United Slates
Environmental Protection
Aoency
inspector General (2441)
Washington DC 20460
EPA-3SO-R-97-002
November 1997
oEPA Office of Inspector General
Semiannual Report
to the Congress
ApriM, 1997 through
September 30, 1997
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Cover photo courtesy of U.S. Fish and Wildlife Service
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Foreword
Our office has completed its first year operating under the OIG strategic plan, and
piloting OIG annual performance planning and evaluation systems. Implementing
Government Performance and Results Act concepts, in concert with National Performance
Review recommendations and Inspectors General Vision Statement Reinvention Principles,
has helped us focus our audit and investigative programs and streamline our administrative
processes. More importantly, it has helped us work with the Agency to improve its delivery
of environmental programs.
The audits described in this semiannual report, such as our work in air enforcement
and hardrock mining, illustrate the success of our initial effort to transition from traditional
compliance audits to evaluating environmental program results. Our joint work with the
Agency to evaluate the success of procurement and contract management initiatives, and to
resolve problems that could have prevented the Agency from receiving an unqualified
opinion on its financial statement audit, illustrate our success in improving working
relationships. The investigations described in this semiannual report illustrate successes in
enforcing Federal criminal and civil laws, recovering funds, and maintaining public
confidence in Agency programs.
Our staff successfully addressed emerging issues to prevent future problems and loss
of Agency resources. Auditors and investigators worked closely with Agency and Army
Corps of Engineers staff to reduce the risk of fraudulent claims associated with EPA's
massive methyl parathion cleanup activities. Investigators and engineers identified
substandard materials during construction of a wastewater treatment plant that were
replaced, avoiding costly future repairs and environmental contamination.
The Federal Deposit Insurance Corporation (FDIC) Office of Inspector General
completed a quality control review of our Office of Audit. The review is similar in design and
scope to peer reviews of certified public accounting firms. The FDIC OIG said that the Office
of Audit's internal quality control system was operating effectively to provide reasonable
assurance that established policies, procedures, and applicable auditing standards were
being followed. We are proud of our Office of Audit. The review confirms the high quality of
its work.
I believe the Agency's commitment to improving management and performance, in
combination with the assistance we are committed to provide, will be the foundation for
improved environmental results.
Nikki L. Tinsley
Acting Inspector General
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INSPECTOR GENERAL VISION
STATEMENT
We are agents of positive change striving for continuous improvement in our
Agency's management and program operations, and in our own offices."
The Inspector General Act of 1978, as amended, requires the Inspector General to:
(1) conduct and supervise audits and investigations relating to programs and operations of
the Agency; (2) provide leadership and coordination, and make recommendations designed
to (A) promote economy, efficiency, and effectiveness and (B) prevent and detect fraud and
abuse in Agency programs and operations; and (3) fully and currently inform the
Administrator and the Congress about problems and deficiencies identified by the Office of
Inspector General relating to the administration of Agency programs and operations.
GOALS
O Help EPA achieve its environmental goals by improving the performance and integrity of EPA
programs and operations, by safeguarding and protecting the Agency's resources, and by dearly
reporting the results of our work
© Foster strong working relationships.
© Operate at the highest performance level.
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Contents
Executive Summary 1
The OIG in EPA-lts Role and Authority 3
Purpose and Reporting Requirements of the Office of Inspector General
Semiannual Report 3
Who's Who in the Office of Inspector General 4
Section 1-Office of Audit-Significant Findings
Programs 6
Financial Statements 17
Assistance Agreements 18
Contracts 26
Section 2-Report Resolution
Status Report on Perpetual Inventory of Reports in Resolution Process
for the Semiannual Period Ending September 30, 1997 31
Status of Management Decisions on IG Reports 32
Inspector General Issued Reports With Questioned Costs 32
Inspector General Issued Reports With Recommendations that Funds Be
Put to Better Use 33
Section 3-Office of Investigations-Significant Results
Summary of Investigative Results 35
Selected Prosecutive Actions 36
Civil and Administrative Actions to Recover EPA Funds 41
Selected Suspension and Debarment Actions 43
Section 4Fraud Prevention and Management Improvements
Advisory and Assistance Services 44
Review of Legislation and Regulations 45
OIG Management Initiatives 47
Committee on Integrity and Management Improvement 47
Hotline Activities 47
Appendices
Appendix 1-Reports Issued 48
Appendix 2-Summary of Reports Issued Without Management Decision 55
Appendix 3-Major Laws Administered by EPA 56
Appendix 4~Profile of Activities and Results 57
The complete text of selected audits is available through the EPA OIG internet home
page, http://www.epa.gov/oigearth/list997.htm
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Executive Summary
Section 1--
Office of Audit-Significant Findings
1. National Inconsistencies in Air Enforcement
and Compliance Assistance Programs Could
Result in Health and Environmental Risks
EPA could prevent inconsistent levels of enforcement,
use of publicity, and economic benefit penalty
assessments in the regions' and delegated agencies' air
enforcement programs. Also, EPA could help delegated
agencies avoid possible duplicate efforts in developing
similar compliance assistance activities and materials
(page 6).
2. Arkansas, Maryland, and Massachusetts Did
Not Report Significant Clean Air Act Violators
Arkansas, Maryland, and Massachusetts air inspection
programs did not identify and report numerous significant
violators (SV) of the Clean Air Act (CAA). Without proper
identification and reporting of SV information, EPA
regions could not adequately monitor the progress of
states in returning facilities to compliance or take timely
enforcement actions
(page 8).
3. EPA Can Do More to Help Minimize Hardrock
Mining Liabilities
Critical gaps in some Federal and state statutory and
regulatory authorities requiring financial assurances
could result in EPA assuming responsibility for cleaning
up additional hardrock mines. EPA had not effectively
implemented its existing statutory authorities or used non-
regulatory tools, such as partnerships, to minimize the
environmental impacts of hardrock mining and help
eliminate financial assurance gaps (page 10).
4. Regional Laboratories Need Results-
Oriented Management and Better National
Leadership.
EPA's regional laboratories' current processes are not
adequate to assist the Agency in meeting the
Government Performance and Results Act. Also, the
absence of a shared identity among regional laboratories
and a limited scope national leadership have resulted in
inefficient efforts to meet common needs (page 11).
5. Superfund Oversight Bills to Responsible
Parties Were Delayed for Years.
Region 3 took extraordinary amounts of time to bill
responsible parties for recovery of Superfund oversight
costs. In several instances, delays amounted to years,
even though the bills should have been sent annually.
Consequently, the Agency sometimes failed to recoup
large portions of the costs (page 13).
6. EPA Needs Internet Security to Protect
Integrity of Agency Data
EPA has not sufficiently developed or implemented
adequate controls to prevent or detect improper/illegal
access to its systems from the Internet. As a result, there
were six documented hacker attacks between 1992 and
1996, and likely many more in actuality
(page 14).
7. Security Over Region 4 Local Area Network
(LAN) Needs Strengthening
Region 4 did not have formal security or disaster recovery
plans for their LANs which contain sensitive agency
information. Also, the Region lacked a structured and
consistent process for rescinding access to its LANs
(page 15).
8. Maryland Department of the Environment
(MDE) Overstated Accomplishments
MDE significantly overstated Leaking Underground
Storage Tank (LUST) program accomplishments
and was erroneously paid up to $1.4 million by
EPA. In addition, MDE lacked documentation
explaining the acceptance of settlement amounts
less than full cost recovery
(page 18).
9. Better Management of Cooperative
Agreements for Lead-Based Paint Abatement
Training is Needed
EPA awarded cooperative agreements to the National
University Continuing Education Association Inc.
(NUCEA) and Regional Lead Training Centers (Centers)
to develop a national cadre of certified lead based paint
abatement specialists. Some of the funds were used to
train individuals not involved with lead abatement. In
addition, the Agency continued providing funds to the
Centers beyond the time when they may have been self-
sustaining (page 19).
10. Region 8 Can Improve Management of
Nonpoint Sources (NPS) Pollution Program
APRIIL1, 1997 THROUGH SEPTEMBER 30, 1997
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Region 8 did not require states to update their NPS
management plans, enforce program requirements, or
provide adequate state program guidance. Further,
states' NPS program management and resource
commitment differed significantly. Consequently, EPA
and the Congress cannot be assured that the most
significant state NPS pollution problems were being
addressed (page 20).
11. More Reliable Data Can Improve
Management of EPA Grants
Although users generally agreed that the Grants
Information and Control System (GIGS) is a good
national database with extensive information, they cannot
rely on the integrity of data in GIGS reports due to system
limitations and inconsistent data entry
(page 22).
12. Almost $9 Million Questioned on Brazil,
Indiana Project
The City of Brazil, Indiana, claimed $8,980,800 of
ineligible construction and engineering costs that were
incurred on a project that did not meet the requirements
of the Clean Water Act (page 24).
13. Over $4 Million Questioned on Henrico
County, Virginia Project
The County of Henrico, Virginia, claimed $4,244,705 of
ineligible construction, engineering, administrative and
claim costs for construction of a secondary wastewater
treatment plant (page 25).
14. Major EPA System Has Serious Control
Weakness
Significant shortcomings in the documentation of security
controls and the absence of management approved
security plans in both the Small Purchase Electronic Data
Interchange (SPEDI) application and the SPEDI Local
Area Network (LAN) represent a serious control
deficiency (page 27).
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 197 reports for which no management
decision had been made. During the second half of fiscal
1997, the Office of Inspector General issued 235 new
reports and closed 252. At the end of the reporting
period, 180 reports remained in the Agency followup
system for which no management decision had been
made. Of the 180 reports, 92 reports remained in the
Agency followup system for which no management
decision was made within 6 months of issuance (page
30).
For the 124 reports closed that required agency action,
EPA management disallowed $48.4 million of questioned
costs and agreed with our recommendations that
$552,000 be put to better use (page 31). In addition,
cost recoveries in current and prior periods included $6.6
million in cash collections, and at least $32.4 million in
offsets against billings
(Appendix 4).
Section 3--Office of Investigations--
Significant Results
During this semiannual reporting period, our investigative
efforts resulted in 8 convictions and 17 indictments. Also,
our investigative work led to about
$580,000 in fines and recoveries (page 35).
The Office of Grants and Debarment completed action
on three OIG-generated suspension and debarment
cases during this reporting period, resulting in one
suspension and two debarments (page 43).
Section 4--Fraud Prevention and
Management Improvements
During this semiannual period, we reviewed three
legislative and 44 regulatory items. Our most significant
comments concerned the Small Business Regulatory
Assistance Act of 1997; certain revisions to EPA policies
governing contracts, grants, and interagency
agreements; and EPA's Plan for a Drug-Free Workplace
(page 45).
The EPA Committee on Integrity and Management
Improvement (CIMI), chaired by the Inspector General,
planned and implemented the eleventh annual
Headquarters observance of Public Service Recognition
Week (page 47).
Twelve new hotline cases were opened and six were
closed during the reporting period. Of the closed cases,
two resulted in environmental, prosecutive, or
administrative corrective action (page 47).
OFFICE OF INSPECTOR GENERAL
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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:
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.
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 two major
offices, each headed by an Assistant Inspector General: Office
of Audit and Office of Investigations. 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.
For fiscal 1997, the Agency was appropriated $6.8 billion and
authorized 17,951 full time equivalent (FTE) positions to conduct
the environmental programs authorized by Congress to restore
and protect the environment. As a separate appropriation
account, the Office of Inspector General (OIG) received $40.1
million to carry out the provisions of the Inspector General Act of
1978, as amended. Eleven million dollars of the OIG's
appropriation was derived from the Hazardous Substance
Superfund trust fund and $577,000 was derived from the
Leaking Underground Storage Tank trust fund. The OIG had a
funded staffing level of 370 FTE positions.
Purpose and Reporting 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
APRIIL1, 1997 THROUGH SEPTEMBER 30, 1997
Source Section/Page
Inspector General Act, as amended.
Section 4(a)(2)
Section 5(a)(1)
Section 5(a)(2)
Section 5(a)(3)
Section 5(a)(4)
Section 5(a)(5)
Section 5(a)(6)
Section 5(a)(7)
Section 5(a)(8)
Section 5(a)(9)
Section 5(a)(10)
Section 5(a)(11)
Section 5(a)(12)
Review of Legislation and Regulations
Significant Problems, Abuses, and
Deficiencies
Recommendations with Respect to
Significant Problems, Abuses, and
Deficiencies
4 45
1 6
Prior Significant Recommendations on
Which Corrective Action Has Not
Been Completed
Matters Referred to Prosecutive
Authorities
Summary of Instances
Where Information Was Refused
List of Audit Reports
Summary of Significant Reports
Statistical Table 1-Reports With
Questioned Costs
Appendix 2 55
3 35
Appendix 1 48
1 6
2 32
Statistical Table 2-Reports With
Recommendations That Funds Be Put
To Better Use
2 33
Summary of Previous Audit
Reports Without Management
Decisions
Appendix 2 55
Description and Explanation of Revised
Management Decisions Appendix 2 55
Management Decisions with Which the
Inspector General Is in Disagreement **
* There were no instances where information or
assistance requested by the Inspector General was refused
during this reporting period.
** There were no instances of management decisions with
which the Inspector General was in disagreement.
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Office of Inspector General-Who's Who
Headquarters
Inspector General
NikkiLTinstey (Acting)
Assistant Inspector General for
Management
John C.Jones
Program Support Staff
Edward Gekosky
Director
Office of Audit
f
Kenneth A. Konz
Assistant Inspector General
James O.Rauch
Prindpal Deputy
Elissa R. Karpf
Deputy for External Audits
IVfchael D. Srrmons
Depuly for Internal Audits
Kenneth D. Hockman
Planning and Resources Mgmt
Robert F. Eagen
Engineering & Scientific Assistance
Patricia H. Hill
ADP Audits and Assistance
Office of Investigates
AfenP.Falin
Assistant Inspector General
EmmettD.DashielL Jr.
Depuly Assistant Inspector General
Divisional Inspectors General for Audit
Regions 1 & 2
Paul D. McKechnie
Region 3
Carl A. Jannetti
Regions 4
Mary M. Boyer
Region 5
Anthony C. Carrollo
Regions 6, 7 & 8
Bennie S. Salem
Regions 9& 10
Truman R. Beeler
Headquarters:
HQ Audit Division
Norman Roth
Financial Audit Division
Melissa M. Heist
Washington Contract
Division
Gordon C. Milbourn III
Divisional Inspectors General for Investigations
Regions 1, 2& 3
Thomas L. Papineau
Regions 4,5,6 & 7
Ailverdes Cornelious
Regions 8,9 & 10
Mark Vallerga
Washington Field Division
David Sermos
OFFICE OF INSPECTOR GENERAL
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Section 1 Office of Audit-Significant Findings
OFFICE OF AUDIT GOALS AND ACTIVITIES
OFFICE OF AUDIT GOALS: In fiscal 1998, the Office of Audit will provide objective, timely,
independent auditing and consulting services by completing and initiating more audit
assignments, reducing the average time on assignments, and dedicating more resources to
consulting services.
ACTIVITIES TO MEET OUR OBJECTIVE
Program Audits - Evaluate the extent to which the desired results or benefits envisioned by
the Administration and Congress are being achieved; review the economy, efficiency and
effectiveness of operations; and determine the extent of compliance with applicable laws and
regulations.
Financial Statement Audits - Evaluate EPA's financial systems and statements to ensure
that the Agency's accounting information is accurate, reliable and useful, and complies with
applicable laws and regulations. Our objective is to assist EPA in making improvements in
the financial management processes and controls which will provide better information for
decisions promoting the greatest possible environmental results.
Assistance Agreement Audits - Evaluate EPA's Construction Grant Program, State
Revolving Fund, Performance Partnership Grants, Interagency Agreements and Cooperative
Agreements, which provide assistance to state, local and tribal governments, universities
and nonprofit recipients accounting for about half of EPA's budget. We will audit both the
financial and performance aspects, building on the Single Audit Act and focusing on
resource-intensive, high-risk programs.
Contract Audits - Evaluate EPA's indirect cost proposals, preaward, interim and final
contracts. These audits determine the eligibility, allowability, allocability, and
reasonableness of costs claimed by contractors and assure that EPA pays only for what it
requests and receives. Performance audits address systemic weaknesses. EPA has
assumed audit cognizance of 15 major contractors and will continue to monitor the contract
universe to identify high-risk contractors. In addition, the Defense Contract Audit Agency
provides contract audit services, on a reimbursable basis, of the majority of EPA's
contractors.
