3HVK6-02-0064-6500103
G3HVK6-02-0048-6500072
G3HVK6-02-0059-6500073
N3HVK6-02-0055-6500067
BINGHAMTON
PRASA
LOVE CANAL AREA REVIT AGCY
PUERTO RICO DEPT OF AGR
TOTAL OF REGION 02
4
C3HVK6-03-
C3HVK6-03-
C3HVK6-03-
E3CEP4-03-
N3HVK6-03-
N3HVK6-03-
0207-6500087
0209-6500089
0221-6500100
0268-6400064
0208-6500088
0211-6500090
ANNE ARUNDEL COUNTY
BALTIMORE COUNTY
ANNE ARUNDEL COUNTY
SPECIAL REVIEW OF CHMR.
DELAWARE STATE OF
MARYLAND STATE OF
NY
PR
NY
PR
MD
MD
MD
PA
DE
MD
TOTAL OF REGION 03 =
C3HVK6-04-0051-6500065
C3HVK6-04-0062-6500080
C3HVK6-04-0069-6500098
NASHVILLE DAVIDSON COUNTY TN
TALLAHASSEE FL
JACKSONVILLE FL
5/16/96
4/16/96
5/ 2/96
5/ 2/96
5/ 2/96
6/12/96
6/12/96
6/12/96
9/ 9/96
5/ 9/96
5/ 9/96
4/19/96
7/24/96
7/31/96
8/21/96
6/20/96
7/30/96
8/ 2/96
4/ 2/96
6/ 3/96
8/19/96
48
OFFICE OF INSPECTOR GENERAL
-------
C3HVK6-04-0070-6500099 PENSACOLA
TOTAL OF REGION 04 =
C3HVK6-05-0133-6500092
C3HVK6-05-0132-6500093
N3HVK6-05-0134-6500094
LANSING FY 95
GRAND RAPIDS FY 95
COLUMBUS FY 95
FL
MI
MI
OH
TOTAL OF REGION 05
E3BUP6-23-0016-6400099 MICHIGAN U OF SEC 5 GRANT MI
TOTAL OF REGION 23
1
C3HVK6-06-0042-6500086
C3HVK6-06-0045-6500104
G3HVK6-06-0047-6500106
N3HVK6-06-0035-6500081
N3HVJ6-06-0046-6500105
SHREVEPORT LA
NORTH LITTLE ROCK CITY OF AR
AMERICANS FOR INDIAN OPPORT NM
GALVESTON COUNTY HEALTH DISTTX
LOUISIANA STATE OF LA
TOTAL OF REGION 06 = 5
C3HVK6-07-0031-6500097 CITY OF KANSAS CITY
N3HVJ5-07-0035-6500079
N3HVJ6-07-0028-6500085
N3HVK6- 07- 0029-6500095
N3HVK6-07-0023-6500096
N3HVJ6-07-0034-6500102
STATE OF IQUA
STATE OF KANSAS
STATE OF NEBRASKA
STATE OF KANSAS
STATE OF IOWA
TOTAL OF REGION 07 = 6
N3HVJ5-08-0049-6500075 STATE OF UTAH
N3HVJ6-08-0032-6500091 STATE OF COLORADO
TOTAL OF REGION 08 = 2
KS
IA
KS
NE
KS
IA
UT
CO
G3HVK6-09-0082-6500107 UEOTT COMMUNITY SVC DIST CA
G3HVH6-09-0084-6500108 NAPA COUNTY RES CONS D CA
TOTAL OF REGION 09 = 2
N3HVK6-10-0012-6500068 SHOSHONE-BANNOCK TRIBES INC ID
8/19/96
8/ 7/96
8/ 7/96
8/ 7/96
9/26/96
7/15/96
9/24/96
9/24/96
6/ 6/96
9/24/96
8/19/96
5/31/96
7/ 2/96
8/ 9/96
8/ 9/96
8/28/96
5/13/96
8/ 5/96
9/25/96
9/25/96
4/24/96
TOTAL OF REGION 10 =
1
1,406,359
1,406,359
0
0
0
0
0
1,072
156
1,228
4,178
4,178
0
0
0
0
0
0
5,851
5,851
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
TOTAL OTHER GRANT ASSIGNMENTS
42
1,411,765
5,851
5. SUPERFUND GRANT ASSIGNMENTS
E5HGN5-09-0094-6300039 STATE SF CREDITS DTSC CA 9/27/96
TOTAL OF REGION 09 = 1
E5HGL6-10-0010-6100256 SUPERFUND STATE CREDITS OR 7/30/96
TOTAL OF REGION 10 = 1
TOTAL SUPERFUND GRANT ASSIGNMENTS
8. OTHER CONTRACT ASSIGNMENTS
D8BML4-01-0116-6100189 CADMUS GROUP MA 4/25/96
D8BML5-01-0140-6100212 NORTHBRIDGE ENVIR MANMENT MA 5/ 8/96
D8DML4-01-0115-6100215 ASCENSION TECHNOLOGY INC. MA 5/14/96
D8DML2-01-0053-6100233 PUTNAM & HAYES 1987 OVERHEADMA 6/17/96
D8DML3-01-0039-6100234 PUTNAM, HAYES & BARTLETT INCMA 6/17/96
D8SML5-01-0107-6100266 INTERNATIONAL FUEL CELLS CT 8/ 9/96
D8DML4-01-0030-6100270 UPI INCORPORATED MA 8/14/96
D8DML3-01-0021-6100271 UPI INCORPORATED MA 8/14/96
D8CML5-01-0005-6100274 CADMUS GROUP MA 8/14/96
D8DML3-01-0020-6100282 THE CADMUS GROUP INC. MA 8/29/96
D8DML3-01-0247-6100283 CADMUS GROUP INC. MA 8/29/96
* The dollar value of contract audits have not been shown.
Public disclosure of the dollar value of financial recom-
mendations could prematurely reveal the Government's
negotiating positions or release of this information is
not routinely available under the Freedom of Information
Act. The number of these reports and dollar value of the
findings have been included in the aggregate data displayed
below. Such data individually excluded in this listing will
be provided to the Congress under separate memorandum within
30 days of the transmittal of the semiannual report to the
agency head. The transmitted data will contain appropriate
APRIL 1. 1996 THROUGH SEPTEMBER 30, 1996
49
-------
D8DML4-01 -0074-6100291
D8AML6-01 -0093-6100293
D80ML4-01 -0042-6100294
D8DML2-01 -0158-6100295
D8DHL2-01 -0064-6100316
D8AMP6-01 -0065-6400048
DBEMP6-01 -0088-6400078
D8BMP6-01 -0089-6400079
D8EMP6-01 -0085-6400080
D8EHP6-01 -0078-6400081
D8EHP5-01 -0183-6400082
D8AHP6-01 -0063-6400083
D8AMP6-01 -0076-6400084
D8AHP6-01 -0075-6400085
D8AMP6- 01 -0091 -6400087
D8AMP6-01 -0092-6400094
D8EMP6-01 -0102-6400098
E8BML4-01 -0026-6100307
E8BHL4-01 -0036-6100308
E8DHP5 - 01 -0622-6400065
E8CMP2-01 -0129-6400071
E8CAP3-01 -0057-6400074
E8CMP2-01 -0340-6400075
E8CAP3-01 -0256-6400076
E8CHP2-01 -0149-6400077
TOTAL OF
D8BML5-02-0040-6100206
D8EML6-02-0052-6100207
D8DML3-02-0189-6100231
D8DHL3-02-0190-6100232
D8DML3-02-0185-6100269
D8BML5-02-0064-6100272
D8DML3-02-0146-6100273
D80HL3-02-0099-6100317
D8EMN5-02-0135-6300034
D8EMP6-02-0061 -6400088
D8EMP6- 02-0060-6400089
D8EMP6-02-0063-6400093
TOTAL OF
D8CML5-03-0228-6100188
D8EML6-03-0163-6100190
D8BML5-03-0214-6100192
D8CPL2-03-0306-6100193
D8EML6-03-01 18-6100204
D8CHL6-03-0166-6100205
D8AML6-03-0169-6100239
D8AML6-03-0137-6100244
D8EML6-03-0179-6100257
D8AHL6-03-0168-6100278
D8CML6-03-0149-6100279
D8BML4-03-0073-6100302
MITRE CORPORATION HA
EASTERN RESEARCH GROUP HA
HITRE CORPORATION HA
HITRE CORPORATION HA
SYRACUSE RESEARCH CORP NY
FOSTER WHEELER ENVIRONMENTALNJ
FOSTER WHEELER ENVIRONMENTALNJ
WADE HILLER ASSOC HA
FOSTER WHEELER ENVIRONMENTALNJ
FAY SPOFFORD & THORNDICKE MA
CAMBRIDGE ENVIRONMENTAL INC. MA
AD LITTLE MA
THE CADMUS GROUP HA
ABT ASSOCIATES HA
THERHO ELECTRON HA
EASTERN RESEARCH GROUP HA
INDUSTRIAL ECONOMICS HA
ALLIANCE FY92 INDIRECT COSTS
TRC-ECI FY92 INDIRECT COSTS
TRC FY92 G&A
ALLIANCE TECHNOLOGIES CORP. MA
ALLIANCE TECHNOLOGIES CORP HA
ALLIANCE TECHNOLOGIES CORP. MA
ALLIANCE TECHNOLOGIES CORP. MA
ALLIANCE TECHNOLOGIES CORP MA
REGION 01 = 36
HEALTH DESIGNS INC. NY
CROXTON COLLABORATIVE NY
BURNS & ROE ENTERPRISES INC.NJ
BURNS & ROE ENTERPRISES INC.NJ
MATHTECH INCORPORATED NJ
MATHTECH NJ
MATHTECH INC. NJ
SYRACUSE RESEARCH CORP NY
CAMRODEN NY
FOSTER WHEELER NJ
CAMRODEN ASSOCIATES INC NY
FOSTER WHEELER NJ
REGION 02 = 12
COMPUTER SCIENCE CORPORATIONVA
ROY F. WESTON PA
S. COHEN AND ASSOCIATES VA
DYNAMAC MD
SMITH ENVIRONMENTAL TECH. PA
LABAT- ANDERSON INC. VA
VERSAR VA
MANTECH ENVIRONMENTAL TECH. VA
S. COHEN & ASSOCIATES VA
PACIFIC ENVIRONMENTAL VA
PRC INC. VA
SCIENTEX CORPORATION
9/12/96
9/16/96
9/16/96
9/16/96
9/30/96
4/29/96
8/ 9/96
8/ 9/96
8/ 9/96
8/14/96
8/14/96
8/14/96
8/14/96
8/14/96
8/29/96
9/12/96
9/25/96
9/26/96
9/26/96
6/24/96
7/30/96
8/ 5/96
8/ 5/96
8/ 5/96
8/ 5/96
5/ 2/96
5/ 2/96
6/17/96
6/17/96
8/14/96
8/14/96
8/14/96
9/30/96
9/12/96
8/29/96
8/29/96
9/12/96
4/25/96
4/25/96
4/25/96
4/25/96
4/30/96
4/30/96
7/ 2/96
7/ 3/96
7/31/96
8/23/96
8/23/96
9/24/96
cautions regarding disclosure.
TOTAL OF REGION 03
12
E8DMP5-22-0253-6400049 ICF FY96 FWD PR RATES
TOTAL OF REGION 22 = 1
D8BHL3-04-0193-6100177 ENTROPY NC
D8BML3-04-0316-6100178 ENTROPY ENVIRONMENTALISTS NC
D8BML3-04-0200-6100236 TRANSCONTINENTAL NC
D8BML6-04-0016-6100237 TRANSCONTINENTAL ENTERPRISESNC
D8BML3-04-0073-6100238 TRANSCONTINENTAL ENTERPRISESNC
E8BML5-04-0069-6100245 EHRT KY
H8AHL6-04-0047-6100176 RESEARCH TRIANGLE INSTITUTE NC
TOTAL OF REGION 04 = 7
D8DML4-05-0264-6100164
D8AML6-05-0086-6100170
D8CHL3-05-0391-6100174
D8BML2-05-0312-6100175
ENVIRON SCIENCE & ENG 92/93 IL
SBI ENVIRONMENTAL/SOBRAN OH
COLEJON HECH OH
IIT FY 90 IL
4/30/96
4/12/96
4/12/96
6/17/96
6/20/96
6/20/96
7/ 8/96
4/12/96
4/ 2/96
4/ 8/96
4/10/96
4/11/96
50
OFFICE OF INSPECTOR GENERAL
-------
D8BML5-05-0103-6100179 BATTELLE FY 94
D8BML4-05-0057-6100187 TRIAD ENG FY 92
D8AWL6-05-01 13-6100226 INTERNATIONAL CONS
D8BML5-05-0106-6100240 CTC TECH INC FY 94
D8BML3-05-0207-6100241 AT KEARNEY FY 90/91 CENTAUR
D8BML3-05-0210-6100242 AT KEARNEY FY 90/91
D8AAL6-05-0129-6100280 FEV ENG TECH
D8BML6-05-0120-6100298 AT KEARNEY FY 92 EH&S
D8AHP6-05-0137-6400097 BATTELLE
E8AMP6-05-0135-6400086 PRC EMI
H8CML4-05-0312-6100171 CINCINNATI U OF 68-03-3379
H8CHL4-05-031 1-6100172 CINCINNATI U OF 68-03-4038
H8CHL5-05-0096-6100173 CINCINNATI U OF 68-C9-0031
TOTAL OF REGION 05 = 17
D8CHL4-06-0172-6100197 RADIAN CORPORATION
D8BML2-06-0076-6100198 LOCKHEED
D8BML6-06-0036-6100235 RADIAN INTERNATIONAL INC.