APRIL 1, 1997 THROUGH SEPTEMBER 30, 1997
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Programs
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. 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 resulting from our efforts.
Findings in Brief
EPA regions and delegated
agencies at state and local levels
were widely inconsistent in their
enforcement approaches to
violators of the Clean Air Act.
National Inconsistencies in Air Enforcement and
Compliance Assistance Programs Could Result in Health
and Environmental Risks
Many different levels of government, including EPA and state agencies, have roles
in enforcing the Clean Air Act (Act). States, which in most instances are primarily
responsible for enforcing the Act, can delegate enforcement authority to state
district offices or local agencies. This consolidated audit included the results of
prior reviews of Regions 5, 6, and 9.
We Found That
EPA regions and delegated agencies inconsistently enforced air regulations during
the 18 month period reviewed. Region 5 completed 33 enforcement actions and
assessed more than $6 million in penalties, while Region 9 completed 25 actions
and assessed about $3.5 million in penalties, and Region 6 completed two cases
and assessed penalties of just over $100,000. These inconsistencies, caused by
various factors, can result in unfair treatment of industry and reduced levels of
environmental protection.
EPA regions and delegated agencies reviewed did not usually publicize
enforcement actions to promote compliance. Only 13 percent of the enforcement
actions we reviewed were publicized and the type of information included varied.
EPA's policy to encourage publicizing enforcement actions is outdated and the
regions did not always follow it. Delegated agencies did not publicize cases
because of possible political repercussions and often did not have written publicity
policies. As a result, the regulated community and the public were unaware of
enforcement actions that could help deter similar violations and promote greater
industry compliance.
OFFICE OF INSPECTOR GENERAL
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Regions and a few delegated agencies used the economic benefit component of
penalties to deter companies from violations, in accordance with EPA's Penalty
Policy. However, most delegated agencies did not consistently consider or
appropriately assess the economic benefit penalty because they: (1) did not have
procedures for computing it, (2) believed legal decisions and case law prevented
them from assessing it, or (3) reduced the penalty. If an economic benefit is not
assessed, companies are more likely to continue polluting the environment
because it is less expensive to violate the law than to comply with it. In addition,
violators gain an unfair economic advantage over companies that comply.
The air enforcement data in the Aerometric Information Retrieval System Facility
Subsystem (AFS) were not of high quality because regions and delegated agencies
applied different data definitions when tracking enforcement data, had difficulty
entering data into AFS, and did not use or maintain data in AFS. The average
amount spent to maintain AFS from fiscal 1991 through fiscal 1996 was over
$858,000 per year, while regions and delegated agencies used additional
resources to maintain separate databases since AFS did not meet their needs.
Consequently, resources were used inefficiently, EPA may not have enough
information about potential violators, and incorrect information could be released to
the public.
Each regional office and delegated agency reviewed had performed compliance
assistance activities, including many that were similar to efforts other agencies had
developed. Since no clearinghouse of compliance assistance activities existed, the
regions and delegated agencies may be duplicating materials and activities rather
than using and sharing already successful methods. If information were shared,
new materials for other program areas may be developed, resulting in wider
outreach to the regulated community.
We Recommended That
The Assistant Administrator for Enforcement and Compliance Assurance:
Set up a mechanism to work with regional and delegated agency staff to
recommend ways to address national inconsistencies in enforcement.
Update and reissue the 1985 EPA policy on publicizing enforcement actions, in
conjunction with the Office of Communications, Education, and Public Affairs.
Ask the regions to work with delegated agencies to assess the full economic
benefit of noncompliance in all enforcement matters.
Determine if the Office of Enforcement and Compliance Assurance's (OECA)
minimum data needs can be obtained directly from regional or delegated agency
data systems. If OECA continues to use AFS, consider establishing a minimum set
of standard data elements and simplifying data input.
Work with regions and delegated agency groups to create and maintain a
clearinghouse of available compliance assistance materials.
What Action Was Taken
A draft of the report was issued on August 7, 1997. Although we did not receive a
written response to the draft report by the date of issuance of the final report, we
made changes based on discussions with OECA staff and a draft response
received on September 22, 1997. Therefore, our final report (7100306) was
APRIL 1, 1997 THROUGH SEPTEMBER 30, 1997
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Administrator for Enforcement and Compliance Assurance on September 30, 1997,
without an Agency response.
Findings in Brief
Arkansas, Maryland, and
Massachusetts air inspection
programs did not identify and
report numerous significant
violators (SV) of the Clean Air Act
(CAA). Without proper
identification and reporting of SV
information, EPA regions could not
adequately monitor the progress of
states in returning facilities to
compliance or take timely
enforcement actions.
Arkansas, Maryland, and Massachusetts Did Not Report
Significant Clean Air Act Violators
Section 105 of the CAA provided the initial authority for Federal grants to help state
and local agencies prevent and control air pollution. These grants require each
state to perform at least a Level 2 inspection (a more stringent classification) at
stationary sources and to report significant violators to EPA in accordance with
EPA's Timely and Appropriate Enforcement Policy. Level 2 inspections provide
support for enforcement action and are a viable method for determining whether a
facility is a significant violator.
We Found That
Region 1. The Massachusetts Department of Environmental Protection (MADEP)
did not report any SVs in fiscal 1996 although several existed. The absence of
routine SV discussions with the State and MADEP's misinterpretation of EPA's
Timely and Appropriate policy resulted in MADEP's inability to identify SVs. Also,
Region 1 awarded a pilot demonstration grant to MADEP covering fiscals 1995 and
1996. The pilot program allowed MADEP to test a multimedia approach to
environmental protection and greater flexibility in using resources. As a result,
Region 1 allowed deviations from standard air program procedures. This allowed
MADEP to reduce its inspections of air major sources. As a result the universe of
potential SV sources of serious violations was not identified and reported to the
Region for appropriate enforcement action.
MADEP also under-reported the number of enforcement actions in EPA's Air
Facility Subsystem (AFS) database for fiscal 1996 and did not enter any
compliance inspection and enforcement data. In addition, there were discrepancies
between the MADEP databases and Region 1's AFS, and MADEP did not update
AFS quarterly as required by the grant. The untimeliness of MADEP data input and
the incompatibility of MADEP and EPA systems contributed to the problem. As a
result, EPA did not have a realistic picture of State accomplishments and needed
additional resources to correct the problem.
Region 3. For the past three years, the Maryland Department of the Environment
(MDE) performed more than 2,000 inspections at major facilities and only reported
six significant violators to EPA. For almost half of the files we reviewed, we could
not determine whether the State did enough to identify significant violators of the
CAA. However, from our limited case review, we identified four significant violators
that MDE did not report. Since many State inspection reports did not show which
evaluations inspectors performed, EPA could not assess Maryland's air inspection
program.
In addition, MDE over-reported Level 2 inspections it performed, hindering EPA's
ability to oversee the State's efforts. Almost 80 percent of the 220 inspections that
we reviewed were misreported by MDE in EPA's database because Region 3 had
not formally communicated to the states criterion for coding different levels of
inspections. Also, MDE did not accurately report negotiated and collected penalties
into EPA's database, which prevented the Agency from effectively evaluating the
adequacy of the State's penalties.
issued to the Assistant
OFFICE OF INSPECTOR GENERAL
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Region 6. Arkansas only reported two cases of significant violators to AFS in fiscal
1996, and Region 6 did not adequately use the case narratives in Arkansas'
monthly reports to identify and verify that significant violators were entered into AFS.
As a result of the Region's clarification of the definition of a significant violator
during the audit, Arkansas identified 14 additional significant violators. In addition,
we identified 10 other significant violators from a universe of 23. Violations
committed by the 10 facilities included repeated instances of equipment,
construction and operations unpermitted, exceeding permits limits, without a permit
designed to prevent significant deterioration of air quality, or failed stack tests.
Arkansas and Region 6 need to take actions ensuring that significant violators
achieve timely compliance. Arkansas did not always set milestone dates for
facilities to come into compliance or stipulate penalties for failure to achieve
compliance. Arkansas adequately addressed only 1 of 15 sampled significant
violators within the suggested timeframe. The remaining 14 facilities did not comply
for an average of 940 days, including four that did not comply for over 3 years.
We Recommended That
The Regional Administrator, Region 1:
Require MADEP, as a grant condition, to discuss SVs and other enforcement
actions monthly.
Provide training and guidance to MADEP staff on identifying and reporting SVs.
Require MADEP to comply with the grant's reporting requirements such as
entering compliance and enforcement as well as penalty data into AFS quarterly.
The Regional Administrator, Region 3:
Ensure that Maryland reports significant violators as required by their Section 105
grant and by EPA's Timely and Appropriate Enforcement Policy.
Require Maryland to conduct Level 2 inspections that determine a facility's
compliance and take follow-up actions to resolve violations timely.
As a condition of future grant awards, require Maryland to accurately report
inspection and penalty information into EPA's database.
The Acting Regional Administrator, Region 6, require Region 6 enforcement to:
Verify that significant violators reported in Arkansas' monthly Enforcement
Activities reports are also included in AFS, when appropriate.
Determine who will input the significant violator designation in AFS.
Take decisive enforcement action when Arkansas does not, and consider
overfiling when State action does not result in timely resolution of the violations.
APRIL 1, 1997 THROUGH SEPTEMBER 30, 1997
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The final report (7100305) was issued to the Regional Administrator, Region 1, on
September 29, 1997. In responding to the draft report, the Region agreed with
most of our recommendations and described various actions that had been
undertaken with MADEP to address the problems.
The final report (7100302) was issued to the Regional Administrator, Region 3, on
September 29, 1997. In response to the draft report, the Region concurred with the
findings of the report. EPA Region 3 committed to work cooperatively with the
MDE to address the deficiencies identified in the OIG report to ensure protection of
public health and the environment.
The final report (7100295 ) was issued to the Acting Regional Administrator,
Region 6, on September 26, 1997. In responding to the draft report, the Region
generally agreed with the findings and recommendations and described corrective
actions that have been or will be taken by Arkansas and Region 6.
Findings in Brief
Critical gaps in some Federal and
state statutory and regulatory
authorities requiring financial
assurances could result in EPA
assuming responsibility for
cleaning up additional hardrock
mines. EPA had not effectively
implemented its existing statutory
authorities or used non-regulatory
tools, such as partnerships, to
minimize the environmental
impacts of hardrock mining and
help eliminate financial assurance
gaps.
EPA Can Do More to Help Minimize Hardrock Mining
Liabilities
Mining activities are regulated under Federal and state authorities. Federal
statutory authority is spread among several agencies with no agency having overall
regulatory responsibility. Most states with significant hardrock mining have
established their own statutory programs and regulate mine activities through mine
permits. Of all EPA's Superfund National Priority List sites, mines are the largest
and most costly to clean up.
We Found That
Federal and state land management agencies' authority requiring environmental
performance standards and financial assurances at hardrock mines varied, leaving
critical gaps in bonding requirements. Land patent provisions in the Mining Law of
1872 provided mine operators relief from the stricter Federal bonding requirements.
Unreasonably low state bond ceilings did not allow adequate financial assurances
for hardrock mining on some state and private lands. Only two of the eight states
we reviewed provided for 100 percent bonding for the estimated costs of
addressing toxic contamination. As a result, EPA may become liable for the
considerable costs of cleaning up abandoned mines. For example, EPA estimated
it will cost about $150 million from the Superfund Trust Fund to
clean up the Summitville mine in Colorado.
EPA could have more effectively implemented its statutory and regulatory
authorities to prevent hardrock mining pollution problems. Although the Agency
has no comprehensive authority to regulate mines, it does have the Clean Water
Act National Pollutant Discharge Elimination System Program (NPDES) and the
Resource Conservation and Recovery Act (RCRA) that could be applied to help
prevent pollution problems at individual mines. The Agency did not always provide
for adequate NPDES oversight or technical assistance to important mining states.
EPA also had not developed a regulatory mining program under RCRA even
though it announced its intention to do so in 1986, and RCRA mining wastes are the
primary cause of environmental damage from mining. While some EPA regions
have developed a cross-media approach for addressing hardrock mining issues,
EPA as a whole has been slow to develop and implement a
What Action Was Taken
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comprehensive hardrock mining strategy and effectively coordinate and address
specific hardrock mining issues.
Even though partnering is an important part of EPA's 5-year strategic plan, EPA
had not consistently engaged in effective partnerships and had missed important
opportunities to participate early in the mine permitting process. For example,
Region 5 did not respond early to Michigan's request for assistance in a copper
mine permitting process, thereby delaying the permit and causing increased costs.
California officials stated that Region 9 showed little interest in state hardrock
mining issues, and Alaska representatives told us that EPA seldom participated on
its major mine permitting teams. EPA cited a lack of resources, adequate mining
expertise, and management commitment for not participating more actively with
Federal and state agencies.
We Recommended That
The Assistant Administrator for Water:
Encourage regions to improve their relationships with Federal and state land
management agencies to help eliminate existing gaps in the Mining Law of 1872
and Federal and state bonding requirements.
Establish and implement a national hardrock mining strategy to provide direction
for EPA's more effective use of its statutes to address hardrock mining issues and
develop stronger partnerships with other hardrock mining stakeholders.
Develop a critical core of cross-media mining expertise and encourage proactive,
timely involvement in hardrock mining environmental issues.
What Action Was Taken
The final report (7100223) was issued to the Assistant Administrator for Water on
June 11, 1997. In responding to the draft report, the Assistant Administrator
agreed that EPA's overall management of mining activities could be made more
effective and efficient, and generally agreed with the report findings and
recommendations. A response to the final report was due by September 11, 1997.
However, Agency comments have been delayed pending approval of a hardrock
mining strategy.
Findings in Brief
EPA's regional laboratories' current
processes are not adequate to
assist the Agency in meeting the
Government Performance and
Results Act (Results Act). Also, the
absence of a shared identity
among regional laboratories and
limited national leadership have
resulted in inefficient efforts to
meet common needs.
Regional Laboratories Need Results-Oriented Management
and Better National Leadership
Each of EPA's ten regions has a laboratory which provides a range of scientific and
technical services for a variety of customers both internal and external to the
Agency. The regional laboratories focus on the application of scientific policies and
methods in support of regulatory programs, monitoring programs, and special
projects.
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We Found That
While EPA is taking steps to meet requirements of the Results Act, regional
laboratories need improvements in: (1) preparing performance plans, (2)
measuring performance, (3) increasing accountability, and (4) linking planning and
performance to funding levels. Only four often regional laboratories prepared work
plans that included goals and indicators, and there was no system for consistently
measuring analytical activity. Seven of the laboratories prepared activity reports but
they varied in terms of information. Only three used
planned activities and prior years' results as the basis for budgets, while seven
based them on historical levels.
EPA's regional laboratories need a stronger shared identity and more active
national leadership. Each regional laboratory has historically operated
independently of the others. However, there are many similarities in their missions,
goals, and contributions to the Agency. A 1994 EPA report recommended
enhancing the role of the "central advocate" for the regional laboratories and re-
evaluating which organizational component should fill that role. Although the Office
of Regional Operations and State/Local Relations was designated to perform this
role, its activities had been limited to budget justification and distribution of
resources for capital equipment. An Agency official attributed the inability to fulfill
responsibilities to limited resources.
The absence of a shared identity among regional laboratories and the limited scope
of national leadership have resulted in inefficient and duplicative efforts to meet
common needs. For example, each regional laboratory independently purchased,
or developed, its own data management system. A stronger national leadership
would prevent duplication of effort in the purchase, development, or modifications
of systems needed to meet to meet the regional laboratories' core needs. In
addition, regional laboratories' capital equipment purchases were made based on
regional rather than national needs, resulting in the potential for inefficient use of
equipment resources. The current method for tracking equipment purchases will
not prevent regional laboratories from purchasing duplicate equipment that will be
underutilized.
We Recommended That
The Acting Associate Administrator for Regional Operations and State/Local
Relations work with the regional laboratories to:
Prepare annual performance plans and accountability reports that meet the
Results Act, and develop a system that all regions will use to consistently measure
laboratory activities.
Develop a common vision and mission statement, and identify the appropriate
responsibilities for the national leader.