OH
WI
OH
OH
IL
IL
MI
IL
OH
IL
OH
OH
OH
TX
TX
TX
D8BML6-06-0017-6100253 SOUTHWEST RESEARCH INSTITUTETX
D8AML6-06-0041 -6100267 SOUTHWEST RESEARCH INSTITUTETX
D8BML6-06-0022-6100268 LEE WILSON & ASSOCIATES
D8BML6-06-0038-6100288 TECOM
D8BML6-06-0039-6100289 TECOM
D8BML4-06-0092-6100290 TECOM INC.
TOTAL OF REGION 06 = 9
D8APL6-07-0021 -6100210 MIDWEST RESEARCH INST
D8APL6-07-0021 -6100211 MIDWEST RESEARCH INST
D8DML6-07-0015-6100220 MIDWEST RESEARCH INSTITUTE
TOTAL OF REGION 07 = 3
D8AML6-08-0025-6100180 E SOURCE INC
D8AML5-08-0051 -6100194 JK RESEARCH ASSOCIATES INC
TOTAL OF REGION 08 = 2
D8CAL4-09-0034-6100219 SAIC FC
D8CAL2-09-0263-6100221 ES FC
D8ABL6-09-0062-6100227 SAIC PA
D8CML6-09-0050-6100258 ACUREX FC
D8BML3-09-0255-6100259 SR CI 92
D8BML4-09-0041 -6100260 SR CI 90
D8BML5-09-0058-6100261 SR CI 93
D8BML6-09-0028-6100263 SR CI 94
D8CSL6-09-0049-6100281 SAIC FC
D8BML5-09-0043-6100292 EERC CI 93
D8BMM4-09-0225-6200009 J&S CI 93-94
D8FMN6-09-0034-6300020 EERC FL
D8AMN6-09-0075-6300030 SAIC PA
D8CMN6-09-0068-6300031 SAIC FC
D8AMN6-09-0077-6300032 SAIC PA
NM
TX
TX
TX
MO
MO
MO
CO
CO
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
4/18/96
4/25/96
6/ 5/96
7/ 2/96
11 2/96
11 2/96
8/26/96
9/23/96
9/23/96
8/16/96
4/10/96
4/10/96
4/10/96
4/29/96
4/29/96
6/17/96
7/19/96
8/13/96
8/13/96
9/12/96
9/12/96
9/12/96
5/ 3/96
5/ 3/96
5/16/96
4/22/96
4/25/96
5/16/96
5/16/96
6/ 6/96
7/31/96
8/ 1/96
8/ 1/96
8/ 1/96
8/ 1/96
8/29/96
9/12/96
5/ 3/96
6/ 4/96
8/27/96
8/27/96
8/28/96
TOTAL OF REGION 09 = 15
TOTAL OTHER CONTRACT ASSIGNMENTS
= 114
911,171
7,210
9,034,986
9. SUPERFUND CONTRACT ASSIGNMENTS
D9BGL6-01-0087-6100265 CAMP DRESSER & MCKEE MA 8/ 9/96
E9CKP6-01-0625-6400092 ALLIANCE TECHNOLOGIES MA 9/ 4/96
TOTAL OF REGION 01 = 2
D9EGP6-02-0023-6400095 FOSTER WHEELER ENV. CORP NJ 9/12/96
E9AHP6-02-0523-6400059 ECOLOGY & ENVIR NY 6/ 5/96
TOTAL OF REGION 02 = 2
D9CGL4-03-0194-6100191 ROY F. WESTON MA 4/25/96
D9AFL6-03-0171-6100243 KIMBALL & ASSOCIATES PA 7/ 3/96
D9BFL3-03-0135-6100287 ENVIRONMENTAL TECHNOLOGY INCVA 9/11/96
APRIL 1. 1996 THROUGH SEPTEMBER 30, 1996
51
-------
TOTAL OF REGION 03 = 3
E9EHP6-22-0036-6400062 GUARDIAN ACCTG. SYSTEM
TOTAL OF REGION 22
DE
TOTAL OF REGION 10
TOTAL SUPERFUNO CONTRACT ASSIGNMENTS
TOTAL REPORTS = 247
6/18/96
D9AGL5-04-0067-6100165 COMMUNITY RELATIONS PLUS
E9EHP6-04-0055-6400070 UESTINGHOUSE REMEDIATION
E9AHP6-04-0071 -6400103 UESTINGHOUSE REMEDIATION
TOTAL OF REGION 04 = 3
D9AKL6-05-011 1-6100213 TN ASSOC
D9AKL6-05-01 10-6100223 TUCKER YOUNG
E9BKL5-05-0046-6100169 PRC EMI FY 93
E9BKL6-05-0036-6100208 PRC EMI FY 87
E9DKL5-05-0056-6100209 PRC EMI FY 86/86T
E9AKP6-05-0098-6400047 PRC EMI FY 96 BILLING RATES
E9BKP5- 05 -0056- 6400051 PRC EMI FY 86&86T
E9AGP6-05-01 18-6400063 PRC EMI RAC
TOTAL OF REGION 05 = 8
D9BHL3-23-0001 -6100195 OHM REM FY 92/93
D9BHL3-23-0001 -6100196 OHM REM FY 92/93
E9CGL4-23-0315-6100230 EARTH TECH ARCS
E9EHP6-23-5001 -6400090 EQMI A/S F/U
TOTAL OF REGION 23 = 4
D9CGL5-07-0014-6100166 BLACK & VEATCH WASTE SCI
D9CGL5-07-0014-6100167 BLACK & VEATCH WASTE SCI
D9CGL5-07-0023-6100168 BLACK & VEATCH
D9CGL5-07-0029-6100216 SVERDRUP CORPORATION
D9CGL5-07-0029-6100217 SVERDRUP CORPORATION
D9AKL6-07-0022-6100225 BLACK & VEATCH SPEC PROJ
D9CKL4-07-0080-6100254 B&V WASTE SCIENCE & TECH
D9CGL4-07-0076-6100276 SVERDRUP CORPORATION
TOTAL OF REGION 07 = 8
D9CJL4-08-0025-6100181 JF SATO & ASSOCIATES
GA
GA
GA
WI
MI
IL
IL
IL
IL
IL
IL
OH
OH
MI
OH
MO
MO
MO
MO
MO
KS
MO
MO
CO
D9AGL5-08-0024-6100182 RBD INC. ENGINEERING CONSULTCO
D9AGL5-08-0024-6100183 RBD INC. ENGINEERING CONSULTCO
D9AGL5-08-0026-6100184 FOOTHILLS ENGINEERING INC.
TOTAL OF REGION 08 = 4
D9AGL6-09-0054-6100224 TETRA PA
D9BGN6-09-0061 -6300019 BECHTEL MS
TOTAL OF REGION 09 = 2
E9EGL4-10-0101-6100319 RES DO RECONCILIATION
E9BHL6- 10-0021 -6100320 RES 1987 D.C.
E9EGN5- 10-0052-6300025 RES CAS COMPLIANCE
CO
CA
CA
OR
OR
OR
4/ 3/96
7/25/96
9/30/96
5/ 9/96
5/20/96
4/ 8/96
5/ 2/96
5/ 2/96
4/26/96
5/ 2/96
6/18/96
4/29/96
4/29/96
6/12/96
9/ 3/96
4/ 5/96
4/ 5/96
4/ 5/96
5/16/96
5/16/96
5/23/96
7/22/96
8/19/96
4/22/96
4/22/96
4/22/96
it/22/96
5/22/96
5/15/96
9/30/96
9/30/96
8/ 8/96
40
2,297,216 1,294,918 0 8,172,300
39,865,018 17,356,362 123,179,077 17,207,286
52
OFFICE OF INSPECTOR GENERAL
-------
Appendix 2 -- Reports Issued Without Management Decision
THE INSPECTOR GENERAL ACT REQUIRES A SUMMARY OF EACH REPORT ISSUED BEFORE THE COMMENCEMENT OF THE REPORTING PERIOD FOR
WHICH NO MANAGEMENT DECISION HAS BEEN MADE BY THE END OF THE REPORTING PERIOD (INCLUDING THE DATE AND TITLE OF EACH SUCH
REPORT), AN EXPLANATION OF THE REASONS SUCH MANAGEMENT DECISION HAS NOT BEEN MADE, AND A STATEMENT CONCERNING THE
DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION ON EACH SUCH REPORT. (The IG provides the summary, the date and title of each such
report. The Agency provides the explanation of the reasons why such management decision has not been made, and a statement concerning the desired timetable
for achieving a management decision on each such report.)
IG Followup Status Codes of Agency's Response at 9/30/96:
No Response
0. Resolution Pending Receipt of Additional Information
1. Proposed Response Received Awaiting Final Determination
2. Resolution Under Negotiation in Headquarters
3. Incomplete Response Received
4. Proposed Response Received in Review Process
5. Final Response Received in Review Process
9. Referred to ARB
ASSIGNMENT CONTROL
NUMBER
TITLE
FINAL REPORT
ISSUED
ASSIGNMENT CONTROL
NUMBER
TITLE
FINAL REPORT
ISSUED
Assistant Administrator for Administration and Resources Management
E3CML3-03-0201-4100523 TEMPLE UNIVERSITY PA 9/15/94
Summary EPA GRANTS SPECIALISTS AND PROJECT OFFICERS DID NOT
PROPERLY ADMINISTER AND MONITOR ASSISTANCE AGREEMENTS TO DETERMINE
IF PERFORMANCE REQUIREMENTS WERE MET, NOR DID THEY IDENTIFY AN
ESTIMATED $35 MILLION IN UNUSED FUNDS FOR ALLOCATION ELSEWHERE.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE DIG REQUESTED THE COMPTROLLER GENERAL'S OPINION REGARDING
THE USE OF NON-FEDERAL TRAVEL UNDER COOPERATIVE AGREEMENTS. OGD,
DIG, AND OGC HAVE COORDINATED A REQUEST FOR GAO TO PROVIDE THEIR
OPINION ON THIS AND OTHER OUTSTANDING
ISSUES - RESOLUTION EXPECTED WITHIN 45 DAYS OF RECEIPT OF GAO
OPINION. AS OF 9/30/96 STILL WAITING FOR GAO OPINION.
USE OF NON-FEDERAL TRAVEL UNDER COOPERATIVE AGREEMENTS OGD,
DIG, AND OGC HAVE COORDINATED A REQUEST FOR GAO TO PROVIDE THEIR
OPINION ON THIS AND OTHER OUTSTANDING ISSUES. AS OF 9/30/96, OGC
HAS NOT RECEIVED GAO OPINION - RESOLUTION EXPECTED WITHIN 45 DAYS
OF RECEIPT OF GAO OPINION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [0)
Assistant Administrator for Air and Radiation
E1SKF5-03-0070-6100161 MGT OF SELECTED CONTRACTS 3/30/96
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [0]
E1HWG4-04-0168-6400043 GULF OF MEXICO FOUNDATION CATX 3/28/96
-Summary: GMF GRANT AWARDED TO PAY CONTRACTOR (FEDERAL) OBLIGATIONS
FOR THE TRAVEL OF INVITED GUESTS, ENTERTAINMENT, CATERING TO THE
1995 GULF OF MEXICO SYMPOSIUM (AUDIT REPORT E1HWF4-04-0168-5100530).
GMF GRANT NOT AWARDED FOR A LEGITIMATE GRANT PURPOSE, BUT FOR DIRECT
BENEFIT OF GMPO.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE OFFICE OF GRANTS AND DISBARMENT RESPONSE TO THE FINAL REPORT WAS
FORWARDED FOR SIGNATURE SEPTEMBER 26, 1996.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [4]
E1FMG4-13-0061-54000S1 IAGS 3/31/95
Summary: EPA OFTEN EXECUTED ECONOMY ACT IAGS WITHOUT OBTAINING
ADEQUATE COST REASONABLENESS INFORMATION. IN ADDITION, EPA DID NOT
RECOVER ITSFULL COSTS OF PERFORMING WORK FOR OTHER AGENCIES.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: A FINAL RESPONSE TO THE AUDIT REPORT RELATING TO MANAGING
INTERAGENCY AGREEMENTS AT EPA HEADQUARTERS WAS FORWARDED FOR
SIGNATURE ON 9/30/96.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
CANNOT BE DETERMINED AT THIS TIME.