What Action Was Taken
The final report (7100277) was issued to the Acting Associate Administrator for
Regional Operations and State/Local Relations on August 20, 1997. In response to
the draft report, Agency officials stated that the regional laboratory managers have
joined the Agency in its efforts to understand and implement the Results Act. Also,
as the reorganization of the Office of Administrator is completed, the regional
operations staff will work to acquire the resources necessary to provide strong
12 OFFICE OF INSPECTOR GENERAL
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leadership for the laboratories. Based on the Agency's response, we closed the
report in our tracking system.
Findings in Brief
Region 3 took extraordinary
amounts of time to bill
responsible parties for recovery of
Superfund oversight costs. In
several instances, delays
amounted to years, even though
the bills should have been sent
annually. Consequently, the
Agency sometimes failed to recoup
large portions of the costs.
Superfund Oversight Bills to Responsible Parties Were
Delayed for Years
EPA incurs oversight costs while monitoring cleanup work performed by
responsible parties at "Enforcement-lead" Superfund sites. Such costs can include
charges for Agency personnel, EPA contractors, or state employees. EPA
recovers these costs through the use of enforcement documents, which are legally
binding agreements between the Agency and the responsible parties.
We Found That
In Region 3, there were 76 enforcement dockets for sites with annual billing
provisions during fiscal 1996. Of the 15 dockets we reviewed, there were:
(1) eight instances where the bills were delayed, in one case for seven years;
(2) three instances where the responsible parties complained that the billing delays
adversely affected their ability to verify what was being billed; (3) four instances
where the responsible parties requested documents to support earlier bills, and the
Region took between eight months and seven years to provide them; and (4) four
instances where no bills had ever been sent even though costs were incurred as far
back as 1988.
Delays occurred because oversight billings were considered a low priority, and
there was a reluctance by Superfund program personnel to relinquish control of the
billings to financial personnel. As a result, reimbursement to the Superfund Trust
Fund was delayed, and the responsible parties were afforded additional
opportunities to challenge the charges, causing more delays.
The Region's delay in assessing oversight bills sometimes resulted in other
problems with a cumulative effect of oversight costs not being recouped from the
responsible party. For example, when the Region delayed submitting a bill for
more than six years, the responsible party challenged $185,525 in indirect costs
and the Region settled for only $19,472. Had the Region submitted the bill timely,
it would have resolved the indirect cost issue early enough to possibly recoup a
large portion of the costs.
In another instance, the Region was unable to bill a responsible party $149,000 for
State oversight costs. Under the terms of a Multi-Site Cooperative Agreement,
EPA paid the State of Maryland for assistance in overseeing cleanups, and then
billed the responsible parties. The Region delayed billing the responsible parties
for six years and excluded $149,000 it had already paid to the State because the
Maryland Department of the Environment had destroyed the time sheets needed to
verify the costs. If Region 3 had submitted a bill in accordance with the
enforcement document, we believe it might have learned of the problem years
earlier.
We Recommended That
The Regional Administrator, Region 3:
Ensure that oversight costs are billed in accordance with the enforcement
agreements signed by the Region, e.g., on their anniversary date.
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Determine if Maryland's Department of the Environment lacks time sheets to
support oversight charges at Superfund sites covered by other cooperative
agreements.
Initiate sanctions against the State of Maryland's Department of the Environment
if it does not adhere to the record-keeping and retention criteria stipulated by the
Code of Federal Regulations.
What Action Was Taken
The final report (7100292) was issued to the Regional Administrator, Region 3, on
September 22, 1997. In responding to the draft report, the Regional Administrator
stated that the Region has taken steps to improve the oversight billing process.
Thus, the Region is reasonably assured that oversight costs are billed in
accordance with the Region's signed enforcement agreements. Agency officials
also stated that the Maryland Department of the Environment has taken action to
correct Cooperative Agreement record-keeping deficiencies and agreed to take
appropriate action if the deficiencies are disclosed in the future. A response to the
final report is due by December 22, 1997.
Findings in Brief
EPA has not sufficiently developed
or implemented adequate controls
to prevent or detect improper/illegal
access to its systems from the
Internet As a result, there were six
documented hacker attacks
between 1992 and 1996, and likely
many more in actuality.
EPA Needs Internet Security to Protect Integrity of Agency
Data
EPA's Internet site allows anyone access to a wide variety of information including
EPA Program and Office data, policies, press releases, and EPA publications.
EPA's Vision of the Internet is to provide every EPA employee with interactive
Internet access, and to establish the Internet as the primary vehicle for public
access to EPA information. Although various EPA manuals address security in a
broad sense, network security is not specified, nor is there any reference to security
and controls relating to the Agency's Internet connectivity.
We Found That
EPA is not sufficiently protecting its information technology resources from
malicious acts via access from the Internet. Joint EPA and OIG tests of 35 systems
indicated that the Agency has not implemented corrective actions for many Internet
services with known security weaknesses. These vulnerabilities include allowing
intruders to add, modify, or delete system files and gain access to user log-on and
system information.
Also, EPA officials were unable to demonstrate that audit logs of network system
activities were being maintained and monitored. These logs identify if systems have
been harmed by hackers, insiders or technical problems, and they are crucial
evidence in enforcement actions brought against individuals with unauthorized
access to systems.
Further, EPA is not using formal firewall technologies which prevent hackers from
compromising internal systems simultaneously while EPA users are accessing
external networks. The EPA network environment would be exposed to fewer risks
if all access to and from the Internet passed through a firewall protecting inherently
insecure services.
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These weaknesses occurred primarily because EPA has not developed and
implemented an Agency network security policy which should be an extension of an
overall organizational policy regarding the protection of information resources
In addition, EPA has not developed a security plan for Internet connectivity as
required by the Computer Security Act and OMB Circular A-130.
We Recommended That
The Director for Information Resources Management:
Develop and implement a network security policy.
Evaluate the costs and benefits of implementing formal firewall technologies.
Maintain and monitor sufficient audit logs.
What Action Was Taken
We issued our final report (7100284) to the Director for Information Resources
Management on September 5, 1997. In responding to the draft report, the Agency
agreed with all of our recommendations and has taken a number of positive actions
to correct the deficiencies. The response indicated that: (1) OIRM is revising EPA's
IRM Policy Manual and Information Security Manual to include a
policy framework for network security: (2) OIRM's Enterprise Technology Services
Division (ETSD) has been evaluating formal firewall technologies, and (3) ETSD
has established logging and a review of audit trails for all centrally managed
computer systems located at EPA 's National Computer Center.
Findings In Brief
Region 4 did not have formal
security or disaster recovery plans
for their LANs which contain
sensitive agency information. Also,
the Region lacked a structured and
consistent process for rescinding
access to its LANs.
Security Over Region 4 Local Area Networks (LAN) Needs
Strengthening
The Information Management Branch (1MB) controls all of Region 4's LAN
administration. There are 33 file servers that comprise the backbone for 10 LANs
serving a variety of EPA Divisions and Offices.
We Found That
Region 4 did not have a LAN security plan nor did it report this omission as a
weakness in its fiscal 1996 Federal Manager Financial Integrity Act Assurance
Letter, as required by OMB Circulars A-130 and A-123. Security policies document
the standards of compliance and identify who is responsible for safeguarding
organization assets, including data. Without an adequate LAN security plan,
employees would be unable to provide adequate protection against violators.
The Region also had not developed a disaster recovery plan for its LANs. All of
Region 4's file servers are located in one room, and a disaster such as a fire,
flood, or severe thunderstorm could destroy the Region's critical information. The
Region would be unable to institute a timely disaster recovery process because
1MB would have to create information on how to get systems restored a/ferthe
disaster, thereby increasing restoration time.
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There are no formal procedures to rescind access to Region 4 LANs if an
employee is terminated or transferred. In addition, some of Region 4's LAN file
server settings did not comply with EPA's LAN Operational Procedures and
Standards (LOPS) manual and industry standards, increasing vulnerability to
security breaches from hacker attacks. Further, Region 4 lacked policies and
procedures for overall LAN maintenance which could result in inconsistent
application of settings and loss of accountability.
Region 4's 1MB management stated that they were unaware of Federal
requirements for formal security and disaster recovery plans. They were also
unaware of the need to formalize procedures for terminating LAN user accounts
and attributed the non-existence of policies and procedures for LAN maintenance
to conflicting priorities and scarce resources.
We Recommended That
The Region 4 Chief, Information Management Branch,
Establish a formal security plan to ensure that physical and security controls
adequately restrict access to LAN data.
Establish a disaster recovery plan.
Bring Region 4 LANs into compliance with the Agency's LOPS manual and
industry standards.
Establish a maintenance plan for Region 4 LANs.
What Action Was Taken
We issued the final report (7100308) to Region 4's Chief, Information Management
Branch, on September 30, 1997. In responding to the draft report, the Agency
agreed to implement our recommendations, and we closed the report upon
issuance.
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Financial Statements
We are currently conducting our audit of the Agency's fiscal 1997 financial
statements. The results will be summarized in our March 31,1998,
semiannual report. We are working jointly with the Agency's financial
managers to resolve issues that have prevented it from receiving unqualified
opinions on its financial statements. We believe accurate, timely financial
information is critical to EPA making the best decisions about how to achieve
its environmental goals.
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Assistance Agreements
Over the past several years, the OIG has identified problems in the Agency's
award and administration of interagency agreements, and assistance
agreements at various offices and facilities. These audits determine whether
costs claimed by assistance recipients are eligible, supported by
documentation, necessary, and reasonable. The following section
summarizes the most significant findings and recommendations reported
during this semiannual reporting period.
Findings in Brief
MDE significantly overstated
Leaking Underground Storage
Tank (LUST) program
accomplishments and
consequently received as much as
$1.4 million in additional grant
funds. MDE lacked
documentation explaining the
acceptance of settlement amounts
less than full cost recovery.
Maryland Department of the Environment (MDE)
Overstated Accomplishments
During the past four fiscal years, EPA awarded MDE four cooperative agreements
totaling $6.8 million and required the submission of semiannual progress reports
showing LUST program activities. EPA Headquarters uses these reports to make
nationwide funding recommendations, report progress to Congress, and disclose
the results of the program in the Agency's financial statements. The Regional
Administrator has the discretion to distribute grant funds across the regional states
regardless of the national distribution formula.
We Found That
When reporting fiscal 1996 LUST program accomplishments, MDE significantly
overstated the number of confirmed releases, cleanups initiated, and cleanups
completed. For example, we estimated that the 480 completed cleanups reported
by MDE were overstated by nearly 50 percent. In addition, confirmed releases
were overstated by 45 percent and MDE considered some cleanups initiated even
when there was no hazard to clean. This over reporting occurred during an
extended period resulting in MDE receiving as much as $1.4 million in additional
grant funds. Although MDE has revised procedures to correct this situation, the
erroneous reporting of program accomplishments is a systemic problem within
EPA.
MDE also did not recover $616,990 (47%) of the $1,304,490 of costs associated
with three recovery cases completed in fiscal 1996, nor document the reason for
accepting settlement amounts less than full cost recovery. We could not determine
whether MDE effectively used LUST Trust Fund resources because required
documentation was not prepared and maintained. When states do not recover
cleanup costs from responsible parties, the state is: 1) relieving responsible parties
of their financial obligation; 2) removing the financial incentive to cleanup
contamination; and 3) shifting the burden of cleanup costs to the Federal
government. MDE has completed drafting new cost recovery procedures
which will require proper documentation in all future cost recovery settlements
where the MDE achieves less than full cost recovery.
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We Recommended That
The Regional Administrator, Region 3:
Review MDE's new procedures to determine if they will result in accurate
reporting of cleanups completed, confirmed releases, and cleanups initiated.
Perform planned program reviews of all the state LUST programs within Region
3 and make appropriate adjustments to the funding levels to correct any inequities
that resulted from inaccurate reporting of program accomplishments.
Require MDE to document the basis for all future settlements that are for
amounts less than full cost recovery.
What Action Was Taken
The final report (7100290) was issued to the Regional Administrator, Region 3, on
September 17, 1997. A response to the final report is due by December 16, 1997.
Findings in Brief
EPA awarded cooperative
agreements to the National
University Continuing Education
Association Inc. (NUCEA)and
Regional Lead Training Centers
(Centers) to develop a national
cadre of certified lead based paint
abatement specialists. Some of
the funds were used to train
individuals not involved with lead
abatement In addition, the Agency
continued providing funds to the
Centers beyond the time when
they may have been self-
sustaining.
Better Management of Cooperative Agreements for Lead-
Based Paint Abatement Training is Needed
EPA wanted to maximize accessibility and public awareness of lead-based paint
abatement by offering two training courses throughout the country. For the first
three years of this training effort, EPA awarded cooperative agreements to NUCEA
to manage and coordinate the establishment and operation of six educational
institutions to serve as Training Centers. These Centers were located at the
University of Maryland, University of Massachusetts, University of Cincinnati,
University of California, University of Kansas, and the Georgia Technical Institute.
For the remainder of the effort, cooperative agreements were awarded directly to
the Centers. As prescribed by the cooperative agreements, the Agency awarded a
total of $6.1 million to NUCEA and the Centers.
We Found That
Although the purpose of the cooperative agreements was to provide training for
individuals who would ultimately be engaged in lead detection and abatement,
1,248 of the 6,134 individuals (20 percent) trained were in occupational fields
unrelated to those activities. Funds may have been unnecessarily expended
because neither EPA, NUCEA, nor the Centers ensured that attendees used their
training for subsequent work in lead detection and abatement activities. Fee
waivers of $250 were paid for each state and local government employee trained to
encourage participation by State and local government employees. EPA
believed the courses would expedite awareness of Federal requirements for lead
paint abatement and encourage states to develop their own statutes and
procedures. However, EPA had already paid the two Centers that we reviewed the
full cost of training each attendee, including state and local government personnel.
As a result, paying fee waivers to the Centers was unnecessary.
At the outset of this training effort, EPA's goal was for the six Centers to be self-
sustaining by May 1993. However, EPA continued providing funds to NUCEA
through September, 1994, and to the Centers from 1994 through 1996 without
performing a financial analysis to determine if tuition revenue was sufficient to
APRIL 1, 1997 THROUGH SEPTEMBER 30, 1997
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cover the costs of the courses. Since the Centers provided fewer courses in 1997
without EPA funding than in 1993 when they received EPA funding, we believe the
Centers could have been considered self-sustaining before 1997. As a result, EPA
awarded Federal funds totaling $5.1 million to achieve a goal it may have already
reached.
Project officers did not adequately monitor the two cooperative agreements
awarded to NUCEA to ensure that Federal funds were managed properly. We
found several oversight weaknesses including a lack of knowledge of the basic
facts concerning the agreements, failure to require NUCEA to prepare a separate
final project report for each of its two cooperative agreements, high turnover among
project officers assigned during the course of the agreements, and agreements
remaining open years after the project period.
NUCEA and the Centers claimed $733,878 of costs for which the eligibility has
been questioned and $218,382 of costs which the OIG determined were not
adequately supported.
We Recommended That
The Director of the National Program Chemical Division (NPCD) ensure that costs
are only incurred as needed to achieve the objectives of assistance agreements.
This would prevent funds from being expended to 1) train individuals unnecessarily,
2) provide needless fee waivers, and 3) support Centers that are already self-
sustaining.
The Director, Grants Administration Division recover all ineligible and unsupported
costs.
What Action Was Taken
A draft report was issued on May 15, 1997. The Agency vigorously objected to
many of the findings and recommendations contained in that report. The final
report (7100297) was issued to the Director, Grants Administration Division, and
the Director, National Program Chemicals Division, on September 24, 1997. A
response to the final report is due by December 24, 1997.
Findings in Brief
Region 8 did not require states to
update their NPS management
plans, enforce program
requirements, or provide adequate
state program guidance. Further,
states' NPS program management
and resource commitment differed
significantly. Consequently, EPA
and the Congress cannot be
assured that the most significant
state NFS pollution problems were
being addressed.
Region 8 Can Improve Management of Nonpoint Sources
(NFS) Pollution Program
The Clean Water Act (CWA) requires states to address NPS pollution by
developing NPS assessment reports and adopting and implementing management
plans. Assessment reports identify and define the sources and extent of NPS
pollution, and management plans outline a strategy for implementing NPS controls.
The CWA authorizes EPA to award grants to states to help them implement their
management programs.
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We Found That
Region 8 should improve its oversight and enforcement of NPS program
requirements while providing more programmatic and technical assistance. The
Region did not require and states did not provide updated management plans due
to anticipated CWA changes, states' low priority on updating plans, and the lengthy
assessment process for determining priorities. Colorado, Utah, and Wyoming had
not updated their management plans since initial publication in 1989. These plans
should be working documents used to identify and fund the highest priority areas
with the greatest potential to reduce NPS pollution.
The Region did not enforce program requirements. Region 8 permitted Wyoming
to continue using NPS funds even though it had not complied with NPS grant
reporting conditions. Wyoming's fiscal 1995 and 1996 annual reports were not
timely, well-organized, accurate, or adequate in describing accomplishments.
While the project officer attempted to withhold NPS payments, top Region 8
managers directed the release of funds thereby sending a message to other states
that continued NPS funding was not dependent upon effective program
management.
Region 8 did not finalize its policy on administrative costs or define what qualified as
a demonstration project. Each state interpreted administrative costs differently, and
the Region could not determine whether they exceeded congressional limits. The
states' interpretation of demonstration projects (intended to show the effectiveness
of a particular NPS pollution control practice) also differed. Some individual
projects implemented the same practice in the same geographic area, even though
funding more than one was unnecessary to demonstrate that it worked. As a result,
Region 8 and the states had limited assurance that states addressed the most
significant nonpoint sources of pollution.
Although each state implemented NPS projects that reduced NPS pollution and
achieved NPS objectives, states' NPS program management and resource
commitment differed significantly with all relying primarily on EPA funding.
Colorado and Utah invested some state funds and had sufficient staff to manage
their NPS programs, while Wyoming did not invest any state funds and lacked
sufficient staff. In addition, EPA's practice of allowing states to carry forward NPS
funds from prior years discouraged states from developing their own capacity and
identifying other sources of funding to sustain their NPS programs.
Utah and Wyoming needed to improve financial management of their NPS
program. Utah inadvertently included agricultural loan lines of credit in its matching
fund pools and did not have supporting documentation for some costs. Wyoming
paid for work performed beyond one project's contract period because of the
State's burdensome contract amendment process.
We Recommended That
The Acting Regional Administrator, Region 8:
Establish milestone dates for each state to update its management plan and
work with Wyoming to ensure that its management plan identifies NPS pollution
priorities.
Finalize the Region's policy on administrative costs and develop a policy that
defines a demonstration project.
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Findings In Brief
Although users generally agreed
that the Grants Information and
Control System (GIGS) is a good
national database with extensive
information, they cannot rely on the
integrity of data in GIGS reports
due to system limitations and
inconsistent data entry.
Help states develop a plan to
build states' capacity to operate the NPS program without reliance on Federal
funding.
Ensure that Utah and Wyoming make administrative improvements to their
financial management.
What Action Was Taken
The final report (7100304) was issued to the Acting Regional Administrator,
Region 8, on September 30, 1997. The Region generally agreed with our findings
and recommendations and provided a schedule of tasks and completion dates for
each recommendation. However, some planned actions need to be more specific.
A response to the final report is due by December 31, 1997. Region 8 NPS staff
stated that they would work closely with Wyoming and Utah, which have already
begun to correct some problems, to improve overall program management and
financial accountability. Wyoming submitted an amendment to its 1997 State/EPA
agreement to Region 8 reflecting additional staff to be hired and suggesting ways
to improve its relationship with the Region. Utah has begun reviewing its matching
pool funds to identify and remove ineligible costs before submitting its final claim.
More Reliable Data Can Improve Management of EPA
Grants
GIGS was created in 1972 to track EPA Research and Demonstration grants, and
eventually expanded to administratively track all EPA grant programs, interagency
agreements, and fellowships. It represents the primary management information
system for the Grants Management Offices and selected program offices.
We Found That
Regional and Headquarters personnel use different data entry screens and data
elements for inputting and accessing the same types of grant information. Without
a requirement for the same data elements between regions and Headquarters,
information within GIGS necessary for tracking, analyzing, and reporting grants may
be incomplete.
GIGS also lacks a table that includes general information about a grantee. Since
the field length is limited and both upper and lower case letters are used, many
grantee names are listed in the system several different ways, some with multiple
employer identification numbers. A grantee table would eliminate the need to re-
enter data every time a grant is initiated and would ensure consistency of grantee
names and numbers.
Some data elements have an inordinate number of legitimate codes which can
have different meanings within a data element. Many grant specialists only used a
few codes because the number of codes was confusing. Extensive or confusing
coding results in codes not being used, or used inappropriately, because the user
needs to guess which code is appropriate for a grant.
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Some reports from GIGS contain incomplete data and lack summary information
such as totals of funds awarded and outstanding grants. Users who generate
customized reports described the report generator as difficult and a process of trial
and error.
These weaknesses were caused by the lack of: (1) formal policies for consistent
data entry; (2) management oversight; and (3) sufficient edits. Further,
management should take a more active role in the operation of GIGS.
We Recommended That
The Director, Grants Administration Division:
Develop, issue and monitor policies governing consistent data entry.
Review data elements and codes to determine if they are necessary and clearly
defined.
Require a grantee table, adequate edit checks, and summary information
reports.
What Action Was Taken
The final report (7100237) was issued to the Director, Grants Administration
Division, on June 24, 1997. The Agency substantially agreed with the report's final
recommendations. In the October 22, 1997, response to the final report, the
Agency indicated that many of the changes called for in the audit have been or will
be built into a replacement data entry system being implemented beginning in
fiscal 1998. Also, the Agency committed to do an extensive analysis and
streamlining of data elements and codes, and to develop policy and training
materials based on this revision.
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Construction Grants
In December 1996, the Agency declared the Construction Grants Close Out a
new material management control weakness under the 1996 Financial
Managers' Financial Integrity Act Report to the President and Congress. To
assist the Agency in its effort to close out the construction grants program,
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. When the
OIG implemented its revised audit strategy, there were 1,453 grants totaling
$12.4 billion subject to audit. As of September 30,1997, there were only 79
grants totaling $1.9 billion which are expected to receive OIG review during
the next two years. Summaries of some audits of construction grants with
significant issues follow.
Findings In Brief
The City of Brazil, Indiana, claimed
$8,980,800 of ineligible
construction and engineering
costs that were incurred on a
project that did not meet the
requirements of the Clean Water
Act
Almost$9MillionQuest^
We Found That
EPA awarded a grant totaling $8,980,800 to Brazil, Indiana, to separate combined
sanitary and storm sewers, and to reduce infiltration, inflow, and stream
degradation. The $8,980,800 was ineligible because the project was not
constructed in accordance with: (1) the approved facilities plan, (2) the construction
plans and specifications, and (3) the requirements of the Clean Water Act.
At the time of our audit, numerous structures were still connected to the old
combined sewer that discharges untreated waste into the receiving stream, and
excessive ground and surface water was entering the sanitary sewer system.
There were also numerous interconnections between the sanitary sewer and the
storm sewer that allowed large quantities of storm water to enter the sanitary sewer
when it rained, causing overloading of the sanitary sewer and resulting in the
discharge of untreated sanitary waste into the receiving stream. Further, sewer
pipes were placed at slopes less than standard design minimums which caused
backups and local flooding.
We concluded that the grantee had not met its responsibilities to complete the
grant project in accordance with established requirements. As a result, the grantee
violated the provisions of the Clean Water Act from the date of initiation of operation
in August 1988.
We Recommended That
The Regional Administrator, Region 5, annul the grant and recover the Federal
share ($4,939,440) of grant funds paid to the grantee.
What Action Was Taken
We issued the final report(7100192) to the Regional Administrator, Region 5, on
May 9, 1997. A response to the report was due on August 5, 1997. Although we
have not received a response to the final report, a Region 5 official has stated that
Brazil has submitted its proposed plan for meeting the objectives of the original
grant-funded project. Negotiations are continuing between the City, State, and
Region 5. Further, the City's proposed schedule appears reasonable, but
24
OFFICE OF INSPECTOR GENERAL
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Findings In Brief
The County of Henrico, Virginia,
claimed $4,244,705 of ineligible
construction, engineering,
administrative and claim costs for
construction of a secondary
wastewater treatment plant
Over $4 Million Questioned on Henrico County, Virginia,
Project
We Found That
EPA awarded a grant totaling $62,800,420 for basic and $3,213,580 for innovative
and alternative funding for the construction of the secondary activated sludge
Henrico Regional Wastewater Treatment Plant. The grantee claimed $4,244,705
of ineligible costs under the grant, including:
$1,192,388 for funds received for failed technology which were not used to
rehabilitate the facility;
$201,114 for engineering costs which exceeded the cost ceiling contained in the
engineering agreement; and
$130,337 for construction, engineering and administrative costs outside the scope
of the eligible project.
We Recommended That
The Regional Administrator, Region 3, not participate in the Federal share of the
ineligible costs ($4,244,705), and recover the applicable amount from the grantee.
We also recommended that the Regional Administrator participate in the additional
eligible alternative costs of $1,203,757.
What Action Was Taken
The final report (7300029) was issued to the Regional Administrator, Region 3, on
May 5, 1997. A response to the audit report, due on August 5, 1997, has not been
received.
additional details are needed on
specific actions to be undertaken.
APRIL 1, 1997 THROUGH SEPTEMBER 30, 1997
25
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Contracts
Potential Vulnerabilities in EPA's Contracts Management
May Still Exist
In June 1992, the Standing Committee on Contracts Management-now the
Resource Management Committee (RMC)-identified seven problem areas and
made forty recommendations to correct longstanding weaknesses in contracts
management. During fiscal 1997, we performed a survey jointly with EPA's Office
of Acquisition Management to determine whether these initiatives were
implemented and effective in correcting the identified weaknesses. We found
indications of potential vulnerabilities in: (1) personal services; (2) contractor
access to confidential or sensitive data; and (3) contractor conflicts of interest.
Although we reported on the status of our work to date, we will continue to conduct
additional audit work in each of these areas to assess the potential vulnerabilities.
A survey report (7400070) was issued to the Acting Assistant Administrator for
Administration and Resources Management on September 30, 1997.
In response to an Office of Management and Budget request, we reviewed EPA's:
(1) use of fixed-price contracts; (2) accuracy of independent government cost
estimates (IGCE); (3) contract capacity; (4) use of award and incentive fees; (5)
use of completion vs. term forms; (6) length of base and option periods; (7)
management of Response Action Contracts (RAC); (8) competition of task orders
under RACs; and (9) use of performance-based service contracting. We found that
EPA has made some progress in correcting past problems related to IGCEs and
the management of award fee contracts, such as issuing IGCE guidance, requiring
IGCEs for all significant contract actions, and limiting award fees to above-
satisfactory performance. However, improvements were still needed and
substantial opportunities exist for EPA to lessen its dependence on cost-
reimbursable, level-of-effort contracts and move toward more efficient, results-
oriented contracting mechanisms.
We found IGCEs were not always adequately prepared and effectively used to
analyze proposed contract costs, or to establish prenegotiation objectives. A good
IGCE that identifies activities and deliverables and assigns estimated costs to these
activities provides a baseline to track actual versus estimated costs and identify
potential cost overruns, thus promoting cost-effective contracts. In certain
instances, IGCEs did not include detailed cost estimates and represented a
projection of available funding rather than an actual cost estimate to complete
contract requirements. Also, EPA had not implemented procedures for evaluating
past IGCEs or accumulating historical cost information for preparation of current
and future IGCEs. As a result, EPA relied heavily on contractors' estimates, often
choosing to award contracts and related work at amounts closer to that proposed
by the contractor rather than the EPA estimate. EPA's ability to properly estimate
its needs and related costs and effectively use these estimates in contract
negotiations are crucial for the Agency's transition to more performance based
service contracts.
26 OFFICE OF INSPECTOR GENERAL
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EPA relies almost extensively on cost-reimbursement level-of-effort (LOE)
contracts that essentially buy hours, not results, and places the burden of cost
control on the government. The Agency's culture preference for LOE contracts,
insufficient knowledge of alternative contract types, lack of program accountability
for the type of contract to be awarded, inability to clearly define its needs, and broad
contract statements of work have perpetuated this continuing reliance on
LOE contracts and precluded a complete transition to more efficient, cost-effective
contract types.
We recommended that the Acting Assistant Administrator for Administration and
Resources Management, in coordination with other appropriate senior managers:
require that IGCEs contain estimated costs for each task and be effectively used for
contract cost negotiations; develop processes to evaluate the quality of IGCEs and
create historical cost databases for use in preparing IGCEs; establish program
goals for award of performance-based servce contracts; require EPA Senior
Resource Officials to implement Office of Federal Procurement Policy that requires
documented justification for use of contract types other than performance-based;
and develop a strategy for meeting OMB's contract reform goals.
We issued the final report (7100301) to the Acting Assistant Administrator for
Administration and Resources Management on September 30, 1997. In
responding to the draft report, the Acting Assistant Administrator agreed with most
of the findings and recommendations presented. However, the response
disagreed with certain audit conclusions and recommendations. He also noted that
the Agency has made significant progress in terms of the visibility and quality of
contracts management. As indicated, progress is continuous as we proceed with
several initiatives to streamline the process and increase management integrity and
accountability. A response to the final report is due by December 29, 1997.
Findings In Brief
Significant shortcomings in the
documentation security controls
and the absence of management
approved security plans in both the
Small Purchase Electronic Data
Interchange (SPED!) application
and the SPEDI Local Area Network
(LAN) represent a serious control
deficiency.
[Major EPA System Has Serious Control Weakness
SPEDI is the part of the Integrated Contract Management System (ICMS) which
electronically handles small purchases. It is a major Agency system which handled
over $44 million in purchases in fiscal 1996. OMB Circular A-130 details the
required policy and guidance agencies must provide to ensure that automated
systems have adequate security programs and documentation.
We Found That
Our survey of 13 SPEDI production sites revealed inadequate security
documentation and inconsistent implementation of security controls. None of the
13 sites provided security documentation required for reasonable assurance that
general controls were operating properly for the SPEDI application. Further, there
was no coordinated overall security documentation for the SPEDI application, and
security personnel were confused about their responsibilities, the need for security
controls and documentation, and the overall risk. During our audit, the Agency
issued interim guidance regarding OMB Circular A-130 requirements.
The lack of management-approved security plans for the SPEDI application and
LANs constitutes a serious control deficiency because of a high risk for potential
loss or manipulation of security data. Significant shortcomings in documentation of
security controls, disaster recovery procedures, and contingency planning
APRIL 1, 1997 THROUGH SEPTEMBER 30, 1997
27
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increase the risk of disruption to SPEDI processing and loss of data integrity.
Although the SPEDI production sites were not in compliance with OMB and Agency
requirements, they were not identified by assessable unit managers in the 1996
Assurance Letters that we reviewed as a serious internal control weakness.
Consequently, top management was not reporting or initiating corrective actions
through the Agency's OMB Circular A-123 process.
Some significant improvements were made in the implementation of security
controls at the Headquarters site. As a result, several high-risk conditions were
corrected which will significantly reduce the level of risk to SPEDI. In addition, a
walkthrough of the SPEDI LAN site at Headquarters revealed that good physical
security controls were in effect.
We Recommended That
The Director for Information Resources Management finalize and implement
Agency policies and guidance for the establishment, completion, and assessment
of Application and General Support System Security plans in accordance with OMB
Circular A-130.
The Director for Planning, Analysis, and Accountability update Agency Integrity
Guidance to comply with current OMB Circular A-123 guidance.
The Director for Acquisition Management direct the ICMS Program Manager to
coordinate the completion and approval of SPEDI (ICMS) Application and General
Support System Security plans, and provide interim guidance for developing a local
Application Security Plan.
What Action Was Taken
The final report (7100307) was issued to the Directors for Information Resource
Management; Acquisition Management; and Planning, Analysis, and
Accountability on July 18, 1997. In response to the draft report, the Agency
issued interim guidance for security plans, and a memorandum to officials
reiterating the need to review management controls for the security of Agency
information. In response to the final report, the Director, Planning, Analysis and
Accountability, agreed with our recommendations and provided milestone dates for
corrective actions. Responses to the final report were due October 18, 1997.