RESOLUTION Summary: UNDER THE FOUR CONTRACTS WE REVIEWED, EPA PROCURED
PRODUCTS AND SERVICES FROM A MAJOR CONTRACTOR WHICH WERE
INADEQUATE, UNTIMELY, AND/OR OF QUESTIONABLE VALUE.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E1FMF4-19-0618-4100407 UNIVERSITY OF KANSAS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:
MEMORANDUM FORWARDED FOR SIGNATURE ON 10/03/96. ANTICIPATED TO
BE SENT TO THE DIG SHORTLY.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
Assistant Administrator tor Water
E1HWE5-23-0001-5100516 DRINKING WATER DATA INTEGRITY 9/29/95
Summary: NATIONWIDE ABOUT 12 PERCENT OF COMMUNITY, SURFACE
PUBLIC WATER SYSTEMS REPORTED INVALID OR POTENTIALLY FALSIFIED
DATA AT LEAST ONCE FROM 1991 THROUGH 1994. WITHOUT STATE
OFFICIALS OR EPA
REVIEWING THE VALIDITY OF THE DATA, SERIOUS HEALTH RISKS COULD GO
UNDETECTED AND NEGATE EP A'S AND STATES' ABILITY TO PREVENT WATER
AND SUPPLY CONTAMINATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: PROGRAM OFFICE IS PREPARING RESPONSE BASED ON RECENT
DECISIONS REGARDING PROGRAM REDIRECTIONS AND THE NEW LEGISLATIVE
AUTHORIZATION. EXPECT RESPONSE TO BE SUBMITTED TO OIG IN
OCTOBER.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
KS
6/17/94
Summary: EPA CIRCUMVENTED ASSISTANCE REGULATIONS AND MISUSED FEDERAL
FUNDS BY AWARDING COOPERATIVE AGREEMENT TO THE UNIVERSITY OF KANSAS
WHICH INCLUDED INELIGIBLE AND UNNECESSARY COSTS SUCH AS TRAVEL,
ALCOHOL, AND ENTERTAINMENT.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE OIG REQUESTED THE COMPTROLLER GENERAL'S OPINION REGARDING THE
IG FOLLOWUP STATUS AS OF 9/30/96 [3]
Comptroller - Region 5
E2BWL5-05-0136-7000980 SAUGET IL 3/31/87
Summary: WE QUESTIONED OVER $7 MILLION FOR INELIGIBLE AND
UNNECESSARY PROJECT COSTS.
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
53
-------
ASSIGNMENT CONTROL
NUMBER
TITLE
FINAL REPORT
ISSUED
ASSIGNMENT CONTROL
NUMBER
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE REGION ISSUED A PROPOSED FINAL DETERMINATION TO DIG ON 3/22/94.
ON 4/6/94, THE OIG AGREED WITH THE PROPOSED ACTIONS ON ALL MATTERS
EXCEPT THE DECISION TO ACCEPT THE COSTS ASSOCIATED WITH THE TRANSFER
SEWERAGE. THIS AUDIT IS NOW UNDER REVIEW BY THE AGENCY AUDIT
RESOLUTION BOARD AND AWAITING A LEGAL
OPINION BY THE OFFICE OF GENERAL COUNSEL.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [9)
E2CWL9-05-0262-3100397 FLINT MI
9/30/93
Summary: FLINT CLAIMED $2.8 MILLION UNNECESSARY/UNREASONABLE COSTS
INCURRED TO RENEGOTIATE A CONTRACT. FLINT CLAIMED $10,416,828
UNSUPPORTED COSTS FOR ADMINISTRATION, ENGINEERING AND CONSTRUCTION.
WE QUESTIONED $415,339 INELIGIBLE ENGINEERING COSTS INCURRED AFTER
CONSTRUCTION COMPLETION DATE.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
DUE TO CONGRESSIONAL INTEREST AND SINCE OVER $13 MILLION OF COSTS
WERE QUESTIONED, THE REGION PROVIDED THE CITY WITH ADDITIONAL TIME
TO PROVIDE SUPPORTING DOCUMENTATION.
ALSO, DUE TO RELATED LEGAL ISSUES, ASSISTANCE WAS NECESSARY
FROM THE OFFICE OF REGIONAL COUNSEL.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
IS EXPECTED PRIOR TO DECEMBER 31. 1996.
IG FOLLOWUP STATUS AS OF 9/30/96
[1]
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION BY 12/30/96.
IG FOLLOWUP STATUS AS OF 9/30/96 []
E5BKL4-04-0243-5100526 CLARK ATLANTA UNIVERSITY
GA
EXPECT
9/30/95
IG FOLLOWUP STATUS AS OF 9/30/96
[0]
E6EML4-07-0023-4100581
FAIRBURY NE
9/30/94
Summary: THE GRANT/LOAN WAS AWARDED FOR ASBESTOS ABATEMENT IN TWO
FAIRBURY SCHOOLS. WE DETERMINED THAT THE GRANTEE CLAIMED AN
UNREASONABLE AMOUNT FOR ADMINISTRATIVE COSTS. THE GRANTEE CLAIMED
INELIGIBLE ENGINEERING AND CONSTRUCTION COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
AUDIT INVOLVES SEVERAL COMPLEX ISSUES AS A RESULT OF CRIMINAL
PROCEEDINGS TAKEN AGAINST A CONTRACTOR UNDER THE PROJECT. THE
PROGRAM OFFICE IS AWAITING INFORMATION FROM THE OFFICE OF GENERAL
COUNSEL (OGC) BEFORE ISSUING FINAL DETERMINATION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION 45 DAYS AFTER RECEIVING INFORMATION FROM OGC.
EXPECT
TITLE
FINAL REPORT
ISSUED
RESOLUTION
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E1FUF5-08-0019-5100528 SCERP PERFORMANCE 9/29/95
Summary: SCERP AND EPA NEEDED TO IMPROVE THEIR WORKING
RELATIONSHIP AND TO BETTER FOCUS LIMITED RESEARCH FUNDING ON
DEVELOPING SOLUTIONS TO THE MOST ACUTE ENVIRONMENTAL PROBLEMS
ALONG THE U.S. - MEXICAN BORDER.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE PROGRAM OFFICE HAS BEEN UNABLE TO ADDRESS AUDIT ISSUES
DUE TO NUMBER OF AUDITS PENDING RESOLUTION. THE OFFICE IS
CURRENTLY REVIEWING AUDIT FINDINGS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECT
RESOLUTION AROUND DECEMBER 1996.
IG FOLLOWUP STATUS AS OF 9/30/96 [ )
E3CBL3-08-0088-4100497 MONTANA STATE UNIVERSITY
MT
8/23/94
Summary: THE COOPERATIVE AGREEMENTS WERE USED TO FUND AN EPA
EMPLOYEE'S ADVANCED EDUCATION CONTRARY TO THE PURPOSE OF THE
COOPERATIVE AGREEMENTS AND INTERGOVERNMENTAL PERSONNEL ACT
AGREEMENT.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE PROGRAM OFFICE CANNOT RESOLVE AUDIT FINDINGS UNTIL THE
OIG FINISHES ITS FOLLOW ON WORK.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION.
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
Grants Administration Division
E3CBP4-04-0252-4400116 REVIEW OF CA WITH NELHA- HI 9/29/94
* Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE PROGRAM OFFICE IS CURRENTLY REVIEWING COMMENTS RECEIVED FROM THE
RECIPIENT.
IG FOLLOWUP STATUS AS OF 9/30/96 []
H5BFL6-20-0015-6100072 FY 94 REPORT (HHS OIG)
* Summary:
11/30/95
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE PROGRAM OFFICE RECEIVED THE AUDIT REPORT ON APRIL 12,
1996, HAS CONTACTED THE DEPARTMENT OF HEALTH AND HUMAN SERVICES
AND IS AWAITING COMMENTS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION BY DECEMBER 31, 1996.
EXPECT
Summary: CLARK ATLANTA UNIVERSITY MISMANAGED CONGRESSIONAL EARMARKED
FUNDS PROVIDED UNDER AN EPA COOPERATIVE AGREEMENT TO ESTABLISH A
HAZARDOUS SUBSTANCE RESEARCH CENTER. AS A RESULT, THE CENTER WAS
NOT PROPERLY ESTABLISHED AND SERIOUS CONTROL WEAKNESSES CONTRIBUTED
TO $3.3 MILLION OF INELIGIBLE OR UNSUPPORTED COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE PROGRAM OFFICE AND THE OIG HAVE AGREED TO POSTPONE RESOLUTION OF
AUDIT FINDINGS UNTIL THE OIG HAS COMPLETED ITS NECESSARY FOLLOW ON
WORK.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
EXPECTED 45 DAYS AFTER THE OIG COMPLETES ITS FOLLOW ON WORK.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E5CKN5-24-0013-5300035 NORTH CAROLINA STATE UNIV NC 9/28/95
Summary: NCSU CLAIMED $48,197 IN INELIGIBLE COSTS RELATED TO
ESTABLISHMENT OF A HAZARDOUS SUBSTANCE RESEARCH CENTER WE
RECOMMENDED THAT EPA MANAGEMENT ADJUST GRANT COSTS PER OUR
DETERMINATION. NET DUE GRANTEE $34,699.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE PROGRAM OFFICE RECEIVED COPY OF AUDIT REPORT ON MARCH
5, 1996 AND IS CURRENTLY REVIEWING AUDIT FINDINGS
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION EXPECT
RESOLUTION BY 12/31/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
Regional Administrator - Region 1
S2CWL1-01-0024-4100179 SPRINGFIELD MA 1/31/94
Summary THE CITY OF SPRINGFIELD, MA CLAIMED UNALLOWABLE PROJECT
COSTS OF $4,059,671 FOR THE CONSTRUCTION OF A SECONDARY SEWAGE
TREATMENT PLANT, INCLUDING NEW INTERCEPTER SEWERS, PUMPING
STATIONS, FORCE MAIN SIPHON, AND OUTFALL SEWER.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: ON JULY 26, 1996 THE REGION FORWARDED ITS RESPONSE TO THE
DIVISIONAL OIG IN ORDER TO REACH RESOLUTION. SINCE RESOLUTION
HAS BEEN DIFFICULT, THE REGION EXPECTS THE DIVISIONAL OIG TO
FORWARD IT TO THE HQ OIG FOR ACTION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME
IG FOLLOWUP STATUS AS OF 9/30/96
[2]
54
OFFICE OF INSPECTOR GENERAL
-------
ASSIGNMENT CONTROL
NUMBER
FINAL REPORT
ISSUED
ASSIGNMENT CONTROL
NUMBER
Regional Administrator - Region 2
P2CWN1-02-0028-4300034
OCEAN COUNTY UA NJ
5/ 4/94
Summary: THE GRANTEE CLAIMED UNALLOWABLE COSTS OF $4,513,658
CONSISTING OF INELIGIBLE COSTS OF $3,057,931 (FEDERAL SHARE
$2,144,016) AND UNSUPPORTED COSTS OF $1,455,727 (FEDERAL SHARE
$883,5411 FOR CONSTRUCTION OF SECONDARY WASTEWATER TREATMENT
FACILITIES AND APPEARANCES.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THIS AUDIT ENCOMPASSED FIVE EPA GRANTS WITH GRANTEE CLAIMED COSTS OF
$247 MILLION AND AUDITOR QUESTIONED COSTS OF $4.5
MILLION. THE ONGOING REGIONAL REVIEW IS ENSURING THAT ALL ISSUES ARE
FULLY EVALUATED AND ANALYZED, AND THAT THE GRANTEE'S ADDITIONAL
SUBMITTED DOCUMENTATION WILL BE THOROUGHLY EVALUATED.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
FINAL RESOLUTION BY APRIL 1997.