Financial Contract Audits
The EPA OIG provides independent contract audits and financial advisory services
to EPA's Office of Acquisition Management (OAM) and to other government
agencies at certain government contractors. During this reporting period, the OIG
maintained contract audit cognizance for 15 contractors where EPA contracts
represent the majority of the contractor's total auditable dollars. We are
responsible for performing all contract audits at these contractors, including
incurred cost audits, proposal reviews, and operations audits. In addition, we
provide assistance to OAM in developing negotiation objectives, input for OAM's
development of contract-related policy, and analysis of contractor responses to
report issues. Presented below are the results of two financial contract audits.
28 OFFICE OF INSPECTOR GENERAL
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Inadequate Supporting Documentation and Misclassified Costs
An audit of an incurred cost proposal resulted in questioned indirect pool costs of
$2,861,238. The questioned costs were comprised of numerous unallowable,
unallocable, and misclassified costs. Our findings included costs associated with
the contractor's annual meeting of $281,686 which were incorrectly classified in the
contractor's accounting records. This resulted in an inequitable allocation to
government contracts. In addition, computer and reproduction activities were
incorrectly classified as overhead expenses, rather than accumulated and
accounted for in a separate service center. This increased the risk of an
inequitable allocation of costs to government contracts. Finally, marketing costs of
$2,365,406 were improperly included in the general and administrative pool. We
questioned this entire amount because it included unallowable costs, unsupported
costs, and costs which did not have a causal/beneficial relationship to government
contracts and should not have been allocated to them.
Labor Proposed Under EPA Contract Overstated by $87,601 and Unsupported
by $3,042,852
An audit of $11,265,658 of labor costs incurred under an EPA contract disclosed
$87,601 of questioned costs and $3,042,852 of unsupported costs. The
questioned costs represent claimed costs which exceed costs actually paid by the
contractor. The unsupported costs represent labor costs which were not
adequately supported by the contractor's accounting records. The contractor was
unable to provide the necessary assurance that all the hours proposed were
actually paid to employees. In addition, we were unable to apply audit procedures
to obtain adequate assurance the labor amounts proposed were reasonable,
allocable, and allowable under Federal Acquisition Regulation, since the
contractor's accounting records did not alway adequately segregate labor costs.
APRIL 1, 1997 THROUGH SEPTEMBER 30, 1997
29
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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, 1997, EPA
had 180 OIG audit reports requiring
resolution, which was 17 less than
the ending balance March 31,
1997.
The number of past due audit
reports (reports with no
management decision within six
months of issuance) dropped from
111 to 92. This represented 51
percent of the reports in the follow-
up system as of September 30,
1997, compared to 56 percent as
of March 31, 1997.
the OIG reports for which
management decisions were past
due as of September 30, 1997, has
increased to 78 percent of total
questioned costs to be resolved
compared to 69 percent as of
March 31, 1997.
As of September 30, 1997, Agency
management had not responded to
77 percent (71 of 92) of the past
due audit reports. Three EPA
offices-Grants Administration
Division, Office of Acquisition
Management, and Region 3-
accounted for 75 percent (53 of 71)
of these.
About 5 percent (5 of 92) of the
past due reports were preaward
audits. As of March 31, 1997, 8
percent (9 of 111) of the past due
reports were preaward audits. EPA
is one of the few agencies that
reports on resolution of audits
conducted on preaward contract
proposals.
unresolved reports from March 31,
1995 (95 -1) through September
30, 1997 (97-2) show a disturbing
trend. Currently, these reports
represent 51.1 percent
of reports needing resolution,
compared to 37.9 percent three
years ago. 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.
Comparison of Unresolved Reports and Related Costs Questioned
(Past the 180-Day Time Frame for Resolution)
Percent
1OO%r
80%
6O% -
4O%
20% -
78.3%
51.1%
O%
95-1 95-2 96-1 96-2 97-1
^% Questioned Cost % Over ISO Days
Trends
However, the costs questioned on Analyses of the Agency's
97-2
30
OFFICE OF INSPECTOR GENERAL
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Status Report on Perpetual Inventory of Reports in Resolution Process for The Semiannual
Period Ending September 30,1997 (Dollar Values in Thousands)
Report Category
A. For which no
management decision was
made by April 1,1997
B. Which were issued
during the reporting period
C. Which were issued
during the reporting period
that required no resolution
Subtotals (A + B - C)
D. For which a
management decision was
made during the reporting
period
E. For which no
management decision
decision was made by the
end of the reporting period
Reports for which no
management decision was
made within six months of
issuance
No.
of
Rpts
197
235
128
304
124
180
92
Report Issuance
Questioned
Costs
$ 390,096
$58,597
0
448,693
187,717
260,976
204,361
Recommended
Efficiencies
$ 19,967
0
0
19,967
14,585
5,382
5,382
Report Resolution
Costs Sustained
To Be Recovered
48,516
As Efficiencies
552
(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.)
APRIL 1, 1997 THROUGH SEPTEMBER 30,1997
31
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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.
As presented, information contained
in Tables 1 and 2 cannot be used to
assess results of reviews performed
or controlled by this office. Many of
the reports were prepared by other
Federal auditors or independent
public accountants. EPA OIG staff
do not manage or control such
assignments. Auditees frequently
provide additional documentation to
support the allowability of such
costs subsequent to report
issuance. We expect that a high
proportion of unsupported costs
may not be sustained.
Table 1 ~ Inspector General Issued Reports With Questioned Costs for Semiannual Period
Ending September 30,1997 (Dollar Value in Thousands)
Report Category
A. For which no management decision was made
by April 1,1997**
B. New reports issued during period
Subtotals (A + B)
C. For which a management decision was made
during the reporting period
(i)Dollar value of disallowed costs
(ii)Dollar value of costs not disallowed
D. For which no management decision was made
by the end of the reporting period
Reports for which no management decision was
made within six months of issuance
Number of
Reports
111
43
154
58
48
45***
96
59
Questioned Costs*
$390,096
58,597
448,693
187,717
48,516
139,200
260,976
204,361
Unsupported Costs
$106,688
19,384
126,072
14,289
7,346
6,943
111,783
92,399
* Questioned costs include the unsupported costs.
** Any difference in number of reports and amounts of questioned costs between this report and previous semiannual report
results from corrections made to data in our audit tracking system.
***Ten audit reports totaling $ 3,085 were not agreed to by management.
32
OFFICE OF INSPECTOR GENERAL
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Table 2 Inspector General Issued Reports With Recommendations That Funds Be Put To
Better Use for Semiannual Period Ending September 30, 1997 (Dollar Values in Thousands)
Report Category
A. For which no management decision was made by April 1, 1997*
B. Which were issued during the reporting period
Subtotals (A + B)
C. For which a management decision was made during the
reporting period
(i) Dollar value of recommendations from reports that were
agreed to by management
(ii) Dollar value of recommendations from reports that were
not agreed to by management
(ill) Dollar value of non-awards or unsuccessful bidders
D. For which no management decision was made by the
end of the reporting period
Reports for which no management decision was made within six
months of issuance
Number of
Reports
9
0
9
6
1
4**
2
3
3
Dollar Value
$19,967
0
19,967
14,585
552
10,913
3,120***
5,382
5,382
* Any difference in number of reports and amounts of recommended efficiencies between this report and our previous semiannual report results from
corrections made to data in our audit tracking system.
** Five 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, no dollars shown for management decision on
these audits.
Audits With No Final Action As Of 9/30/97 Which Are Over One Year Past OIG Report Date
Audits
Programs
Allegations
Construction Grants
Assistance Agreements
Contracts
TOTAL
Non Superfund
37
o
3
135
10
23
208
Superfund
10
-
-
14
40
64
Total
47
o
3
135
24
63
272
Percent
17%
1%
50%
9%
23%
100%
APRIL 1, 1997 THROUGH SEPTEMBER 30,1997
33
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Section 3 - Office of Investigations-Significant Results
OFFICE OF INVESTIGATIONS GOALS AND ACTIVITIES
OFFICE OF INVESTIGATIONS GOALS: In fiscal 1998, the Office of Investigations will
increase its effectiveness in detecting and deterring fraud and other improprieties by
increasing the number of assistance and contract cases, improving the percentage of cases
resulting in referrals for action, reducing the average time for case completions, and
conducting more fraud awareness briefings.
ACTIVITIES TO MEET OUR GOALS
Program Integrity Investigations - Investigations of activities that could undermine the
integrity of Agency programs concerning safety and public health and erode public
confidence in the Agency. These cases are initiated in response to allegations or may be
self-initiated in high-risk areas where there is reasonable suspicion of fraud.
Assistance Agreement Investigations - Investigations of criminal activities related to
Agency grants, State Revolving Fund grants, interagency agreements and cooperative
agreements, which provide assistance to state, local and tribal governments, universities and
nonprofit recipients. Collectively, these programs account for about half of EPA's budget.
Contract and Procurement Investigations - Investigations involving acquisition
management, contracts and procurement practices. We specifically focus on cost
mischarging, defective pricing and collusion on EPA contracts. The decentralized nature and
the complexity of EPA contracting increase the Agency's vulnerability to fraud.
Employee Integrity Investigations - Investigations involving allegations against EPA
employees that could threaten the credibility of the Agency.
34
OFFICE OF INSPECTOR GENERAL
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Investigative Results
Summary Of Investigative
Activities
Pending Investigations as
of March 31, 1997 169
New Investigations
Opened This Period 82
Investigations Closed
This Period 95
Pending Investigations as
of September 30, 1997 156
Prosecutive and
Administrative Actions
In this period, investigative efforts
resulted in 8 convictions and 17
indictments.* Fines and recoveries,
including those associated with civil
actions, amounted to $579,700.
Twelve administrative actions were
taken as a result of investigations.
Reprimands 4
Resignations/Removals 2
Restitutions 2
Suspensions &
Debarments 3
Other 1
TOTAL 12
* Does not include indictments obtained in cas
in which we provided investigative assistance.
Profiles of Pending Investigations by Type
General EPA Programs
Total Cases = 98
Superfund/LUST
Total Cases = 58
APRIL 1, 1997 THROUGH SEPTEMBER 30,1997
35
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Fugitive Indicted as Money
Laundering Co-Conspirator
Asbestos Abatement
Training Firm Owner
Sentenced to Pay Over
$234,000 and Serve 52
Months in Prison and Three
Years Probation
On July 15, 1997, Sonny Igbokwe Wowo, a former Maryland resident,
was indicted for conspiracy and money laundering after an
investigation into embezzlement of $1.2 million from the State
Revolving Fund (SRF). A substantial portion of the SRF, administered
by the Maryland Water Quality Financing Administration (WQFA), was
funded by EPA for construction projects. The indictment charges that
Wowo and Rufus Ukaegbu, a former chief fiscal officer for the WQFA,
funneled the embezzled funds through phony businesses and bank
accounts using names similar or identical to those of contractors who
had legitimate business with the WQFA. Ukaegbu allegedly initiated
and authorized the fraudulent funds transactions, using wire and
check transfers.
In June 1994, Ukaegbu pleaded guilty to state charges of theft and
federal charges of money laundering. In October 1994, he was
sentenced to 41 months imprisonment on the federal charges and
repaid the state $100,000. In November 1994, he was sentenced on
the state charges to 20 years imprisonment (10 years suspended), five
years probation, and ordered to pay $1,105,901 in remaining
restitution. Ukaegbu is currently serving the remainder of his
sentence on federal charges. Wowo is currently a fugitive. This
investigation was conducted jointly by the EPA OIG and the FBI.
On September 26, 1997, Robert G. Cooley was sentenced to 52
months imprisonment and 3 years probation, ordered to pay restitution
of $234,763, and assessed $100 after pleading guilty to mail fraud and
bank fraud in July 1996.
Cooley owned and operated I.P.C. Chicago, Inc. (IPC), a company
approved by the Illinois Department of Public Health (IDPH) to provide
asbestos abatement training and issue accreditation certificates. IDPH
required all asbestos abatement workers and supervisors to be
accredited before they could lawfully perform any asbestos abatement
work in Illinois. During the course of the scheme, IPC issued
accreditation certificates to its customers without the customers
receiving the requisite training. Workers possessing IPC certificates
were subsequently discovered working on EPA funded Asbestos
School Hazard Abatement Act (ASHAA) projects. This case was
investigated jointly by the EPA OIG, FBI, and EPA CID
Selected Prosecutive
Actions
Corporate President Sentenced to Three
Years Probation
36
OFFICE OF INSPECTOR GENERAL
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Insurance Executive
Sentenced To Pay Over
$10,000 and Two Years
Probation for Fraud
special fee. DellaVecchia pleaded guilty on April 11, 1997, to
misprision of a felony in connection with a scheme to obtain corporate
financing by overstating the price of industrial equipment to be
purchased by IETG. DellaVecchia's sentencing concludes a three
year investigation by EPA OIG in which Robert Feller, President of Non
Hazardous Incineration Corporation (NHI) pleaded guilty to conspiracy
to create and distribute false approval letters of the EPA.
On July 11,1997, David Shewmake, president of Shewmake
Insurance Company, was sentenced to two years probation, fined
$5,000, assessed a $50 fee, and ordered to pay $5,212 for the cost of
probation supervision after pleading guilty to making a false statement
to influence the award of an EPA-funded asbestos abatement
contract.
As previously reported, in 1991, under the Asbestos School Hazard
Abatement Act (ASHAA), EPA approved the funding by the Chicago
Board of Education for asbestos abatement at Kennedy High School.
The Chicago Board of Education solicited bids from contractors to
perform the abatement, including required bid bonds frequently
accompanied by a power of attorney certifying authorization of an
agent to commit the surety to the promises made in the bid bond.
The indictment charged that Loyalty Environmental, Inc., a private
company engaged in asbestos removal, submitted a bid package of
$1,444,015 containing a fraudulent bid bond and power of attorney
that Shewmake prepared on behalf of Indiana "Lumberman's" Mutual
Insurance Company using an embossing device bearing the name of
the insurance company from a local printer.
On July 18, 1997, Laurence
DellaVecchia, former president of
Innovative Environmental
Technologies, Inc. (IETG), was
sentenced in United States District
Court, District of New Jersey, to 3
years probation and assessed a $50
Business Owner Indicted for
Impersonating a United States Officer
and Mail Fraud
APRIL 1, 1997 THROUGH SEPTEMBER 30,1997
37
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Former Laboratory
Directors Plead Guilty to
Falsifying Test Results;
Company Charged
Businessman Convicted;
Partner Sentenced to Pay
$70,000 and Serve Five
Years Probation for
Conspiracy
restaurants in various states by mailing a notice that falsely purported
to be from a U.S. government agency, the United States
Environmental Protection Enforcement Agency (EPEA), requiring the
restaurant owners to file and pay an annual registration fee of $189,
under the Clear Air Act to Birt's business address. The notice warned
that failure to comply could result in a temporary restraining order or a
permanent injunction and a civil penalty of up to $5,000 per day.
On June 20, 1997, a superseding indictment charged Birtwith
additional counts of mail fraud. This investigation was conducted
jointly by the EPA OIG and Postal Inspection Service.
On June 27, 1997, Michael Louis Klusaritz, former director of Hess
Environmental Laboratories (Hess), East Stroudsburg, PA, pleaded
guilty to falsifying water and sewage test results for the Tobyhanna
Army Depot and other clients. Klusaritz was charged on June 19,
1997, with making false statements, false claims, and mail fraud.
Phase II Laboratories, which is owned by Klusaritz, also pleaded guilty
to similar charges. Klusaritz admitted falsifying test results and billing
customers more than $223,000 for testing that, in most cases, was
never done.
On September 17, 1997, Judith McCoy, a former Hess Technical
Manager, pleaded guilty of conspiracy to defraud the government,
making false statements, and mail fraud while she was acting
laboratory director at Hess. McCoy ran the laboratory after Klusaritz
left in June 1995 and continued the falsified environmental testing at
the direction of another Hess official. Some of the falsified results
reported lower amounts of contaminants and hazardous materials
when, in fact, they exceeded regulatory levels. She was charged on
July 30, 1997, with falsifying test results and billing customers more
than $27,000 for the false results. On September 29, 1997, an
information was filed charging Hess with conspiracy, false statements,
false claims, mail fraud, and violations of the Clean Water Act. The
investigation was conducted jointly by the EPA OIG, the EPA CID, and
the Army Criminal Investigations Command.