TARGETED
IG FOLLOWUP STATUS AS OF 9/30/96 [1]
P2CWL4-02-0141-5100407 NEPTUNE SA
NJ
7/10/95
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E2CWL4-02-0089-6100102 PRASA GRANT CLOSE OUT
21 5/96
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
FINAL RESOLUTION IS JUNE 30, 1996.
IG FOLLOWUP STATUS AS OF 9/30/96
Regional Administrator - Region 3
P2BWN3-03-0077-4300032 PHILADELPHIA CITY OF
PA
TARGETED
3/30/94
Summary: THE CITY OF PHILADELPHIA CLAIMED $10,959,010 OF INELIGIBLE
FORCE ACCOUNT, ENGINEERING, CONSTRUCTION AND INDIRECT COSTS AN
ADDITIONAL $32,663,495 OF UNSUPPORTED AND $794,684 OF UNNECESSARY
FINAL REPORT
ISSUED
COSTS WERE ALSO QUESTIONED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE- THE SIZE AND COMPLEXITY OF THIS MEGA-AUDIT (COVERING
SEVERAL GRANTS UNDER THE CITY OF PHILADELPHIA SOUTHWEST TREATMENT
PLANT PROJECT) REQUIRES SIGNIFICANT TIME FOR RESOLUTION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION.
ESTIMATED DATE FOR ISSUANCE OF A MANAGEMENT DECISION IS 9/30/97
IG FOLLOWUP STATUS AS OF 9/30/96
E2CWM4-03-0291-5200024 WSSC
Summary: PRASA CLAIMED UNSUPPORTED COSTS OF $1,154,476 (FEDERAL
SHARE $865,856)
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THIS AUDIT ENCOMPASSED GRANTEE CLAIMED COSTS OF $55 MILLION AND
AUDIT QUESTIONED COSTS OF $1.1 MILLION. ALSO, THE AUDITOR REPORTED
FINANCIAL MANAGEMENT SYSTEM DEFICIENCIES AND GRANTEE DIFFICULTIES IN
MEETING EFFLUENT LIMITATIONS CONTAINED IN THE GRANT AGREEMENT THE
ONGOING REGIONAL REVIEW IS ENSURING THAT ALL ISSUES ARE FULLY
EVALUATED AND ANALYZED.
[ 1
MD 9/27/95
Summary: THE GRANTEE CLAIMED $856,871 (FEDERAL SHARE $642,653) OF
INELIGIBLE COSTS. THE MAJORITY OF THESE COSTS RELATED TO COSTS
CLAIMED OUTSIDE THE SCOPE OF THE APPROVED PROJECT.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
FACTORS THAT HAVE DELAYED THE RESOLUTION OF THIS AUDIT INCLUDE THE
INVOLVEMENT OF AN AGENCY OTHER THAN THE DELEGATED STATE AGENCY.
THIS RESULTED IN A MORE LENGTHY REVIEW PROCESS TO INSURE THAT ALL
PARTICIPANTS' POSITIONS WERE ANALYZED AND FOUND CORRECT. DIG HAS
CONCURRED ON DRAFT RESOLUTION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: TARGETED
FINAL RESOLUTION IS APRIL 30, 1997.
IG FOLLOWUP STATUS AS OF 9/30/96 [1]
P2CWL4-02-0061-6100096 NEW YORK CITY-OAKWOOD BEACH NY 2/ 5/96
Summary: THE CITY OF NEW YORK CLAIMED UNALLOWABLE COSTS OF
$10,087,654 INCLUDING INELIGIBLE COSTS OF $7,481,371, UNSUPPORTED
COSTS OF $1,934,408 AND UNREASONABLE COSTS OF $671,875.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
FACTORS THAT HAVE DELAYED THE RESOLUTION OF THIS AUDIT INCLUDE THE
INVOLVEMENT OF AN AGENCY OTHER THAN THE DELEGATED STATE AGENCY.
ALSO, PENDING DECISIONS TO BE MADE BY THIS AGENCY ARE ANTICIPATED TO
HAVE A MATERIAL IMPACT ON THE FINAL RESOLUTION. THIS RESULTED IN A
MORE LENGTHY REVIEW PROCESS TO ENSURE THAT ALL PARTICIPANTS'
POSITIONS WERE ANALYZED AND FOUND CORRECT.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: TARGETED
FINAL DECISION IS JUNE 30, 1997.
Summary: COSTS OF $1.7 MILLION WERE INELIGIBLE BECAUSE THE
GRANTEE CLAIMED CONSTRUCTION COSTS ASSOCIATED WITH EXCESS
RESERVE CAPACITY.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: LEGAL ARGUMENTS AND ADDITIONAL DOCUMENTATION PRESENTED BY
THE GRANTEE REQUIRE FURTHER REVIEW BY THE DIG, THE OFFICE OF
REGIONAL COUNSEL, AND THE WATER MANAGEMENT DIVISION. THE FINAL
DETERMINATION LETTER IS BEING DELAYED TO ALLOW AMPLE TIME FOR
REVIEW
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: TARGET
COMPLETION DATE IS 12/31/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ 1
Regional Administrator - Region 4
E2CWP3-04-0225-4400096 BRUNSWICK GA
8/10/94
Summary: CONSTRUCTION COST WITH FEDERAL SHARE OF $311,250 WAS
QUESTIONED BECAUSE SOME SEWERS WERE NOT BUILT AS PLANNED
ENGINEERING COST CLAIMED WITH FEDERAL SHARE OF $65,000 WAS
QUESTIONED BECAUSE THE GRANTEE DID NOT PROCURE THESE SERVICES IN
CONFORMITY WITH EPA REGULATIONS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE REGION RECEIVED LETTER FROM THE DIG STATING IT DOES
NOT AGREE WITH REGION'S PROPOSED FINAL DETERMINATION LETTER.
THIS AUDIT HAS BEEN FORWARDED TO THE DIG HEADQUARTERS OFFICE FOR
RESOLUTION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [2]
E2CWM5-04-0042-5200006 STARKE FL 1/20/95
Summary: WE QUESTIONED AS INELIGIBLE THE GRANTEE'S CLAIM OF
$1,372,564 FOR ACQUISITION OF A SPRAY IRRIGATION SITE. THE COSTS
WERE QUESTIONED BECAUSE THE SITE WAS NEVER UTILIZED FOR THE
INTENDED PURPOSE
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: A PROPOSED FINAL DETERMINATION LETTER HAS NOT BEEN
PREPARED PENDING LEGAL DISCUSSION REGARDING ELIGIBILITY OF A
PORTION OF THE LAND WHICH HAS BEEN DECLARED A WETLANDS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E2CWM4-04-0118-6200007 MIAMI-DADE WATER i SEWER AU FL 3/11/96
* Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: A DRAFT FINAL DETERMINATION LETTER HAS BEEN PREPARED BUT
NOT YET SIGNED.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION BY EARLY NOVEMBER.
EXPECT
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E2CWM4-04-0151-6200008 MIAMI DADE WATER t SEWER AUTFL 3/21/96
* Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
55
-------
ASSIGNMENT CONTROL
NUMBER
TITLE
FINAL REPORT
ISSUED
MADE: A DRAFT FINAL DETERMINATION LETTER HAS BEEN PREPARED BUT NOT
YET SIGNED.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECT
RESOLUTION BY EARLY NOVEMBER.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
P2CWN5-04-0041-6300012 TAMPA PL
1/24/96
Summary: THE CITY OF TAMPA CLAIMED $234,449 OF INELIGIBLE
CONSTRUCTION AND ENGINEERING COSTS FOR ITS SLUDGE HEAT DRYING
FACILITY. THE QUESTIONED COSTS WERE FOR RELOCATION OF STORM WATER
RETENTION PONDS AND AIR PERMIT PROCUREMENT COSTS THAT WERE OUTSIDE
THE GRANT SCOPE.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
A DRAFT FINAL DETERMINATION LETTER HAS BEEN PREPARED BUT NOT YET
SIGNED.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECT
RESOLUTION BY EARLY DECEMBER.
IG FOLLOWUP STATUS AS OF 9/30/96 t ]
E5CGL4-04-0036-5100490 FLORIDA DER SF COOP AGR PL 9/19/95
Summary: FDEP DID NOT PROVIDE SUPPORT FOR COSTS TOTALING $2,149,111.
THE UNSUPPORTED COSTS WERE NOT IN COMPLIANCE WITH 40 CFR 30.501.
DUE TO A BOOKKEEPING ERROR. FDEP ALSO CLAIMED AN ADDITIONAL $28,911
OF INELIGIBLE COSTS THAT RELATED TO ANOTHER PROJECT.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
AUDITOR AND GRANTEE ARE CONTINUING TO NEGOTIATE OVER THE SUPPORT
DOCUMENTS FOR THE UNSUPPORTED COST QUESTIONED IN THE AUDIT.
SUBSTITUTIONS ARE BEING OFFERED BY THE GRANTEE ON THE "SAMPLES'
REQUESTED IN THE AUDIT. SAMPLES ARE UNSATISFACTORY AT THIS TIME.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
Regional Administrator - Region 6
E2CWN3-06-0089-4300052 HOUSTON TX
9/29/94
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION BY NOVEMBER.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E5BGN4-06-0075-5300012
LA SF CO-OP AGREEMENTS LA
ESTIMATE
3/30/95
Summary: LDEQ'S PROCUREMENT PRACTICES RESULTED IN QUESTIONED COSTS
OF OVER $2 MILLION. WE ALSO FOUND THAT WORK WAS PERFORMED THAT WAS
OUTSIDE THE SCOPE OF THE CONTRACTS; EQUIPMENT PURCHASED WITH OUT
EPA'S PRIOR APPROVAL AND CLAIMED AMOUNTS THAT WERE NOT SUPPORTED BY
ACCOUNTING RECORDS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY (LDEQ) HAS REQUESTED A
FINAL DISPUTE DETERMINATION PROM THE REGION. DOCUMENTATION HAS BEEN
REVIEWED.
SUMMARY
REVIEW OF LDEQ'S RESPONSE REVIEWED BY PROGRAM. DEVIATION ON
$710,192, AND $272,968 REQUESTED FROM EPA HEADQUARTERS ON 01/19/96.
AWAITING ACTION ON REQUESTED DEVIATION.
ASSIGNMENT CONTROL
NUMBER
FINAL REPORT
ISSUED
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
Regional Administrator - Region 7
N3HVJ4-07-007 5-5500094
Summary:
STATE OF IOWA
2/23/95
Summary: HOUSTON, TEXAS CLAIMED $6,159,937 OP INELIGIBLE ENGINEERING
AND CONSTRUCTION COSTS FOR THE CONSTRUCTION OF A WASTEWATER
TREATMENT FACILITY. AN ADDITIONAL $991,174 OF UNSUPPORTED COSTS AND
41,063,235 OF UNNECESSARY AND UNREASONABLE COSTS WERE QUESTIONED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
AN AUDIT TRANSMITTAL LETTER WAS SENT BY THE TEXAS WATER DEVELOPMENT
BOARD TO HOUSTON ON 02/03/95. A 90-DAY AND 120-DAY EXTENSION WAS
REQUESTED AND GRANTED. AUDIT HAS OVER 90 COMPLEX FINDINGS WITH
CLAIMED COSTS OF $208,720,680, QUESTIONED COSTS OF $13,417,479, AND
$3,562,938 POTENTIALLY DUE EPA. A DRAFT FINAL DETERMINATION LETTER
IS BEING REVISED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE REGION HAS TRANSMITTED THE INITIAL DETERMINATION
LETTER TO RECIPIENT AND HAS REQUESTED ADDITIONAL INFORMATION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION.
ANTICIPATE RESOLUTION BY 11/1/96.
IG FOLLOWUP STATUS AS OF 9/30/96 ( ]
N3HVJ5-07-0036-5500225 STATE OF MISSOURI MO 9/19/95
•Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE REGION HAS SENT INITIAL DETERMINATION LETTER TO
RECIPIENT AND HAS REQUESTED ADDITIONAL INFORMATION
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION
ANTICIPATE RESOLUTION BY 11/1/96.
IG FOLLOWUP STATUS AS OF 9/30/96 []
Regional Administrator - Region 8
E1SFG5-08-0032-6400019 SUMM1TVILLE CO 1/22/96
•Summary: REGION 8 REASONABLY SELECTED REMOVAL PND REMEDIAL
CLEANUP ACTIONS AND COMPLIED WITH NATIONAL CONTINGENCY PLAN
REQUIREMENTS AND SUPERFUND GUIDANCE. HOWEVER, THE REGION NEEDED
TO IMPROVE AND BETTER IMPLEMENT ITS IAG OVERSIGHT TO ENSURE
IMPLEMENTATION OF THE CLEANUP.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: PROPOSED DECISION WAS SENT TO THE OIG ON 7/11/96 AND WAS
RETURNED BY THE OIG AS UNACCEPTABLE. THE REGION IS NOW WORKING
WITH THE OIG TO RESOLVE FINAL TWO RECOMMENDATIONS
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION-
RESOLUTION IS EXPECTED BY 11/15/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [3)
P2CWL3-08-0039-5100107 ASHLEY VALLEY UT
12/ 1/94
Summary: THE GRANTEE HAD ABANDONED THE ALTERNATIVE EFFLUENT LAND
APPLICATION FACILITIES THAT RESULTED IN ABOUT $1.2 OF FEDERAL
COSTSSHARE QUESTIONED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: AS OF 9/96, MEETINGS WITH ALL PARTIES HAVE NOT RESULTED IN
A FINAL SOLUTION TO MITIGATE THE ENDANGERED SPECIES PROBLEM
ENGINEERING REPORT FOR REPLACEMENT OF THE FACILITIES IS UNDER
REVIEW.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION BY 12/31/96
EXPECT
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E2CWN3-08-0054-6300011 RAMSEY COUNTY
ND
12/ 5/95
Summary: QUESTIONED COSTS CONSIST OF $200,000 OF ENGINEERING
COSTINCURRED AFTER THE CONSTRUCTION PERIOD OF PERFORMANCE,
$113,405 OFUNREASONABLE FORCE ACCOUNT TRAINING, AND $32,785 OF
PROJECT COSTS IN EXCESS OF THE 105 PERCENT REGULATION LIMITATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: ON 3/21/96, THE REGION PROPOSED A DECISION TO THE OIG
WHICH THE OIG FOUND UNACCEPTABLE. THE REGION MET WITH OIG AND
PROGRAM STAFF TO ARRANGE A SETTLEMENT AND PROVIDE MORE
INFORMATION. THE REGIONAL COUNSEL HELD AN ON-SITE MEETING WITH
THE GRANTEE TO OBTAIN MORE INFORMATION.
56
OFFICE OF INSPECTOR GENERAL
-------
ASSIGNMENT CONTROL
NUMBER
FINAL REPORT
ISSUED
ASSIGNMENT CONTROL
NUMBER
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION-
DECISION EXPECTED 10/31/96.
IG FOLLOWUP STATUS AS OF 9/30/96
N3HVJ5-08-0048-6500058
STATE OF NORTH DAKOTA
ND
3/15/96
IG FOLLOWUP STATUS AS OF 9/30/96 [3]
S2CWNO-09-0076-3300080 LAS VIRGENES MWD
Summary
9/30/93
INELIGIBLE COSTS OF $5,091,815 INCLUDES: $42,564 FOR
CONSTRUCTION COSTS NOT INCURRED; $192,643 OF INTEREST EARNED;
$647,791 FOR UNALLOWABLE ARCHITECT/ENGINEERING (A/E) AND
ADMINISTRATIVE; $1,919,244 FOR A/E AND CONSTRUCTION OUTSIDE SCOPE OF
PROJECT $2,289,573 RELATED TO EXCESS CAPACITY AND $757,976
UNREASONABLE A/E COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
RESOLUTION WAS REACHED BETWEEN THE OIG AND THE REGION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE OIG
CLOSED THIS AUDIT ON 10/3/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [5J Report closed 10/3/96.
S2CWN2-09-0091-4300051 VALLEJO SAN 4 FLOOD CONTROL CA 9/29/94
Summary: INELIGIBLE COSTS OF $5,525,458 INCLUDES $712,246 OF
UNALLOWABLE ARCHITECT/ENGINEERING FEES; $3,162,957 OF EARNED
INTEREST NOT CREDITED TO THE GRANT, AND $1,650,255 OF UNALLOWABLE
CONSTRUCTION. UNREASONABLE COSTS OF $3,874,497 REPRESENTED UNUSED
FACILITIES
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
IN DRAFTING THE FINAL DETERMINATION LETTER, THE STATE WATER
RESOURCES CONTROL BOARD (SWRCB) DISCOVERED NUMEROUS CALCULATION
ERRORS IN THE ELIGIBLE COSTS OF CHANGE ORDERS AND CONSTRUCTION. THE
ERRORS MUST BE CORRECTED BEFORE
THE DRAFT FINAL DETERMINATION LETTER IS COMPLETE. THE SWRCB AND OIG
ARE NEGOTIATING THE DRAFT FINAL DETERMINATION LETTER.
TITLE
FINAL REPORT
ISSUED
Summary: QUESTIONED COSTS OF $1,945,213 ARE FISCAL 1990 AND 1991
FUNDS GIVEN TO BORROWERS UNDER THE CAPITALIZATION GRANT FOR STATE
REVOLVING FUNDS WHERE LOAN DOCUMENTS DID NOT REQUIRE COMPLIANCE WITH
THE SINGLE AUDIT ACT.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
RESPONSE FROM THE STATE ON THE BOND BANK ISSUE WAS RECEIVED BY THE
WATER PROGRAM ON 4/96.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE REGION
EXPECTS RESOLUTION BY 10/31/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
Regional Administrator - Region 9
E2AWT3-09-0082-3400037 SAN DIEGO, CITY OF CA 3/29/93
Summary: INELIGIBLE COST INCLUDES: $209,577 OF UNALLOWABLE
CONSTRUCTION COSTS; $141,043 OF SETTLEMENT COST NOT CREDITED TO
GRANT; AND $334,271 OF UNALLOWABLE ENGINEERING. UNREASONABLE
COSTS OF $802,163 ARE PENDING REEVALUATION BY SWRCB.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE SWRCB IS CURRENTLY RESEARCHING THE VARIOUS AUDIT
ISSUES AND
DRAFTING A FINAL DETERMINATION LETTER.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY 3/31/97.
IG FOLLOWUP STATUS AS OF 9/30/96 [1
Regional Administrator - Region 10
P2CWN1-10-0049-3300076
SEASIDE, CITY OF OR 9/30/93
Summary: THE CITY OF SAN DIEGO HAS CONSTRUCTED AN $11.8 MILLION LAND
OUTFALL WHICH WILL NOT BE USED BY THE CITY FOR THE INTENDED PURPOSE
OF THE GRANT NOR WILL IT BE USED IN THE FORESEEABLE FUTURE.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE OUTFALL PROJECT IS A JOINT EFFORT WITH THE INTERNATIONAL
BOUNDARY AND WATER COMMISSION. THE AUDIT CANNOT BE RESOLVED UNTIL A
REQUIREMENT FOR SECONDARY TREATMENT IS DETERMINED. SAN DIEGO
RECEIVED A 301(H) WAIVER. AS OF JULY, EPA DEOBLIGATED THE BALANCE OF
GRANT FUNDS (EXCEPT MITIGATION MEASURE EXPENSES)AND AUDITORS ARE
CONDUCTING FIELD WORK.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
IS EXPECTED BY MARCH 1997.
Summary: INELIGIBLE COST OF $97,155 INCLUDES $7,889 OF
UNALLOWABLEFORCE ACCOUNT AND $89,266 OF CONSTRUCTION COSTS
RELATED TO SERVICELATERALS. COSTS OF $188,202 WERE NOT SUPPORTED
BY SOURCE DOCUMENTATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE REGION HAS BEEN OBTAINING INFORMATION, COMMENTS, AND
DOCUMENTATION FROM THE STATE AND OPERATIONS OFFICE. THE REGION
WILL SUBMIT A REVISED DRAFT FINAL DETERMINATION LETTER TO THE OIG
BY 12/12/96.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [0]
P2CWN1-10-0041-3300077 METROPOLITAN WASTEWTR. MGT. OR
9/30/93
Summary: INELIGIBLE COSTS OF $2,511,772 INCLUDES: $26,970 OF
MISCELLANEOUS COSTS, $107,481 OF INSURANCE PREMIUMS, $181,830
ALLOCABLE TO INELIGIBLE PERCENT; $2,195,491 OUTSIDE SCOPE OF
PROJECT $6,657,189 NOT SUPPORTED BY
ADEQUATE SOURCE DOCUMENTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE REGION RECEIVED A DEVIATION FROM HEADQUARTERS.
PENDING EVALUATION AND REVISION OF THE DRAFT FINAL DETERMINATION
LETTER, EXPECT TO FORWARD IT TO THE OIG BY 11/1/96.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 []
P2CWN2-10-0068-4300013 WASILLA, CITY OF AK
12/15/93
Summary: INELIGIBLE COSTS OF $306,738 INCLUDED $182,188 OF COSTS
ALLOCABLE TO INELIGIBLE PORTION OF CONSTRUCTION; $122,647 OF
UNALLOWABLE ARCHITECT/ENGINEERING COSTS; AND $1,730 OF COSTS.
CLAIMED TWICE; COSTS OF $97,346 WERE NOT SUPPORTED BY SOURCE
DOCUMENTATION.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE REGION, STATE AND CITY HAVE BEEN GATHERING ADDITIONAL
INFORMATION AND DOCUMENTATION. THE REGION FORWARD A REVISED
DRAFT FINAL DETERMINATION LETTER TO THE OIG ON 8/23/96.
ADDITIONAL INFORMATION AND INVOICES WERE PROVIDED TO THE OIG ON
10/4/96.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [0]
P2CWN3-10-0034-4300039 NORTH BEND, CITY OF OR
6/27/94
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
IS EXPECTED BY 12/31/96.
Summary: INELIGIBLE COSTS OF $56,470 INCLUDES: $3,197 OF
UNREFUNDED P&S DEPOSITS $9,000 OF UNALLOWABLE CONSTRUCTION;
RESOLUTION $15,440 OF OPERATION AND MAINTENANCE RELATED COSTS; $28,833 COST
ALLOCABLE TO INELIGIBLE PERCENTAGE $88,853 OF UNSUPPORTED
ENGINEERING AND ADMINISTRATIVE COSTS.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
S2CWN3-09-0098-6300015 SAN BERNARDINO, CITY OF CA 2/ 7/96
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE REGION RECEIVED ADDITIONAL PARTIAL DOCUMENTATION FROM
THE CITY. THE DOCUMENTS MUST BE ANALYZED AND EVALUATED BEFORE
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
57
-------
ASSIGNMENT CONTROL
NUMBER
FINAL REPORT
ISSUED
ASSIGNMENT CONTROL
NUMBER
FINAL REPORT
ISSUED
THE REGION CAN REVISE THE DRAFT FINAL DETERMINATION LETTER. EXPECT
TO FORWARD DRAFT FINAL DETERMINATION LETTER TO THE DIG BY 11/15/96.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ 1
E2CWN5-10-0018-6300010 MONTESANO, CITY OF WA 11/30/95
Summary: COSTS OF $113,637 REPRESENT ADMINISTRATIVE AND ENGINEERING
COSTS ALLOCABLE TO THE INELIGIBLE PORTION OF THE CONSTRUCTION
PROJECT.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE DIG AGREED TO THE PROPOSED DRAFT FINAL DETERMINATION LETTER ON
7/1/96. THE STATE HAS ADDITIONAL COMMENTS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECT TO
ISSUE THE FINAL DETERMINATION LETTER BY 11/15/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [1)
E5CGL5-10-0053-6100060 PUYALLUP TRIBE SPECIAL REV WA 1-1/21/95
*Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE-
THE REGION EXPECTS TO FORWARD A DRAFT FINAL DETERMINATION LETTER TO
THE OIG BY 11/19/96.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
Contracts Management Division - RTF
E8CAP3-01-0060-6400009 ALLIANCE TECHNOLOGIES CORP MA ll/ 3/95
•Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE CONTRACTING OFFICER NEEDS TO COMPLETE AN ANALYSIS OF A COST
OVERRUN SITUATION TO DETERMINE IF THE
GOVERNMENT WILL FUND THE OVERRUN. THE EPA-OIG STATES THAT A PORTION
OF THE OVERRUN IS ALLOWABLE.
* DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
ANTICIPATES THE CONTRACT WILL BE CLOSED BY 12/31/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ J
D8EML6-03-0136-6100154 DYNCORP-NMI VA
•Summary:
3/26/96
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
CONTRACTING OFFICER NEEDED TO CONDUCT ANALYSIS OF THE TOTAL AMOUNT
OF FIXED FEE EARNED. FINAL DETERMINATION SHOULD BE MADE BY THE END
OF OCTOBER.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECT
CLOSE OUT BY 12/31/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E8CMP2-23-0178-5400001 PEI ASSOC OH 10/ 3/94
Summary: WE QUESTIONED $175,940 OF UNSUPPORTED LABOR AND ASSOCIATED
OVERHEAD COSTS. WE ALSO QUESTIONED $52,181 OF INELIGIBLE OVERHEAD
COSTS BILLED IN EXCESS OF NEGOTIATED INDIRECT RATES.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE.