On July 14, 1997, Richard D. Salvatierra was convicted in United
States District Court for the District of Maryland on three counts of
filing false personal and corporate income tax returns. On December
18, 1996, Salvatierra, an officer and shareholder of Ricards
International, Inc. (Rll), of Silver Spring, Maryland, was indicted on
charges of conspiracy to defraud the United States, false claims,
aiding and abetting, and filing a false tax return. Salvatierra was also
On June 2, 1997, Larry Birt, owner of
Kentron of Georgia, a refrigeration,
heating and air conditioning business,
was arrested following his indictment
on charges of impersonating an
officer of the United States to obtain
money and mail fraud. The
indictment charges that Birt defrauded
38
OFFICE OF INSPECTOR GENERAL
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EPA Employee Sentenced
to Probation, Community
Service, and Ordered to Pay
$3,453 in False Claims Case
Company and Its President
Charged; President
Arrested
as part of the conspiracy, Salvatierra and Edsel Billingy, former officer
at Rll and shareholder in PLI, divided extra funds generated by the
inflated costs between themselves by having PLI pay certain personal
expenses, claiming them as business expenses on their income tax
returns.
On July 30, 1997, Billingy was sentenced to five years probation,
ordered to pay restitution of $70,000, and a special fee of $50, after
pleading guilty to conspiracy on March 17, 1997. This investigation
was conducted jointly by the EPA OIG, the HHS OIG, and the Internal
Revenue Service.
On June 19, 1997, James M. McDuffie, an EPA personnel
management specialist, was sentenced to one year probation, 50
hours of community service, fined $2,000, ordered to pay restitution of
$1,428, and a $25 special fee, after pleading guilty to submitting a
false claim for mileage expenses while on an Intergovernmental
Personnel Act assignment. An investigation revealed that McDuffie
claimed mileage expenses for travel between his residence and his
post of duty at North Carolina A&T University in Greensboro, North
Carolina, when he did not report to his post of duty.
On May 7, 1997, Christopher Tate, president of Safety Management
Institute, Inc. (SMI), Roaring Spring, PA, was arrested on charges of
tampering with public records, forgery, unsworn falsification to
authorities, and violating the Underground Storage Tank Act. Tate
was previously arrested on April 16, 1997, on charges of various
environmental violations. SMI was a contractor engaged in the
removal of underground storage tanks in Hanover, PA, during 1994
when Tate allegedly falsified documents, transported hazardous
waste without a license, and failed to report that he was previously
suspended and debarred from government contracting. This
investigation was conducted jointly by the EPA OIG and the
Environmental Crimes Section of the Office of the Attorney General,
Commonwealth of Pennsylvania.
an officer and shareholder in Potomac
Leasing, Inc. (PLI), which leased
warehouse and office space and then
subleased the space to Rll at a higher
rate. These higher costs were billed
to EPA and the Department of Health
and Human Services (HHS). Further,
EPA Project Officer Pleads Guilty to
Conflict of Interest
APRIL 1, 1997 THROUGH SEPTEMBER 30,1997
39
-------
authorizing EPA to make a $33,894 payment to benefit Lyndon Lee
and Associates, Inc. (LLA), on a matter pending under his authority
while he negotiated and accepted future employment with LLA.
EPA gave the State of Minnesota a grant to assist in financing Wetland
Conservation training. Rockwell advised the Minnesota Board of
Water and Soil Resources (MBWSR) of the ability of LLA to provide
the wetland conservation training, and LLA was awarded the contract.
Rockwell acted as the project officer on the wetland conservation
training project and acted as an instructor during the training provided
by LLA. Rockwell began negotiating future employment with LLA in
August 1992. Rockwell authorized payment of EPA funds to LLA in
September 1992. Rockwell signed an employment agreement with
LLA in December 1992, and he resigned from EPA in January 1993.
Rockwell was employed by LLA from January 18, 1993, through
March 12, 1993 and was rehired by EPA on May 1, 1994.
On August 14, 1997, Theodore
Rockwell, an EPA Region 10
Environmental Scientist, pleaded
guilty in United States District Court,
District of Alaska, to violating Federal
conflict of interest statues. On July 7,
1997, Rockwell was charged with
40
OFFICE OF INSPECTOR GENERAL
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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 of the Office of General Counsel, 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.
Company Agrees to
$150,000 Settlement on
Double Billing and
Unsubstantiated Changes
On September 3, 1997, Waste-Iron, Inc., of Charleston, West
Virginia, agreed to pay the government $150,000 in a settlement
agreement with the United States Attorney's Office, Eastern District of
Pennsylvania, to resolve allegations that the company, as a
subcontractor, caused false claims to be submitted through the
government's prime contractor OH Materials Corp., now OHM
Remediation Services, in connection with the cleanup of a polluted
site. The Fike/Artel Chemical Superfund Site in Nitro, West Virginia,
consisted of a 12-acre facility, including a chemical production facility
and various disposal areas for wastes that had been produced by the
chemical processes. Waste-Iron, as a subcontractor, was
responsible for the transportation and disposal of waste from the
Fike/Artel Site. The investigation resulted in allegations that Waste-
Iron submitted fraudulent invoices to OHM that inflated the quantities
or nature of the wastes disposed, improperly added charges for
transportations and disposal of waste which had already been billed,
and was paid twice in some instances.
Contractor Required to Pay
Over $92,000
On April 21, 1997, Chemical Waste Management, Inc. (ChemWaste),
of Bensalem, Pennsylvania, entered into a settlement agreement with
the Department of Justice requiring ChemWaste to pay $92,685 to
resolve civil fraud and contract claims arising out of work performed by
the company at the Moyer Landfill Superfund Site in Montgomery,
Pennsylvania. In 1989, the U.S. Army Corps of Engineers contracted
with ChemWaste for remediation work at the site. In January 1993,
ChemWaste disclosed to the Department of Defense that
Civil and Administrative
Actions to Recover EPA
Funds
EPA Contractor Agrees to Pay $10,000
and Remove Over $300,000 in Incentive
Compensation Cost from Overhead
APRIL 1, 1997 THROUGH SEPTEMBER 30,1997
41
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settlement agreement with the United States in which it agreed to
remove $300,443 in incentive compensation from its incurred cost
submission for 1993, 1994 and 1995, and pay the United States
$10,000. The civil settlement was the result of an investigation into
allegations that JWK improperly charged salaries, travel costs, direct
labor, and consultant costs to an EPA contract. This investigation was
conducted jointly by the EPA OIG and the Naval Criminal Investigative
Service.
ChemWaste employees had failed to
conduct air and Geiger counter
monitoring at the site as required by
the contract. This investigation was
conducted jointly by the EPA OIG and
the Defense Criminal Investigative
Service.
On April 24, 1997, JWK International,
Inc. (JWK), entered into a civil
42 OFFICE OF INSPECTOR GENERAL
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Selected Suspension and
Debarment Actions
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.
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 OIG
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.
The action summarized below resulted from an OIG investigation:
On April 22, 1997, EPA debarred James B. Speer, Jr., for 15 years
from July 3, 1995, the date of the EPA Notice of Suspension and
Proposed Debarment. Speer is the former project manager for the
Olympic View Environmental Review Council (OVER-C), an EPA
grantee. On July 1, 1997, Cassandra Wohlgethan, Speer's associate,
was also debarred for three years from July 3, 1995. An OIG
investigation revealed that Speer embezzled funds from OVER-C by
paying himself $82,000 instead of fully paying a contractor for
consultant services. As previously reported, on March 30, 1995, Speer
was convicted on 26 counts of first and second degree theft and, on
May 5, 1995, was sentenced to 66 months incarceration and ordered
to make full restitution. Wohlgethan was not prosecuted in connection
with the embezzlement, but was debarred for allowing funds that she
knew or had reason to know were illegally obtained by Speer to be
placed in her credit union account. This investigation was conducted
jointly by the EPA OIG and the Kitsap County, Washington,
Prosecuting Attorney's Office.
APRIL 1, 1997 THROUGH SEPTEMBER 30,1997
43
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Section 4- Fraud Prevention and Management Improvements
This section describes 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.
Advisory and Assistance Services
Allegations of Fraud in Methyl
Parathion Program
Responding to a request from Agency regional
officials, Ol special agents began investigating
allegations of fraud in the methyl parathion
relocation program. Early in the course of the
investigation, systemic vulnerabilities within the
program were identified. Ol special agents had a
positive effect on the integrity of the program by
helping to establish identification and verification
procedures for applicants and household members
at the time of application and prior to release of
subsistence payments. Ol suggested other
improvements in the application process to help
protect against abuse and fraud, to include a
certification form with a warning regarding penalties
for false statements, a medical release form, and
interview questions designed to identify fraudulent
claims. To raise awareness concerning the potential
for program abuse, the investigators conducted
fraud awareness briefings for Agency and Army
Corps of Engineers personnel who were assisting
with the relocation of residents from contaminated
dwellings and with removal and clean-up activities,
and for other state and local officials in the affected
regions. Individual investigations have resulted in the
program addressing numerous ineligible applicants
which represent a considerable cost savings, and
several cases are being considered for prosecution
by the Department of Justice.
Controls Over Emergency Removal
Actions at Methyl Parathion Sites
At the Agency's request, the Office of Audit assessed
controls over emergency Superfund removal actions
at sites contaminated with methyl parathion. Methyl
parathion, a highly toxic pesticide registered for
outdoor agricultural use, was illegally sprayed inside
numerous businesses and residences. The methyl
parathion removal actions included environmental
and biological sampling, resident relocation, and
residence decontamination and restoration.
We found that EPA could strengthen controls over
the emergency removal process for methyl
parathion. The lack of clear and concise guidance
has resulted in potential risks in implementing new
sampling procedures to detect excessive levels of
methyl parathion in residents, and increased costs
and delays in completion of residential restorations.
EPA did not adequately address resources to collect
and analyze the samples, subsequent monitoring, or
procedures for disclosure and notification of
changes in residential occupancy. Without adequate
resources and procedures, implementation of the
new procedures could result in reduced
effectiveness of the program and create increased
exposure and adverse health effects.
Lack of clear guidance also contributed to
inconsistencies in decisions to clean up
contaminated businesses, the potential for
fraudulent and excessive relocation costs, and
inconsistencies in the documentation of personal
property items. The lack of specific detail in some
regions could expose EPA to fraudulent claims and
additional expenses should residents dispute
reimbursements and/or claim items as missing or
damaged.
A report (7400069) was issued to the Acting
Assistant Administrator for Solid Waste and
Emergency Response on September 23, 1997. We
suggested that EPA modify existing guidance and
develop new guidance to address emergency
removal actions at methyl parathion sites. EPA has
issued several new directives which address some of
our concerns.
Implication of Conflicts of Interest
Not Supported
The book, Toxic Deception: How the Chemical
Industry Manipulates Science. Bends the Law, and
Endangers Your Health refers to 3,363 trips taken by
Agency employees over a two-year period that were
reimbursed (over $3 million) by the industry. The
44
OFFICE OF INSPECTOR GENERAL
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book implies that sponsoring these trips influences
the regulatory decisions of key Agency officials. The
book also discusses a number of top level officials
and staff who have left EPA for jobs in the industry
(the revolving door) alleging that this activity is the
most effective method for the industry to stifle
regulations. At the request of EPA's Deputy
Administrator, we reviewed these issues.
We found that the facts presented in the book were
essentially correct. However, the facts did not
support the implication of any violation of the
applicable Ethics Reform Act of 1989 and its
implementing regulations. We found that the
applicable internal controls are sufficient regarding
these issues; and therefore, we made no
recommendations. The report (7100227) was
issued to the Deputy Administrator on June 16,
1997.
Inferior Materials Replaced, Current
Costs Reduced, Future Costs
Avoided in California Wastewater
Treatment Plant.
An investigation determined that four subcontractors
installed substandard, non-conforming material
during construction of the North City Water
Reclamation Plant in San Diego, California. As a
result, inferior materials were replaced where
possible, contract amendments were effected, and
significant future costs were avoided. As part of the
special appropriations for Coastal Cities grants for
the construction of wastewater treatment plants,
EPA granted $75,950,000 for the North City Water
Reclamation Plant. The United States entered into a
treaty with Mexico to allow wastewater from Tijuana
to be diverted to the new treatment plant.
Previously, this wastewater was allowed to enter into
the Tijuana River and it eventually reached and
contaminated San Diego Bay. Based upon
information supplied by the Army Corps of
Engineers, the investigation identified substandard,
non-conforming material installed by four electrical
and mechanical subcontractors at the site. Unistrut
supports and pipe hangers contained lower grade
corrosion coating material than called for in the
contract specifications. Technical support for the
investigation was provided by the EPA Office of
Audit, Engineering and Science Staff.
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 three legislative and 44 regulatory items.
The most significant items reviewed are summarized
below.
H.R. 96 - Small Business Regulatory
Assistance Act of 1997
J
While we recognize the bill's goal of assisting
voluntary compliance with Federal regulations by
small businesses, we expressed concern with the
proposed mechanism for achieving this objective.
Specifically, Small Business Development Centers,
staffed by non-EPA, non-Federal employees, would
provide advice and assistance in interpreting Federal
regulations for small businesses. Such a function
appears to be inherently governmental and would
best be performed by Federal employees.
We also expressed concern with the provision
allowing participating small businesses to be in full
compliance if they fulfilled certain compliance
objectives and priorities, because the bill did not
indicate who would make this determination and
what means used to achieve the objectives would be
acceptable.
Finally, we disagreed with the provision granting
anonymity to participating small businesses because
we believed it would hinder EPA's enforcement
program.
In its May 12 response to the Office of Management
and Budget, EPA's Office of Congressional and
Legislative Affairs (OCLA) also opposed the
development of Small Business Development
Centers. OCLA stated that such a mechanism
would divert funds from an efficient, direct method of
counseling to administrative costs and an additional
"middleman." OCLA also expressed concern with
the compliance provision and stated that any
"compliance" schedules established by the Centers
would not be enforceable and would be hidden from
the public under the confidentiality provision.
Contracts Management Manual
Chaper 1
APRIL 1,1997 THROUGH SEPTEMBER 30,1997
45
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We commented that the revised chapter, which
provides guidance on acquisition and contract
management planning, did not adequately address
performance-based service contracting or fixed-price
contracting. We recommended that the chapter be
revised to require program offices to demonstrate in
their plans how conversion from level-of-effort type
contracts to performance-based contracts will be
accomplished, or explain why it is not feasible to do
so. We also noted that the chapter did not highlight
certain important requirements of FAR 7.105, which
addresses the contents of acquisition plans.
At the end of the reporting period, the Agency had
not issued a revised document.
Revised Draft Implementation Order
to Streamline Small Grants
While the revised version addressed our concerns
with the initial document, it did not:
clearly indicate how EPA will determine
whether small grant recipients meet
required criteria or who will make this
determination;
describe the extent of financial information
needed for an award decision; what
guidance will be used to conduct a price
analysis of the applicant's proposed budget;
or require that the analysis be documented
and maintained in the grant file;
require grantees to satisfactorily complete
the Final Project Report and the Financial
Status Report before final payment is made,
regardless of the size of the grant award;
and
require that the maximum allowable amount
of preaward costs be specified in the grant
award.
The Agency had not revised the document at the
end of the reporting period.
Revision of Delegations Manual 1-11,
Interagency Agreements
We did not concur with the proposed revision
concerning the award of interagency agreements
because it did not specify that the Assistant
Administrators and Regional Administrators must
consult their Senior Resource Official prior to
exercising their authority. We also pointed out that
while supporting documents indicated that Associate
Award Officials would have limited authority, the
revised delegation contained no limitation.
At the end of the reporting period, the OIG and
Agency were working to resolve OIG concerns.
EPA Plan for a Drug-Free Workplace |
We did not concur with the draft document because
it did not adequately reflect the independent status of
the OIG. We recommended that the document
specify that personnel decisions for OIG employees
be made by the Inspector General.
We also recommended that the policy statement
make clear that the Federal policy of zero tolerance
for drug use will be unaffected by conflicting state
laws and that employees who voluntarily admit to
drug use will be subject to certain administrative
actions. Finally, we indicated that additional OIG
positions should be added to the list of Testing
Designated positions.