CURRENTLY ESTABLISHING PRE-NEGOTIATION POSITION. COMPLETION OF
NEGOTIATIONS BY 10/31/96. COMPLETION OF CONTRACT MODIFICATIONS BY
11/28/96.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECT
CLOSEOUT BY 12/31/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
0AM Cost Advisory and Financial Analysis Division - CPRN
D8DML3-01-0132-6100041 ABB ENVIRONMENTAL SERVICES ME 10/30/95
Summary: INDIRECT COST RATE AGREEMENTS WILL BE ISSUED UPON
RECEIPT OF ASSIST AUDIT AS CORPORATE GENERAL AND ADMINISTRATIVE
RATES. NO EXCEPTIONS TO DIRECT COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE OIG AGREED TO POSTPONE AUDIT RESOLUTION BECAUSE THE
PROGRAM OFFICE NEEDS THE RESULTS OF THE DCAA AUDIT OF CORPORATE
ALLOCATION
COSTS IN ORDER TO FINALIZE THE INDIRECT RATES WITH THE
CONTRACTOR.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
EXPECTED RESOLUTION IS 12/30/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [0]
P9BGL1-02-0155-5100122 ECOLOGY & ENVIR NY 12/23/94
Summary: WITH THE EXCEPTION OF SELLING, GENERAL AND
ADMINISTRATIVERATES, NO EXCEPTION TO THE CONTRACTOR'S PROPOSED
INDIRECT COST RATES WERE NOTED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE AUDIT INVOLVES A NUMBER OF COMPLEX ISSUES WHICH WILL
REQUIRE ADDITIONAL TIME TO RESOLVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION.
ANTICIPATE NEGOTIATIONS TO BE CONCLUDED BY 11/30/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ 1
P9DGL1-02-0154-5100125 ECOLOGY S. ENVIR NY 12/28/94
Summary: WITH THE EXCEPTION OF SELLING, GENERAL AND
ADMINISTRATIVE RATES, NO EXCEPTION TO THE CONTRACTOR'S PROPOSED
INDIRECT COST RATES WERE NOTED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: AUDIT INVOLVES A NUMBER OF COMPLEX ISSUES WHICH WILL
REQUIRE ADDITIONAL TIME TO RESOLVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS ANTICIPATED TO BE COMPLETED BY 11/30/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9DFL3-02-0165-6100078 EBASCO SERVICES INC. NY 12/11/95
•Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: DCAA IS REEXAMINING SOME OF THE COSTS. THE OIG AGREED TO
THE REEXAMINATION. DCAA AUDIT EXPECTED TO BE ISSUED BY 12/30/96.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION EXPECTED BY 3/31/97.
IG FOLLOWUP STATUS AS OF 9/30/96 [0]
P9DGL2-02-0134-6100093 ECOLOGY AND ENVIRONMENT NY 1/24/96
Summary WITH THE EXCEPTION OF SELLING, GENERAL, AND
ADMINISTRATIVE RATES, NO EXCEPTIONS TO THE CONTFACTORS PROPOSED
INDIRECT COST RATES WERE NOTED.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: AUDIT INVOLVES A NUMBER OF COMPLEX ISSUES WHICH WILL
REQUIRE ADDITIONAL TIME TO RESOLVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION-
ANTICIPATE NEGOTIATIONS TO BE CONCLUDED BY 11/30/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D8BML6-04-0029-6100070 MANTECH ENVIRONMENTAL NC 11/29/95
•Summary
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: AUDIT INVOLVES A NUMBER OF COMPLEX ISSUES WHICH WILL
REQUIRE ADDITIONAL TIME TO RESOLVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
58
OFFICE OF INSPECTOR GENERAL
-------
ASSIGNMENT CONTROL
NUMBER
TITLE
FINAL REPORT
ISSUED
ASSIGNMENT CONTROL
NUMBER
FINAL REPORT
ISSUED
NEGOTIATIONS ANTICIPATED TO BE COMPLETED BY DECEMBER 2, 1996.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E8DML3-04-0260-4100357 EHRT KY 6/ 2/94
*Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE CONTRACTOR HAS FILED FOR BANKRUPTCY AND IS NOW OUT OF BUSINESS.
THERE ARE NO COMPANY OFFICIALS WITH WHOM WE CAN NEGOTIATE. ALL
CONTACT AND CORRESPONDENCE IS THROUGH THE CONTRACTOR'S ATTORNEY.
RESOLUTION OF OUTSTANDING QUESTIONED COSTS ARE BEING ADDRESSED AT
THE CONTRACT LEVEL BY THE INDIVIDUAL CONTRACTING OFFICERS FINAL
DECISION OR THROUGH BANKRUPTCY COURT.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: FINAL
RESOLUTION EXPECTED BY 12/30/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9BKL3-04-0034-3100010 EHRT KY 10/ 9/92
* Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THE CONTRACTOR HAS FILED FOR BANKRUPTCY AND IS NOW OUT OF BUSINESS.
THERE ARE NO COMPANY OFFICIALS WITH WHOM WE CAN NEGOTIATE. ALL
CONTACT AND CORRESPONDENCE IS THROUGH THE CONTRACTOR'S ATTORNEY
RESOLUTION OF OUTSTANDING QUESTIONED COSTS ARE BEING ADDRESSED AT
THE CONTRACT LEVEL BY THE INDIVIDUAL CONTRACTING OFFICERS FINAL
DECISION OR THROUGH BANKRUPTCY COURT.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: FINAL
RESOLUTION EXPECTED BY 12/30/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9BKL5-04-0078-5100194 MANTECH TECHNOLOGY NC 2/24/95
* Summary •
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
AUDIT RESULTS CONTAIN COMPLEX ISSUES WHICH REQUIRES EXTENSIVE
DISCUSSION HOWEVER, A NEGOTIATED SETTLEMENT IS POSSIBLE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECT
RESOLUTION BY 12/2/96
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9BJL3-07-0100-5100531 DPRA INC 9/29/95
* Summary.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
NEGOTIATIONS ARE IN PROCESS PENDING RESOLUTION OF ALLOWABILITY OF
CERTAIN COSTS RELATED TO BUSINESS TRAVEL AND MEALS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: FINAL
RESOLUTION EXPECTED BY 11/30/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9CJL3-07-0162-5100532 DPRA,INC. KS 9/29/95
* Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
NEGOTIATIONS ARE IN PROCESS PENDING RESOLUTION OF ALLOWABILITY OF
CERTAIN COSTS RELATED TO BUSINESS TRAVEL AND MEALS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECT
RESOLUTION BY 11/30/96
IG FOLLOWUP STATUS AS OF 9/30/96 t ]
S5DGN2-09-0047-4300033 CA DEPT OF HLTH ICRP CA 3/31/94
* Summary•
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
THERE ARE COMPLEX ISSUES WHICH WILL TAKE MUCH DISCUSSION. HOWEVER,
A NEGOTIATED SETTLEMENT IS POSSIBLE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION- EXPECT
RESOLUTION BY 2/28/97.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E9EFP4-22-0176-6400002 ICF KAISER ENG INC D/S 12/93 10/18/95
* Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: DETERMINATION OF INADEQUACY AND NONCOMPLIANCE ISSUED TO THE
CONTRACTOR
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION OF COMPLEX ACCOUNTING ISSUES EXPECTED BY 6/30/97.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E9EFP4-22-0437-6400018 ICF INTN'L-CAS 403 0/H INS. 12/ 6/95
*Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: NOTIFICATION OF NONCOMPLIANCE ISSUED TO THE CONTRACTOR.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION OF COMPLEX ACCOUNTING ISSUES EXPECTED BY 6/30/97
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
P8BMP1-23-0339-3400050 PEI ASSOC FY 89 OH 5/13/93
Summary: THE QUESTIONED COSTS DO NOT REFLECT AN ADJUSTMENT FOR
INDIRECT COSTS. INELIGIBLE COSTS OF $284,000 ARE DUE TO AN
INADEQUATE BILLING SYSTEM. UNSUPPORTED COSTS OF $530,000 WERE
DUE TO INTER-COMPANY TRANSFERS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:QUESTIONED DIRECT COSTS HAVE BEEN REFERRED TO THE
APPROPRIATE CONTRACTING OFFICERS. THE QUESTIONED DIRECT COSTS
WILL BE RESOLVED ON A CASE-BY-CASE BASIS AS THE INDIVIDUAL
CONTRACTS ARE CLOSED OUT. THE DIG WILL PERFORM CLOSE-OUT AUDITS.
THE CONTRACT CLOSE-OUTS ARE IN PROGRESS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
P8BMPO-23-0177-3400062 PEI ASSOC FY 87/88 OH 6/14/93
Summary: WE QUESTIONED AS INELIGIBLE $759,941 OF COST BILLED BUT
NOT INCURRED. WE ALSO QUESTIONED AS UNSUPPORTED $1,224,486, 48
PERCENT OF WHICH WAS DUE TO USING CATALOG PRICES. COSTS WERE NOT
ADJUSTED FOR AUDITED INDIRECT RATES.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: QUESTIONED DIRECT COSTS HAVE BEEN REFERRED TO THE
APPROPRIATE CONTRACTING OFFICERS. THE QUESTIONED DIRECT COSTS
WILL BE RESOLVED ON A CASE-BY-CASE BASIS AS THE INDIVIDUAL
CONTRACTS ARE CLOSED OUT. THE DIG WILL PERFORM CLOSE-OUT AUDITS
THE CONTRACT CLOSE-OUTS ARE IN PROGRESS. UNSUPPORTED COST IN THE
AMOUNT OF $626,555 HAVE BEEN RESOLVED UNDER CONTRACT
NO.68-01-7084.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [3]
QAM Cost Advisory and Financial Analysis Division
Financial Analysis Branch
P9DGL2-01-0237-5100135 TRC ENVIRONMENTAL CONSULT. CT I/ 9/95
Summary•
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: RATE AGREEMENT HAS BEEN ISSUED FOR INDIRECT COSTS. COST
QUESTIONED HAS BEEN SUSTAINED QUESTIONED COST WILL BE RECOVERED
ON THE FINAL VOUCHER DURING CONTRACT CLOSEOUT.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
59
-------
ASSIGNMENT CONTROL
NUMBER
TITLE
FINAL REPORT
ISSUED
ASSIGNMENT CONTROL
NUMBER
FINAL REPORT
ISSUED
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9BKL2-03-0599-4100295 KEYDATA SYSTEMS INC VA 5/18/94
Summary: DCAA QUESTIONED $233,278 OF COSTS INCURRED DCAA ALSO
CONSIDERS $431,395 TO BE EXCESS COSTS BILLED TO EPA.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
BOARD OF CONTRACT APPEALS SETTLEMENT OF THE CONTRACTOR'S CLAIM WILL
NOW ALLOW THE CONTRACTING OFFICER TO SETTLE REMAINING AUDIT ISSUES.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
IS EXPECTED BY 12/31/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9EFL5-03-0108-5100162 NUS MD 2/ 9/95
Summary: IN DCAA'S OPINION, THE CONTRACTOR IS NOT ALTOGETHER
COMPLIANT WITH THE SPECIAL PROVISIONS OF THE CONTRACT.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
DUE TO THE COMPLEX CONTRACT COMPLIANCE ISSUES, THE CONTRACTING
OFFICER IS CONSULTING WITH REGIONAL LEGAL COUNSEL AND THE AUDITOR IN
ORDER TO DEVELOP A POSITION PAPER FOR NEGOTIATIONS. EXTENDED
DISCUSSIONS HAVE BEEN ONGOING WITH THE CONTRACTOR INCLUDING FOUR
LETTERS IN THE PAST THREE MONTHS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECT
RESOLUTION BY DECEMBER 31, 1996.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E9CHN4-04-0227-5300020 EHRT KY
7/ 5/95
Summary THE CONTRACTOR CLAIMED INELIGIBLE COSTS TOTALING $175,000
RELATED TO A 24 HOUR CALL CENTER AND QUALITY ASSURANCE AND QUALITY
CONTROL PROGRAM. THE CONTRACTOR ALSO CLAIMED UNSUPPORTED COSTS
TOTALING $75,000
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
CONTRACTOR FILED FOR BANKRUPTCY ON 2/16/96. EPA'S OGC INITIATED A
PROOF OF CLAIM ON BEHALF OF EPA ON 5/19/96.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION- ESTIMATED
RESOLUTION IS DECEMBER 31, 1996.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
P9BGL4-10-0107-4100398 CH2M REM/FIT 87-89 C.I. OR
6/10/94
Summary. NET COSTS QUESTIONED OF $173,335 CONSIST OF INELIGIBLE
OVERTIME COSTS OF $20,178, INELIGIBLE MOVING COSTS OF $8,323,
INELIGIBLE PUBLICATIONS COST OF $128, AND INELIGIBLE OVERHEAD CREDIT
OF $3,045. UNSUPPORTED COSTS
INCLUDED TRAVEL COSTS OF $16,027 AND COMPUTER COSTS OF $131,724.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE.