At the end of the reporting period, the OIG and the
Agency were working to resolve OIG concerns.
OIG Management Initiatives
As part of our continuing reinvention efforts, we
consolidated activities in the immediate Office of
Inspector General (OIG) and the Office of
Management (OM) which will result in a more
systematic, streamlined approach to performing
many administrative and technical functions. The
Program Support Staff (PRSS), which replaces OM,
will provide complete, high-quality, timely support
services to the Offices of Audit and Investigations.
Within PRSS, we have also consolidated and co-
located budget execution staff who were previously
split among the three offices. The sharing of
knowledge, expertise, and responsibilities will enable
46
OFFICE OF INSPECTOR GENERAL
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the new budget team to develop and execute the
OIG budget in a highly efficient and effective
manner.
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
com posed of senior EPA program and regional
officials and is chaired by the Acting Inspector
General.
PUBLIC SERVICE RECOGNITION
WEEK
To pay tribute to EPA's employees and to convey
appreciation for their outstanding contributions
toward the Agency's mission and to the overall well-
being of our Nation, CIMI sponsored a series of
special events and exhibits during the eleventh
annual EPA Headquarters observance of Public
Service Recognition Week. The highlight of the
week's events was a special ceremony honoring the
EPA work force, at which 33 employees from ten
Headquarters organizations were presented with the
EPA Employee Recognition Award for Community
Service. Acting Inspector General Nikki Tinsley
served as mistress of ceremonies for the event;
several EPA employees provided musical
entertainment; and our guest speaker, DPI White
House Bureau Chief Helen Thomas, reflected upon
her long and illustrious career and discussed the
importance of public service. Following the
ceremony, the Administrator and the Acting
Inspector General hosted a reception for the 1997
award ees.
prosecutive, or administrative corrective action.
Cases that did not have immediate validity due to
insufficient information may be used to identify
trends or patterns of potentially vulnerable areas for
future review. At the end of this semiannual
reporting period, 38 Hotline cases were open.
The following is an example of corrective action
taken as a result of information provided by the OIG
Hotline:
A complainant alleged that Region 5's Office of
Regional Counsel employed a non-United States
citizen in a position requiring citizenship. The matter
was referred to the Office of Human Resources and
Organizational Services, which conducted an inquiry
that led to the employee's termination.
Hotline Activities
The OIG Hotline opened 12 cases and completed
and closed six cases during the reporting period. Of
the cases closed, two resulted in environmental,
APRIL 1,1997 THROUGH SEPTEMBER 30,1997
47
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Appendix 1 -- Reports Issued
THE INSPECTOR GENERAL ACT REQUIRES A LISTING, SUBDIVIDED ACCORDING TO SUBJECT MATTER, OF EACH REPORT ISSUED
BY THE OFFICE DURING THE REPORTING PERIOD AND FOR EACH REPORT, WHERE APPLICABLE, THE DOLLAR VALUE OF
QUESTIONED COSTS AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE.
Questioned Costs
Assignment Control Number
Title
Final Report
Issued
Recommended
Efficiencies
Ineligible
Costs
Unsupported
Costs
Unreasonable (Funds Be Put
Costs To Better Use)
1. INTERNAL AND MANAGEMENT ASSIGNMENTS
Deputy Administrator
E6AMF7-11-0010-7100227 CENTER FOR PUBLIC INTEGRITY
TOXIC DECEPTION
6/16/97
Associate Administrator for Regional Operations and
State/Local Relations
E1PMF6-05-0115-7100277 ERA'S MANAGEMENT OF REGIONAL LABS 8/20/97
FMD Cincinnati Accounting Operations Office
E1AMG6-23-7096-7400037 CFO ACT 96 FMD-CINCINNATI
4/24/97
Grants Administration Division
E1FEF7-13-0087-7100236 EPA AND GRANTEE CONTROLS OVER 6/19/97
LOBBYING EXPENSES
E1NMF6-15-3044-7100237 INTEGRITY OF DATA IN THE GRANTS 6/24/97
INFORMATION AND CONTROL SYSTEM
Assistant Administrator for Administration and Resources Management
9/30/97
E1SKF7-04-0037-7100301 OMB REQUESTED REVIEW OF EPA
CONTRACTING
E1YFB7-05-0002-7400070 CONTRACT MANAGEMENT INITIATIVES
E1FEF6-13-0079-7100296 SENIOR ENVIRONMENTAL EMPLOYMENT
(SEE) PROGRAM
9/30/97
9/29/97
Office of Information Resources Management
E1NMF5-15-3037-7100284 EPA INTERNET SECURITY
E1AMR7-15-7012-7100307 SECURITY OF SMALL PURCHASE
ELECTRONIC DATA INTERCHANGE
(SPEDI) LANS
9/ 5/97
7/18/97
Assistant Administrator for Solid Waste & Emergency Response
E1DSF7-11-0005-7100274 REVIEW OF RCRA FACILITY 8/13/97
INVESTIGATIONS
Assistant Administrator for Water
E1DMF6-08-0016-7100223 HARDROCK MINING LIABILITIES
6/11/97
Office of Emergency & Remedial Response
48
OFFICE OF INSPECTOR GENERAL
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E1SFB7-06-0020-7400069 ASSESSMENT OF CONTROLS OVER
EMERGENCY REMOVAL ACTIONS AT
METHYL PARATHION SITES
9/23/97
Assistant Administrator for Enforcement & Compliance Assurance
E1GAE5-05-0169-7100306 CONSOLIDATION REVIEW OF THE AIR 9/30/97
ENFORCEMENT AND COMPLIANCE
ASSISTANCE PROGRAMS
Director of Environmental Justice
E1FME6-01-0086-7100247 NATIONWIDE AUDIT OF ENVIRONMENTAL 7/30/97
JUSTICE SMALL GRANT PROGRAM
Regional Administrator - Region 1
E1KAD7-01-0017-7100305 VALIDATION OF AIR ENFORCEMENT
DATA REPORTED TO EPA BY
MASSACHUSETTS
9/29/97
E1FMG6-01-0071-7400058 LESSONS LEARNED FROM THE 7/24/97
MASSACHUSETTS GRANT FLEXIBILITY
PROGRAM
Regional Administrator - Region 2
E1EPF6-02-0027-7100213 TOXIC RELEASE INVENTORY
5/28/97
E1SHF6-02-0047-7100288 EMERGENCY RESPONSE MANAGEMENT AT 9/16/97
SUPERFUND REMOVAL SITES
Regional Administrator - Region 3
E1KAF7-03-0047-7100302 REGION 3'S OVERSIGHT OF 9/29/97
MARYLAND'S AIR ENFORCEMENT DATA
Chief Information Management Branch - Region 4
E1NMF7-15-0001-7100308 SECURITY OF REGION 4 LANS
9/30/97
Director Science & Ecosystems Support Division -
Region 4
E1NMF7-15-0001-7100309 SECURITY OF SCIENCE AND 9/30/97
ECOSYSTEMS SUPPORT DIVISION LANS
Regional Administrator - Region 5
E1AMG6-05-7596-7400036 CFO ACT 96 -- REGION 5
4/24/97
Regional Administrator - Region 6
E1GAF7-06-0014-7100295 REGION 6'S OVERSIGHT OF ARKANSAS 9/26/97
AIR ENFORCEMENT DATA
Regional Administrator - Region 8
E1HWF7-08-0009-7100304 REGION 8 NONPOINT SOURCE PROGRAM 9/30/97
Regional Administrator - Region 9
E1GAD6-09-0023-7100246 REGION 9'S ENFORCEMENT OF THE 7/24/97
CALIFORNIA AIR COMPLIANCE AND
ENFORCEMENT PROGRAM
TOTAL
26
APRIL 1, 1997 THROUGH SEPTEMBER 30,1997
49
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2. CONSTRUCTION GRANT ASSIGNMENTS
E2CWP5-01-0171-7400046 WEST WARWICK
TOTAL OF REGION 01 =
RI
1
P2CWL5-02-0014-7100185
P2CWL2-02-0085-7100212
P2CWL4-02-0093-7100273
NASSAU COUNTY - CEDER CREEK NY
PRASA MAYAGUEZ RS PR
PARSIPPANY-TROY HILLS NJ
TOTAL OF REGION 02
E2CWN6-03-0147-7300041
E2HTP7-03-0134-7400048
P2CWN5-03-0035-7300029
P2CWN4-03-0042-7300032
P2CWN5-03-0039-7300033
UPPER GWYNEDO-TOWAMENCIN
WV INTERNAL CONTROLS-SRF
HENRICO COUNTY
COLUMBIA, D1ST OF
COLUMBIA, DIST OF
PA
WV
VA
DC
DC
TOTAL OF REGION 03 =
E2CWN6-04-0022-7300030
E2CWN4-04-0218-7300035
E2CWN6-04-0050-7300037
E2CWN5-04-0134-7300038
GASTONIA NC
MANATEE COUNTY FL
CAVELAND SANITATION AUTHORITKY
HILLSBOROUGH COUNTY FL
TOTAL OF REGION 04 =
E2CWL6-05-
E2CWL5-05-
E2CWL5-05-
E2CWM6-05-
E2CWM6-05-
E2CWM6-05-
E2CWM6-05-
E2CWM6-05-
0052-7100192
0125-7100275
0080-7100276
0058-7200007
0049-7200008
0048-7200018
0045-7200019
0047-7200020
BRAZIL
PORTAGE LAKE WSA
BARAGA
WINCHESTER
MONROE CO
WAYNE CO
WAYNE CO
WAYNE CO
TOTAL OF REGION 05 =
8
IN
MI
MI
MI
MI
MI
MI
MI
HI
AZ
E2BWN6-09-0063-7300039 HAWAII, COUNTY OF
E2HTP7-09-0063-7400057 ARIZONA - SRF
TOTAL OF REGION 09 = 2
TOTAL CONSTRUCTION GRANT ASSIGNMENTS
3. OTHER GRANT ASSIGNMENTS
C3HVK7-33-0001-7500038 ANNE ARUNDEL COUNTY MD
C3HVK7-33-0012-7500045 FORT LAUDERDALE CITY OF FL
C3HVK7-33-0011-7500051 ILLINOIS EPA IL
G3HVK7-33-0003-7500040 WASHINGTON SUBURBAN SANITARYMD
N3HVK7-33-0002-7500039 NEBRASKA, STATE OF NE
N3HVJ7-33-0004-7500041 LOUISIANA STATE OF LA
N3HVK7-33-0005-7500042 BALTIMORE MD
N3HUK7-33-0006-7500043 ALASKA NATIVE HEALTH BOARD AK
N3HUK7-33-0008-7500044 UNIVERSITY OF AKRON OH
N3HMK7-33-0007-7500046 MORONGO BAND OF MISSION INDSCA
N3HVK7-33-0018-7500047 NEW JERSEY STATE OF FYE 6/95NJ
N3HVJ7-33-0019-7500048 IDAHO STATE OF ID
N3HVJ7-33-0017-7500049 FLORIDA STATE OF FYE 6/96 FL
N3HVJ7-33-0017-7500050 FLORIDA STATE OF FYE 6/96 FL
N3HUK7-33-0026-7500052 NATIONAL ACADEMY OF SCIENCE DC
N3HVK7-33-0023-7500053 MASS. COMMONWEALTH OF MA
N3HVK7-33-0020-7500054 ILLINOIS DNR IL
N3HVK7-33-0016-7500055 ILLINOIS DMN IL
N3HVH7-33-0031-7500056 BALTIMORE CITY MD
N3HVJ7-33-0021-7500057 MAINE STATE OF ME
TOTAL OF REGION 33 = 20
E3CWL7-02-0013-7100283 NEWARK NJ
TOTAL OF REGION 02 = 1
C3HVK7-03-0128-7500036 PRINCE WILLIAM COUNTY VA
5/19/97
4/30/97
5/28/97
8/11/97
9/17/97
5/30/97
5/ 5/97
5/30/97
6/ 2/97
5/14/97
6/ 4/97
6/ 5/97
6/19/97
5/ 9/97
8/14/97
8/14/97
5/ 1/97
5/27/97
8/ 4/97
8/ 4/97
8/ 8/97
7/31/97
7/23/97
= 23
5/20/97
7/15/97
9/11/97
5/22/97
5/21/97
6/ 5/97
6/ 5/97
6/18/97
6/27/97
7/15/97
7/29/97
7/31/97
8/27/97
8/27/97
9/15/97
9/22/97
9/22/97
9/22/97
9/30/97
9/30/97
9/ 2/97
4/ 9/97
1,374,670
1,374,670
93,515
302,113
1,959,778
2,355,406
225,670
0
4,244,705
892,825
1,985,919
7,349,119
268,924
873,286
92,652
84,903
1,319,765
0
5,367
26,838
77,060
120,766
269,676
99,973
72,894
672,574
61,062
0
61,062
13,132,596
0
0
0
0
0
0
2,619,911
0
0
0
0
0
0
0
0
0
0
0
19,417
0
2,639,328
0
0
0
0
0
13,538,839
1,315,732
1,549,129
16,403,700
285,275
0
0
296,451
285,709
867,435
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
17,271,135
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
519,500
519,500
0
4,939,440
0
0
0
0
0
0
0
4,939,440
11,873,026
0
11,873,026
16,812,466
0
0
0
0
0
0
0
0
0
0
0
0
639,653
0
0
0
0
0
0
0
639,653
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
50
OFFICE OF INSPECTOR GENERAL
-------
C3HVK7-03-0138-7500037
E3LLL7-03-0009-7100290
E3CEL6-03-0139-7100297
G3HUK7-03-0135-7500035
BALTIMORE COUNTY MD
AUDIT OF MD LUST AGREEMENTS MD
NATIONAL UNIV CONT ED ASSOC.DC
CENTER FOR WATERSHED PROTECTMD
TOTAL OF REGION 03 = 5
E3RWP7-05-0060-7400034 RIVER ROUGE SITE DEMO
TOTAL OF REGION 05 = 1
MI
4/17/97
9/17/97
9/24/97
4/ 8/97
4/21/97
0
7,883
733,878
0
741,761
272,859
272,859
0
0
218,382
0
218,382
0
0
TOTAL OTHER GRANT ASSIGNMENTS
= 27
3,653,948
737,882
639,653
5. SUPERFUND GRANT ASSIGNMENTS
E5FFL7-03-0008-7100292 SUPERFUND OVERSIGHT COSTS
TOTAL OF REGION 03 = 1
E5BGL6-07-0035-7100220 SUPERFUND COOPERATIVE AGREE MO
TOTAL OF REGION 07 = 1
E5HGL6-10-0027-7100188 BOOMSNUB SF CREDIT WA
TOTAL OF REGION 10 =1
H5BFL7-20-0007-7100285 IAG AUDIT REPORT
H5BFL7-20-0007-7100286 IAG AUDIT REPORT
M5BFL7-20-0007-7100293 SUPERFUND IAG-DOD
TOTAL OF REGION 20 = 3
TOTAL SUPERFUND GRANT ASSIGNMENTS =
9/22/97
6/ 9/97
4/30/97
9/10/97
9/10/97
9/23/97
0
0
0
0
0
0
0
0
0
8. OTHER CONTRACT ASSIGNMENTS
D8BML6-44-0074-7100154 CLEAN AIR VEHICLE CI 96
D8BML7-44-0106-7100170 ETS INCORPORATED
D8DML6-44-0026-7100178 RAVEN RIDGE RESOURCES INC
D8CML7-44-0082-7100184 SRA TECHNOLOGIES INC.
D8BML4-44-3148-7100195 F.W. ENVIRESPONSE INC
D8CML6-44-0090-7100202 WESTAT
D8CML6-44-0181-7100203 AMERICAN MANAGEMENT SYSTEMS VA
D8EML7-44-0036-7100204 OAO CORPORATION
D8BML5-44-0322-7100205 SCIENTIFIC&COMMERCIAL SYSTEMVA
D8BML7-44-0035-7100206 GEOLOGICS CORPORATION
D8DML7-44-1040-7100209 VIGYAN, INC.
D8BML2-44-0324-7100214 JWK INTERNATIONAL
D8CML7-44-0022-7100215 PACIFIC ENVIRONMENTAL SERV
D8BML7-44-0070-7100216 SOLUTIONS BY DESIGN
D8BML7-44-0102-7100217 MNEMONICS SYSTEMS INC.