CONTRACTING OFFICER IS IN PROCESS OF DEVELOPING A PRE-NEGOTIATION
POSITION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS EXPECTED TO BE COMPLETE BY JANUARY 31, 1997.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
P9BGL4-10-0117-4100417 CH2M TECH 1 C.I. 1987-88 OR 6/22/94
Summary: NET COSTS QUESTIONED OF $212,587 CONSIST OF INELIGIBLE
OVERTIME LABOR OF $7,754 AND INELIGIBLE OVERHEAD CREDIT OF $19,177.
UNSUPPORTED COST CONSIST OF TRAVEL COSTS OF $108,035 AND COMPUTER
COST OF $115,975.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
CONTRACTING OFFICER IS IN PROCESS OF DEVELOPING A PRE-NEGOTIATION
POSITION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION.
NEGOTIATIONS ANTICIPATED TO BE COMPLETE BY JANUARY 31, 1997
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9BGL3-10-0088-4100471 URS FY 1989 AC WA 8/ 2/94
* Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE CONTRACTING OFFICER IS IN PROCESS OF RESOLVING THE
REMAINING OPEN ISSUES FOR FISCAL YEARS 1987 THROUGH 1993.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
ESTIMATED COMPLETION DATE IS 11/15/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [3]
P9BGL4-10-0129-4100489 CH2M TECH II C.I. 1988-89 OR 8/16/94
Summary NET COSTS QUESTIONED OF $92,160 CONSIST OF INELIGIBLE
OVERTIME LABOR OF $2,507 AND INELIGIBLE OVERHEAD CREDIT OF
$20,817. UNSUPPORTED COSTS INCLUDED TRAVEL COSTS OF $40,650 AND
COMPUTER COSTS OF $69,820.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE CONTRACTING OFFICER IS IN PROCESS OF DEVELOPING A
PRE-NEGOTIATION POSITION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS ANTICIPATED TO BE COMPLETE BY JANUARY 31, 1997.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
P9BGL4-10-0132-4100512 CH2M ARCS WEST 1989 COSTS OR 8/30/94
*Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: CONTRACTING OFFICER IS IN PROCESS OF DEVELOPING A
PRE-NEGOTIATION POSITION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS ANTICIPATED TO BE COMPLETE BY NOVEMBER 1, 1996.
IG FOLLOWUP STATUS AS OF 9/30/96 []
P9BGL4-10-0147-4100566 CH2M ARCS III 1988-89 COSTS OR 9/28/94
Summary: UNSUPPORTED COSTS OF $115,000 CONSIST OF TRAVEL COSTS OF
$42,000 AND COMPUTER COSTS OF $73,000. INELIGIBLE COSTS OF
$4,000
CONSIST OF OVERHEAD COSTS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: CONTRACTING OFFICER IS IN PROCESS OF DEVELOPING
A PRE-NEGOTIATION POSITION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS ANTICIPATED TO BE COMPLETE BY DEC2MBER 31, 1996.
IG FOLLOWUP STATUS AS OF 9/30/96 ( ]
D9BGN3-10-0089-6300001 URS AC 90-93 WA 10/16/95
Summary: DCAA QUESTIONS DIRECT LABOR OF $18,006, FRINGE OF
$2,488,OVERHEAD OF $131,031; ODC'S OF $2,690,211, SUBS OF
($2,521,264), GENERAL AND ADMINISTRATIVE COSTS OF $235,573; BiP
OF $104,345; AND OTHER OF $3,931.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE. THE CONTRACTING OFFICERS ARE WORKING TO RESOLVE THE
QUESTIONED COSTS WITH THE CONTRACTOR.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION.
EXPECTED COMPLETION DATE IS 4/30/97.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9BGN4-10-0026-6300007 CH2M CI 90-93 OR 11/13/95
Summary EPA-FAB IS ACTION OFFICIAL FOR DIRECT COST ISSUES:
$452,873 ADJUSTMENTS FOR WRITE-UPS; $51,556 MEALS; $51,880
ENVIRONMENTAL LAB VARIANCES. ALSO, UNRESOLVED COSTS OF
$5,229,000 IN 1990; $3,841,000 IN 1991; $2,712,000 IN 1992;
$4,051,000 IN 1993.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE CONTRACTING OFFICERS ARE CURRENTLY IN THE PROCESS OF
NEGOTIATING PRIOR YEAR AUDITS. UPON COMPLETION OF THE PRIOR YEAR
AUDIT NEGOTIATIONS, THE CONTRACTING OFFICERS WILL START
60
OFFICE OF INSPECTOR GENERAL
-------
ASSIGNMENT CONTROL
NUMBER
FINAL REPORT
ISSUED
ASSIGNMENT CONTROL
NUMBER
NEGOTIATIONS ON FY 1990 THROUGH 1993.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECT TO
RESOLVE BY 6/30/97.
IG FOLLOWUP STATUS AS OF 9/30/96 [0]
E9BHP4-23-0002-5400015 OHM REM FY 87
OH
11/18/94
Summary: WE QUESTIONED $61,773 RELATED TO: (1) EXCESSIVE PROFIT OF
AFFILIATES' COSTS; (2) INELIGIBLE AND UNSUPPORTED TRAVEL; AND (3)
UN-SUPPORTED SUBCONTRACTOR CHARGES.
CONTRACTOR ALSO HAD MAJOR CONTRACT NONCOMPLIANCE PROBLEMS, AND WAS
CITED FOR A CAS 401 VIOLATION.
EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
BOTH CONTRACTING OFFICERS HAVE PREPARED THEIR POSITIONS AND ARE IN
PROCESS OF NEGOTIATIONS WITH THE CONTRACTOR. THE FINANCIAL
ADMINISTRATIVE CONTRACTING OFFICER MUST RESOLVE COST ACCOUNTING
STANDARD ISSUES BEFORE CONTRACTING OFFICERS CAN FULLY RESOLVE
QUESTIONED COSTS
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: ESTIMATED
COMPLETION DATE IS DECEMBER 31, 1996.
IG FOLLOWUP STATUS AS OF 9/30/96
E9BHP4-23-0003-5400020
OHM REM FY 88 OH
12/ 6/94
summary. WE QUESTIONED $2,209,975 RELATED TO: (1) EXCESSIVE PROFIT OF
AFFILIATES COSTS, (2) UNSUPPORTED SUBCONTRACTOR CHARGES, AND (3)
INELIGIBLE OVERHEAD RATES. CONTRACTOR ALSO HAD MAJOR CONTRACT
NONCOMPLIANCE PROBLEMS AND CAS 401 VIOLATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
$2,119 OF QUESTIONED COSTS APPLICABLE TO CONTRACT 68-W8-0101 HAS
BEEN CREDITED ON A PREVIOUS VOUCHER. $74,253 OF QUESTIONED COSTS
APPLICABLE TO CONTRACT 68-01-7404 IS DUE TO A COST ACCOUNTING
STANDARD NONCOMPLIANCE WHICH THE FINANCIAL ADMINISTRATIVE
CONTRACTING OFFICER IS IN PROCESS OF RESOLVING. THE
QUESTIONED($70,219) AND UNSUPPORTED)$2,063,384) COSTS APPLICABLE TO
CONTRACT 68-01-7445 ARE BEING RESOLVED BY ANOTHER CONTRACTING
OFFICER.
TITLE
FINAL REPORT
ISSUED
CONTRACTING OFFICER IS IN PROCESS OF RESOLVING. THE
QUESTIONED($200,902) AND UNSUPPORTED ($12,515) COSTS APPLICABLE
TO CONTRACT 68-01-7445 ARE BEING RESOLVED BY ANOTHER CONTRACTING
OFFICER.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION IS EXPECTED BY 1/31/97
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E9BHP4-23-0006-5400031 OHM REM FY 91
OH
1/13/95
Summary: WE QUESTIONED $482,217 RELATED TO: (1) EXCESSIVE PROFIT
OF AFFILIATES' COSTS, (2) UNALLOWABLE GENERAL AND ADMINISTRATIVE
COSTS, AND (3) UNSUPPORTED SUBCONTRACTOR CHARGES. CONTRACTOR
ALSO HAD MAJOR CONTRACT NONCOMPLIANCE AND CAS 401 VIOLATIONS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: $33,528 OF QUESTIONED COSTS APPLICABLE TO CONTRACT
68-W8-0101 WILL BE CREDITED ON A SUBSEQUENT VOUCHER. $16,650 OF
QC APPLICABLE TO CONTRACT 68-W8-0101 AND $25,158 OF QUESTIONED
COSTS APPLICABLE TO CONTRACT 68-01-7404 ARE DUE TO COST
ACCOUNTING STANDARD NONCOMPLIANCE WHICH THE FINANCIAL
ADMINISTRATIVE CONTRACTING OFFICER IS RESOLVING. THE QUESTIONED
($105,837) AND UNSUPPORTED ($301,044) COSTS APPLICABLE TO
CONTRACT 68-01-7445 ARE BEING RESOLVED BY ANOTHER CONTRACTING
OFFICER.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION.
RESOLUTION IS EXPECTED BY 1/31/97
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
QAM Cost Advisory and Financial Analysis Division
Washington Cost Advisory Board
D8BML4-03-0345-4100343 PRC, INC. VA 6/ 1/94
* Summary:
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: AGREEMENT COULD NOT BE REACHED BETWEEN THE CONTRACTING
OFFICER AND THE CONTRACTOR. THE CONTRACTING OFFICER HAS
REQUESTED A REVISED SUBMISSION.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION-
IS EXPECTED BY 1/31/97
RESOLUTION = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E9BHP4-23-0004-5400025 OHM REM FY 89
IG FOLLOWUP STATUS AS OF 9/30/96
OH
12/14/94
D9BGL5-06-0020-5100287
VERTAC-VSC TX
4/17/95
Summary. WE QUESTIONED $646,574 RELATED TO- (1) EXCESSIVE PROFIT OF
AFFILIATES COSTS, (2) UNSUPPORTED SUBCONTRACTOR CHANGES, AND (3)
INELIGIBLE OVERHEAD RATES. CONTRACTOR ALSO HAD MAJOR CONTRACT
NONCOMPLIANCE PROBLEMS AND CAS 401 VIOLATION
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
$39,355 OF QUESTIONED COSTS APPLICABLE TO CONTRACT 68-W8-0101 HAS
BEEN CREDITED ON A PREVIOUS VOUCHER. $104,285 OF QUESTIONED COSTS
APPLICABLE TO CONTRACT 68-01-7404 IS DUE TO COST ACCOUNTING STANDARD
NONCOMPLIANCE WHICH THE FINANCIAL ADMINISTRATIVE CONTRACTING OFFICER
IS IN PROCESS OF RESOLVING. THE QUESTIONED($264,653) AND UNSUPPORTED
($238,281) COSTS APPLICABLE TO
CONTRACT 68-01-7445 ARE BEING RESOLVED BY ANOTHER CONTRACTING
OFFICER.
Summary: THE REPORT QUESTIONED $9,453,222 OF DEPRECIATION AND
LOSS ASSOCIATED WITH THE ON-SITE INCINERATOR. THE CONTRACTOR
BASED LOSS COMPUTATIONS ON NOT RECEIVING 18,000 TONS OF MATERIAL
TO BURN. CONTRACTUAL REQUIREMENTS WITH EPA ONLY INCLUDED 5,023
TONS OF MATERIAL.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE. THERE HAS BEEN A REVISION TO THE ORIGINAL CLAIM AND
ADDITIONAL RESEARCH AND REVIEW WILL HAVE TO BE PERFORMED.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS ANTICIPATED TO BE CONCLUDED DURING FOURTH QUARTER OF
FY 1997
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
IS EXPECTED BY 1/31/97.