D8CML6-44-0199-7100218 PACIFIC ENVIRONMENTAL SVCS
D8BML6-44-0060-7100219 SONOMA CI 95
D8BML7-44-1054-7100224 PROF AND SCIENTIFIC ASSOC
D8BML3-44-0194-7100225 INTEGRATED LABS
D8CML7-44-1055-7100226 DYNAMAC
D8CML3-44-0120-7100228 MIDWEST RESEARCH INST.
D8BML5-44-0085-7100229 INTEGRATED LABORATORY SYSTEMNC
D8EML7-44-1062-7100231 MANTECH ENVIRONMENTAL
D8CML7-44-1063-7100232 PARSONS ENGINEERING SCIENCE CA
D8BML5-44-0381-7100240 EAGLE MAINTENANCE SERVICES
D8GML7-44-1093-7100241 OAO CORPORATION
D8BML5-44-0371-7100242 SCICOMM INC
D8BML6-44-0073-7100243 SIERRA CI 95
D8BML5-44-0072-7100244 VISTA COMPUTER SERVICES, II
D8BML7-44-0088-7100245 ARMSTRONG DATA SERVICES INC.VA
D8BML6-44-0095-7100248 CADMUS GROUP INC
D8BML5-44-2188-7100249 WADE MILLER ASSOCIATES INC.
D8CML7-44-0016-7100251 RADIAN CORP
D8CML7-44-0017-7100252 RADIAN CORP
D8AML7-44-1046-7100253 EG&G AUTOMOTIVE
D8EML7-44-1095-7100254 S. COHEN & ASSOCIATES
D8BML7-44-0068-7100256 PACIFIC ENVIRONMENTAL SERV.
D8BML5-44-0087-7100257 RESEARCH & EVAL. ASSOC.
CA
VA
CO
VA
NJ
! VA
MD
VA
VA
VA
VA
VA
VA
DC
VA
CA
VA
NC
MD
KS
MNC
VA
CA
DC
MD
MD
CA
CVA
.VA
MA
MA
TX
TX
TX
VA
VA
NC
4/ 2/97
4/17/97
4/18/97
4/29/97
5/14/97
5/20/97
5/20/97
5/20/97
5/20/97
5/20/97
5/21/97
6/ 2/97
6/ 2/97
6/ 2/97
6/ 2/97
6/ 4/97
6/ 4/97
6/11/97
6/11/97
6/11/97
6/12/97
6/13/97
6/13/97
6/13/97
6/26/97
7/15/97
7/16/97
7/16/97
7/16/97
7/16/97
7/31/97
7/31/97
7/31/97
7/31/97
7/31/97
8/ 1/97
8/ 1/97
8/ 1/97
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
cautions regarding disclosure.
APRIL 1, 1997 THROUGH SEPTEMBER 30, 1997
51
-------
D8BHL4- 44 -0090 -71 00258 RESEARCH & EVAL. ASSOC. NC
D8BML4-44-01 18-7100259 AAMERICAN MANAGEMENT SYSTEMSVA
D8CML7-44- 1146- 7100264 ALLIEDSIGNAL TECHICAL SERV. MD
D8CML7-44-0071 -7100267 TARITAS MI
D8AWL7-44- 1081 -7100269 UMNO-TECH, INC. MI
D8BML4- 44 -0095 -71 00270 TEAM CI 93 OR
D8BML5-44-0063-7100271 PATHOLOGY ASSOCIATES INC. MD
D8AWP7-44-1080-7100272 PARSONS ENGINEERING SCIENCE CA
D8AWL7-44- 1082-7100278 TETRA TECH, INC. VA
D8BML7-44-2010-7100280 DPRA KS
D8BML7-44-001 1-7100281 DPRA KS
D8AML7-44-1126-7100287 DTA TECHNOLOGIES
D8BML7-44-1098-7100298 TECHNICAL RESOURCES INTL MD
D8BWL4-44-0061 -7100299 WOODWARD -CLYDE CONSULTANTS CO
D8BML7-44-0079-7100300 SCIENCE AND POLICY ASSOCIATEDC
D8BMM6-44-0125-7200009 JACA CORPORATION PA
D8BMM7-44-0051-7200015 URIBE CI 94 CA
D8BMM6-44-0087-7200017 DAVID C. COX
D8BMM7-44- 11 41 -7200021 LISBOA ASSOCIATES, INC. DC
D8BMM6-44-0177-7200022 GANNETT FLEMING
D8EMN7-44-0062-7300027 SIERRA FL CA
D8GMP7-44-0016- 7400032 INDUSTRIAL ECONOMICS MA
D8AMP7- 44 -0083 -7400040 FEV ENG TECH MI
D8AMP7-44-0083-7400055 FEV ENG TECH MI
D8AWP7-44-1079-7400060 MARASCO NEWTON GROUP VA
D8GMP7-44-0016-7400063 INDUSTRIAL ECONOMICS MA
D8AWP7-44- 1080-7400064 PARSONS ENGINEERING SCIENCE CA
D8AMP7-44-1 127-7400066 DCT, INC. OK
D8AMP7-44- 1078-7400067 SIERRA RESEARCH INC. CA
TOTAL OF REGION 44 = 67
D8BML7-01 -0022-7100198 MITRE CORP FY95 INCURRED CO MA
D8BMP6-01-0084-7400043 ENVIRONMENTAL HEALTH & ENG. MA
E8AMP7- 0 1 - 0608- 7400035 TRC EN V I RONMENTAL MA
E8CAP3-01 -0061 -7400038 ALLIANCE TECHNOLOGIES CORP MA
E8EMP6-01 -0619- 7400053 TRC - EC BILLING SYSTEM CT
E8EMP6-01 -0619-7400054 TRC - EC BILLING SYSTEM CT
E8EMP6-01 -0634-7400059 TRC FY96 FLOORCHECK MA
E8CAP3-01 -0255-7400062 ALLIANCE TECHNOLOGIES CORP. MA
TOTAL OF REGION 01 = 8
D8BML7-03-0025-7100157 WALCOFF & ASSOCIATES
D8BML5-03-0104-7100161 SOCIOTECHNICAL RESEARCH VA
D8EML7-03-0081 -7100162 S. COHEN & ASSOCIATES VA
D8BML5-03-0380-7100163 ENVIRO-MANAGEMENT & RESEARCHVA
D8CML7-03-0083-7100164 DYNAMAC MD
D8BML6-03-0184-7100165 HAMPSHIRE RESEARCH ASSOC. INCVA
D8BML7-03-01 16-7100166 COMSIS CORPORATION MD
D8BML6-03-0157-7100169 WESTAT
D8BML7-03-0107-7100171 ETS INCORPORATED VA
D8BML3-03-0418-7100172 BOOZ ALLEN HAMILTON MD
D8BML4-03-0467-7100173 BOOZ ALLEN HAMILTON MD
D8AML7-03-0091 -7100179 ROY F. WESTON PA
D8CML6-03-0152-7100180 NUS CORP MD
D8BML4-03-0054-7100182 COMPUTER SCIENCE CORP. VA
D8CBL4-03-0395-7100183 WESTAT, INC. MD
D8BML5-03-0186-7100189 DAVID C. COX VA
D8BML5-03-0187-7100190 DAVID C. COX VA
D8EML5-03-0134-7100210 MANTECH ENVIRONMENTAL TECH. VA
TOTAL OF REGION 03 = 18
D8BML7-05-0085-7100152 COLEJON MECH 94 OH
D8BML7-05-0080-7100191 GRACE ANALYTICAL LAB 95 IL
D8BML7-05-0072-7100196 ENVIRON SCIENCE & ENG 94 IL
D8AAL7-05-0091 -7100211 AUTO TESTING LAB OH
TOTAL OF REGION 05 = 4
D8DML6-07-0037-7100199 MRI MO
D8DML6-07-0037-7100200 MRI MO
8/ 1/97
8/ 5/97
8/ 5/97
8/ 7/97
8/ 7/97
8/ 7/97
8/ 7/97
8/ 7/97
8/25/97
8/25/97
8/25/97
9/10/97
9/25/97
9/25/97
9/25/97
5/28/97
7/16/97
8/ 1/97
8/25/97
9/25/97
4/14/97
4/21/97
5/ 1/97
7/16/97
7/31/97
8/ 7/97
8/ 7/97
9/10/97
9/10/97
5/19/97
5/14/97
it/22/97
4/28/97
7/ 7/97
7/ 7/97
7/24/97
8/ 5/97
4/ 4/97
4/15/97
4/15/97
4/15/97
4/16/97
4/16/97
4/16/97
4/17/97
4/17/97
4/18/97
4/18/97
4/21/97
4/21/97
4/23/97
4/23/97
5/ 1/97
5/ 1/97
5/22/97
4/ 1/97
5/ 8/97
5/15/97
5/27/97
5/19/97
5/19/97
TOTAL OF REGION 07 =
TOTAL OTHER CONTRACT ASSIGNMENTS
99
1,767,032
1,029,074
52
OFFICE OF INSPECTOR GENERAL
-------
9. SUPERFUND CONTRACT ASSIGNMENTS
D9BFL2-44-0401 -71 00156
D9CKL7-44-0015-71 00175
09DJL4-44-0054-71 00176
D9CKL7-44-0014-71 00177
D9BFL6-44-0124-71 00193
D9EFL7-44-1039-71 00208
D9BFL7-44-1053-7100221
D9AKL7-44-0028-71 00222
D9EFL7-44-1061-71 00230
D9AFL7-44-1013-71 00233
D9BGL7- 44 - 0025 - 71 00234
D9EFL7-44-0084-71 00238
D9AFL7-44-1014-71 00239
D9EHL7-44-0096-71 00250
D9EFL7-44- 1094-71 00255
D9GFL7-44- 1 148-71 00260
D9GFL7-44- 1148-71 00261
D9EFL7-44-1023-71 00262
D9GFL7-44-1 147-71 00263
D9BFL7-44-1070-71 00265
D9GFL7-44-1147-71 00268
D9DKL4-44-0078-7100279
D9BFM7-44-011 1-7200010
D9BFM7-44- 1059-7200012
D9BFM7-44- 1058- 7200013
09BFM7-44- 1057- 7200014
D9BJM6-44-0056-7200016
D9BGN7-44-0061 -7300026
D9BGN7-44-0056-7300031
D9AFN7-44-1016-7300034
D9AKP7- 44-0029- 7400050
D9AFP7-44-1015-7400051
D9BKP7-44-0044-7400061
TOTAL OF
E9EGP5-01 -0612-7400065
E9GGP5-01 -0626-7400068
NUS CORP - HALLIBURTON HD
AGEISS ENVIRONMENTAL INC CO
AGEISS ENVIRONMENTAL INC. CO
AGEISS ENVIRONMENTAL INC CO
ENVIRONMENTAL MANAGEMENT SUPMD
MARASCO NEWTON GROUP, LTD. VA
SVERDRUP ENVIRONMENTAL INC MO
HALLIBURTON NUS TX
DPRA KS
S. COHEN & ASSOCIATES, INC. VA
TAMS CONSULTANTS INC. NY
ROY F. UESTON PA
ROY F. WESTON, INC. PA
CITY ENVIRONMENTAL MI
GRIFFIN SERVICES, INC. GA
BECHTEL SYSTEMS & INFRASTRUCCA
BECHTEL SYSTEMS & INFRASTRUCCA
BECHTEL NATIONAL INC. CA
GANNETT FLEMING, INC. PA
BECHTEL NATIONAL INC. CA
GANNETT FLEMING, INC. PA
DPRA, INC.
HYDROGEOLOGIC INC. VA
SVERDRUP CORP MO
SVERDRUP CIVIL INC MO
SVERDRUP ENVIRONMENTAL INC MO
DESA, INC. SC
JACOBS AC 93 CA
JACOBS AC 92 CA
MELE ASSOCIATES, INC. MD
LOCKHEED MARTIN SERVICES TX
ALL AMERICAN ENVIR. SERVICESMD
RUST ENVIRONMENTAL SC
REGION 44 = 33
TRC EDP REVIEW CT
TRC CAS4Q2
4/ 4/97
4/18/97
4/18/97
4/18/97
5/13/97
5/21/97
61 6/97
6/ 9/97
6/13/97
6/16/97
6/18/97
6/26/97
6/26/97
7/31/97
8/ 1/97
8/ 5/97
8/ 5/97
8/ 5/97
8/ 5/97
8/ 5/97
8/ 7/97
8/25/97
5/28/97
6/12/97
6/12/97
6/12/97
7/16/97
4/14/97
5/21/97
6/ 2/97
6/ 9/97
6/16/97
7/31/97
8/22/97
9/17/97
TOTAL OF REGION 01 = 2
D9BGL7-02-0028-7100266 TAMS CONSULTANTS
TOTAL OF REGION 02 = 1
D9BFL6-
D9CFL6-
D9AFL7-
D9BFL6-
D9BFL5-
E9EFL4
E9EFP4-
E9EFP4-
D9BHL6-
E9BHN5
03-0227-7100159
03-0148-7100167
03-0076-7100168
03-0114-7100174
03-0217-7100181
VIAR
ROY f. UESTON
SMITH TECHNOLOGY CORP.
BOOZ ALLEN HAMILTON
CMD FEDERAL PROGRAMS
NY
VA
PA
PA
VA
TOTAL OF REGION 03 =
22-0174-7100289
22-0178-7400041
22-0177-7400047
ICF CONSULTING GRP D/S 12/93
ICF KAISER INTNL HQ DS 12/93
ICF KAI. ENG HO DS 12/93
TOTAL OF REGION 22 =
04-0054-7100160
04-0103-7300040
CMC
UESTINGHOUSE REMEDIATION
TOTAL OF REGION 04 =
E9BKL4'
E9BKL4
E9GKL7-
E9GKL7-
E9BKL6-
05-0135-7100186
05-0137-7100187
05-0095-7100194
05-0097-7100197
05-0119-7100282
PRC EMI 90
PRC EMI 91
PRC EMI CAS 405
PRC EMI CAS 418/410
PRC EMI 92
KY
GA
IL
IL
IL
IL
IL
TOTAL OF
D9BHP7-23-0003-7400056
TOTAL OF
E9BGL6-10-0005-7100291
REGION 05 = 5
SUPERIOR SPECIAL SVRCS ERCS UI
REGION 23 =1
RES-OVERTIME LABOR PROPOSAL OR
8/ 6/97
4/ 8/97
4/16/97
4/17/97
4/18/97
4/22/97
9/17/97
5/ 7/97
5/29/97
4/15/97
9/16/97
4/30/97
4/30/97
5/14/97
5/16/97
8/28/97
7/18/97
9/17/97
APRIL 1, 1997 THROUGH SEPTEMBER 30, 1997
53
-------
E9HGM7-10-0003-7200011 COLBERT LANDFILL CLAIM UA 6/ 6/97
TOTAL OF REGION 10 = 2
TOTAL SUPERFUND CONTRACT ASSIGNMENTS = 54 3,207,042 346,107 0
TOTAL REPORTS =235 21,760,618 19,384,198 17,452,119
54 OFFICE OF INSPECTOR GENERAL
-------
Appendix 2 - Reports Without Management Decision
Reports Issued Without Management Decision - 180 Days Past Report Issue Date
Action Official
Grants Administration Division
Office of Acquisition Management (OAM)
Contract Mgmt. Division RTF
OAM Superfund/RCRA POD
OAM Cost Advisory - CRNSC
OAM Cost Advisory - FASC
Asst Administrator for Air & Radiation
Asst Administrator for Adm & Resources Mgmt
Office of Pollution, Prevention & Toxics
Regional Administrator Region 1
Regional Administrator Region 2
Regional Administrator Region 3
Regional Administrator Region 4
Comptroller Region 5
Regional Administrator Region 6
Regional Administrator Region 8
Regional Administrator Region 9
Regional Administrator Region 10
TOTALS
No Response
Received
7
13
4
6
20
1
0
1
0
1
7
1
0
2
1
4
3
71
Response In Review
Process
1
10
0
4
1
0
3
0
1
1
1
0
0
0
0
2
0
14
Inadequate
Response
1
0
0
2
2
0
0
0
0
0
0
1
0
0
0
0
0
6
Appeal to ARE
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
1
APRIIL1, 1997 THROUGH SEPTEMBER 30, 1997
55
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