RESOLUTION IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9EKN5-10-0033-5300016 MK FIN CAP ID
5/24/95
IG FOLLOWUP STATUS AS OF 9/30/96 [ J
E9BHP4-23-0005-5400027 OHM REM FY 90 OH
12/22/94
Summary WE QUESTIONED $259,289 RELATED TO. (1) EXCESSIVE PROFIT OF
AFFILIATES' COSTS; (2) UNALLOWABLE GENERAL AND ADMINISTRATIVE COSTS;
AND (3) UNSUPPORTED SUBCONTRACTOR CHARGES. CONTRACTOR ALSO HAD
MAJOR CONTRACT NONCOMPLIANCE AND CAS 401 VIOLATION.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE•
$2,179 OF QUESTIONED COSTS APPLICABLE TO CONTRACT 68-W8-0101 WILL BE
CREDITED ON A SUBSEQUENT VOUCHER. $7,046 OF QUESTIONED COSTS
APPLICABLE TO CONTRACT 68-W8-0101 AND $36,647 QUESTIONED COSTS
APPLICABLE TO CONTRACT 68-01-7404 ARE DUE TO COST ACCOUNTING
STANDARD NONCOMPLIANCE WHICH THE FINANCIAL ADMINISTRATIVE
Summary: THE CONTRACTOR'S FINANCIAL CONDITION IS HIGHLY
UNFAVORABLE. THE CONTRACTOR IS HAVING DIFFICULTY MEETING ITS
FINANCIAL OBLIGATIONS AND MAY NOT HAVE THE FINANCIAL RESOURCES TO
CONTINUE PERFORMING ON GOVERNMENT CONTRACTS UNLESS IT TAKES
DRASTIC MANAGEMENT ACTIONS.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE- NEGOTIATIONS IN PROCESS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS TO BE CONCLUDED BY NOVEMBER 30, 1996.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
APRIL 1, 1996 THROUGH SEPTEMBER 30, 1996
61
-------
ASSIGNMENT CONTROL
NUMBER
TITLE
FINAL REPORT
ISSUED
D8EML5-23-0008-6100045 OHM REM OH 10/31/95
•Summary: CONTRACTOR'S ACCOUNTING SYSTEM STILL CONTAINED
DEFICIENCIES,INCLUDING TIMEKEEPING PROBLEMS, OUT OF DATE ACCOUNTING
MANUALS, FLOOR CHECK PROBLEMS. DCAA PLANS A FOLLOW-UP AUDIT OF THE
ACCOUNTING SYSTEM AND INTERNAL CONTROLS IN FY 96.
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
NEGOTIATIONS TO BE CONCLUDED BY NOVEMBER 30, 1996.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: 11/30/96.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E9EHP5-23-0011-6400010 EQMI A/S OH ll/ 7/95
Summary: CONTRACTOR'S EQUIPMENT TRACKING SYSTEM CONTAINED
DEFICIENCIES THAT NEED CORRECTION. CONTRACTOR'S TRACKING SYSTEM
DOES NOT INTERFACE WITH ITS ACCOUNTING SYSTEM.
ASSIGNMENT CONTROL
NUMBER
TITLE
FINAL REPORT
ISSUED
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
NEGOTIATIONS IN PROCESS.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
NEGOTIATIONS EXPECTED TO BE COMPLETED BY NOVEMBER 30, 1996
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
TOTAL AUDITS EXCLUDING PREAWARDS ISSUED BEFORE REPORTING PERIOD FOR
WHICH NO MANAGEMENT DECISION WAS MADE DURING THE REPORTING PERIOD:
87
Contracts Management Division - RTF
D8AMP5-01-0182-6400004 NORTHBRIDGE ENVIRONMENTAL MA 10/26/95
•Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D8AML5-03-0345-5100525 UNIVERSAL SYSTEMS i TECH. VA 9/29/95
•Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
0AM Cost Advisory and Financial Analysis Division
Washington Cost Advisory Board
D8AML6-01-0011-6100118 PEQUAD ASSOC MA 2/22/96
•Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D8AMP6-01-0203-6400024 CADMUS GROUP MA 2/ 5/96
•Summary IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9AGL5-01-0185-6100064 ANEPTEK CORPORATION MA 11/22/95
•Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9AKL5-01-0181-6100069 METCALF 5, EDDY INC MA 11/29/95
•Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION
CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D9AKL5-01-0184-6100097 FOSTER WHEELER ENVIR CCRP NJ 2/ 5/96
•Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 (]
E9AGP5-01-0627-6400006 TRC-RFP W400072-G4 CT 10/27/95
•Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D8AML6-02-0032-6100139 KAPADIA CONSULTING NY 3/14/96
•Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION-
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D8AML5-03-0351-5100523 BOOZ ALLEN 9/29/9')
•Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D8AML5-03-0338-5100524 INTERNATIONAL RESOURCES GRP.DC 9/29/95
•Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISI3N HAS NOT BEEN
MADE: SEE SUMMARY ABOVE.
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
62
OFFICE OF INSPECTOR GENERAL
-------
ASSJGNMENT CONTROL ""^D ^1"*™ TITLE _ ISSUED
ISSUED NUMBER - iiii£ -- — -
D8AML6-03-0099-6100116 DECISION ANALYSIS CORP. VA 2/22/96 D9AGL5-08-0030-5100282 WESTERN TECHNOLOGY fc ENGINEEMT 4/17/95
-Summary: IN CONTRACT NEGOTIATION PROCESS .Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
SEE SUMMARY ABOVE. "^ SEE SUMMARY ABOVE'
JSS-SS A mama" DECISION: RESOLUTION LSS^TS55^^'S^!S^A>1II" DECISION:
IG FOLLOWUP STATUS AS OF 9/30/96 1 ] IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D8AML6-03-0107-6100136 ANTARES GROUP INC. MD 3/14/96 T CONTACT
•Summary: IN CONTRACT NEGOTIATION PROCESS _ EXpLANATION QF TRE REASONS ^^^ DECISION HAS NOT BEEN
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: MADE: SEE SUMMARY ABOVE.
SEE SUMMARY ABOVE. = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
CANNOT BE DETERMINED AT THIS TIME. ^ ^^ ^^ ^ Qp ^^ ( }
IG FOLLOWUP STATUS AS OF 9/30/96 [ ] D9AGL5-08-0028-5100355 MORRISON KNUDSEN CORP. ENVIRCO 6/ 9/95
D8AML6-03-0113-6100158 INTERNATIONAL DEVELOPMENT DC 3/27/96 'Summary: IN CONTRACT NEGOTIATION PROCESS
-Summary IN CONTRACT NEGOTIATION PROCESS - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: SEE SUMMARY ABOVE.
SEf SuS^ABO™ REAS°NS MANAGEMENT DECISION HAS N°T BEEN *"*'• - DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
SEE SUMMARY ABUVfc . RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
CANNOT BE DETERMINED AT THIS TIME.
Qf ^^ { }
IG FOLLOWUP STATUS AS OF 9/30/96 [ ] D9AGL5-08-0028-5100387 MORRISON KNUDSEN CORP. ENVIRCO
D9AFL6-03-0103-6100109 TECHNOLOGY & MANAGEMENT MD 2/16/96 6/27/95
•Summary: IN CONTRACT NEGOTIATION PROCESS _ -Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
SEE SUMMARY ABOVE. ™*>*'- SEE SUMMARY ABOVE.
- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
CANNOT BE DETERMINED AT THIS TIME. RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [] IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
D8AML5-05-0150-6100010 CHEMICAL ABSTRACT SV OH 10/ 4/95 D9AGL5-08-0028-5100427 MORRISON KNUDSEN CORP. ENVIRCO 7/21/95
•Summary: IN CONTRACT NEGOTIATION PROCESS •Summary: IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
SEE SUMMARY ABOVE. MADE: SEE SUMMARY ABOVE.
- DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION- RESOLUTION = DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
CANNOT BE DETERMINED AT THIS TIME. RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
IG FOLLOWUP STATUS AS OF 9/30/96 [ ] IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
E9AGP6-05-0038-6400017 PRC EMI RAC IL 12/ 5/95 P9AGL2-10-0089-4100225 CH2M ARCS IV TERM STLMT OR 3/28/94
•Summary: IN CONTRACT NEGOTIATION PROCESS Summary IN CONTRACT NEGOTIATION PROCESS
- EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: - EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
NEGOTIATIONS WERE CONCLUDED AND THE CONTRACTOR WAS THE SUCCESSFUL MADE: SEE SUMMARY ABOVE.
OFFEROR. _ DESIRED TIMETABLE poR ACHIEVING A MANAGEMENT DECISION:
= DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: CONTRACT RESOLUTION CANNOT BE DETERMINED AT THIS TIME.
AWARDED .
IG FOLLOWUP STATUS AS OF 9/30/96 [ ]
IG FOLLOWUP STATUS AS OF 9/30/96 [ ) Report closed 10/2/96
TOTAL PRKAWARD AUDITS ISSUED BEFORE REPORTING PERIOD FOR WHICH NOMANAGEMENT DECISION WAS MADE DURING THE REPORTING PERIODl 23
TOTAL AUDITS ISSUED BEFORE REPORTING PERIOD FOR WHICH NO MANAGEMENT DECISION WAS MADE DURING THE REPORTING PERIOD: 110*
Agency procedure* do not require the IG'« approval on Agency'* Management Decision on an audit (other than a preaward or an internal and
management audit) with the Federal chare of
-------
OIG MAILING ADDRESSES and TELEPHONE NUMBERS
OIG HOTLINE (202) 260-4977
Headquarters
Environmental Protection Agency
Office of Inspector General
401 M Street, S.W. (2441)
Washington, DC 20460
(202)260-3137
Atlanta
Environmental Protection Agency
Office of Inspector General
16th Floor-100 Alabama St. SW
Atlanta, GA 30303
Audit: (404) 562-9830
Investigations: (404) 562-9857
Boston
Environmental Protection Agency
Office of Inspector General
JFK Federal Building (OIG)
(office at 1 Congress St)
Boston, MA 02203
Audit: (617) 565-3160
lnvestigations:(617) 565-3928
Chicago
Environmental Protection Agency
Office of Inspector General
77 West Jackson Boulevard
13th Floor (IA-13J)
Chicago, IL 60604
Audit: (312) 353-2486
Investigations: (312) 353-2507
Cincinnati
Environmental Protection Agency
Office of Inspector General
MS: Norwood
Cincinnati, OH 45268-7001
Audit: (513) 366-4360
Investigations: (312) 353-2507 (Chicago)
Dallas
Environmental Protection Agency
Office of Inspector General (6OIG)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Audit: (214) 655-6621
Investigations: (404) 347-2398 (Atlanta)
Denver
Environmental Protection Agency
Office of Inspector General
999 18th Street, Suite 500
Denver, CO 80202-2405
Audit: (303) 294-7520
Investigations: (312) 353-2507 (Chicago)
Kansas City
Environmental Protection Agency
Office of Inspector General
726 Minnesota Avenue
(office at 630 Minnesota Ave)
Kansas City, KS 66101
Audit: (913) 551-7878
Investigations: (312) 353-2507 (Chicago)
New York
Environmental Protection Agency
Office of Inspector General
290 Broadway, Room 1520
New York, NY 10007-1866
Audit: (212) 637-3071
Investigations: (212) 637-3041
Philadelphia
Environmental Protection Agency
Office of Inspector General
841 Chestnut Street, 13th Floor
Philadelphia, PA 19107
Audit: (215) 566-5800
Investigations: (215) 566-2360
Research Triangle Park, NC
Environmental Protection Agency
Office of Inspector General
Catawba Building
Highway 54, Mail Drop 53
Research Triangle Park, NC 27711
Audit: (919) 541-2204
Investigations: (919) 541-1027
Sacramento
Environmental Protection Agency
Office of Inspector General
650 Capitol Mall, Suite 6309
Sacramento, CA 95814
Audit: (916) 551-1076
Investigations: (415) 744-2465 (SF)
San Francisco
Environmental Protection Agency
Office of Inspector General
75 Hawthorne St (1-1)
19th Floor
San Francisco, CA 94105
Audit: (415) 744-2445
Investigations: (415) 744-2465
Seattle
Environmental Protection Agency
Office of Inspector General
1111 3rd Avenue, Suite 1460
Seattle, WA 98101
Audit: (206) 553-4403
Investigations: (206) 553-1273
64
U S Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12tn MOOT
Chicago, IL 60604-3590
OFFICE OF INSPECTOR GENERAL
-------
GET A HOLD
ON SPENDING
REPORT FRAUD, WASTE, OR ABUSE TO THE
INSPECTOR GENERAL
HOTLINE
• INFORMATION IS CONFIDENTIAL
202-260-4977
S. ENVIRONMENTAL PROTECTION AGENCY • OFFICE OF THE INSPECTOR GENERAL • 401 M STREET S.W. WASHINGTON, D.C. 20460
&EPA
-------
------- |