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We Recommended That
The Assistant Administrator for
Pesticides and Toxic
Substances'
• Develop a plan for conducting
an awareness program for small
and volunteer fire departments
and commercial building owners
that
 — Assigns specific duties and
responsibilities to Headquarters
and regional personnel,
 — Contains milestone dates,
 — Requires the regions to
monitor the plan's effectiveness
by selectively following up with
targeted entities, and
 — Considers ways to
supplement Agency resources,
such as using fire inspectors to
determine compliance
• Require the regions to use
registration information in
selecting facilities for  inspection

• Issue guidance on
transformer safety features.

What Action Was Taken

In a March 3,  1988,
memorandum, the Assistant
Administrator for Pesticides and
Toxic Substances described
several actions planned by the
Agency that would address our
findings and recommendations
  The final audit report was
issued to the Assistant
Administrator for Pesticides and
Toxic Substances on March  17,
1988 A response to the audit
report is due on June 15, 1988
States in Region 1 Are
Not Enforcing the
Clean Water Act

Problem

EPA Region 1  did not ensure
that States within Region 1
effectively enforced the Clean
Water Act against publicly
owned treatment works
violating their National
Pollutant Discharge
Elimination System permit
conditions.

We Found That
• Enforcement actions taken by
the States in Region 1 were
inadequate or ineffective in
returning municipal violators to
compliance in a timely manner
While States in Region 1 issued
notices of violation and
administrative orders, they did
not aggressively enforce these
actions against major municipal
treatment works  until Federal
grant awards became available
• Region  1 did not take direct
Federal enforcement actions
against polluters when States
failed to carry out their permit
enforcement responsibilities
resulting  in facilities  continuing
to discharge inadequately
treated effluent
• Thirty-seven major facilities in
Region I, discharging 758 million
gallons a day of inadequately
treated effluent, will not meet
the July 1, 1988,  deadline
established by Congress in  the
Clean Water Act to achieve
treatment levels necessary to
protect water quality

We Recommended That
The Regional Administrator,
Region !•
•  Require that States ensure
that publicly owned  treatment
works comply with the
provisions of enforcement
actions,
•  Initiate direct Federal
enforcement against violators
when necessary, and,
•  Consider withdrawal of
enforcement authority and
funding for States that
continually fail to take
appropriate enforcement
actions

What Action Was Taken
In  commenting on our draft
audit report, the Region stated
that it was taking actions that
would address all our concerns
   The final audit report was
issued to the Regional
Administrator, Region I,  on
March 31, 1988  The Region's
response to the audit report is
due by June 29,  1988
Better Enforcement
Against Air Pollution
Violators  Needed in
Region 5

Problem

Air pollution violations in
cities are continuing as EPA
and State officials are not
taking timely action or
assessing high enough
penalties to enforce the
National Ambient Air Qualit
Standards.

Background
EPA enforces State
implementation of the Nation
Ambient Air Quality Standards
by requiring that within 120
days of a significant violation,
the State or region bring the
source into compliance, issue
an enforceable order, or refer
to the State Attorney General
EPA Headquarters for the
possible assessment of
penalties

We Found That
Of 29 cases selected from 12
stationary sources whose
violations placed them on EP
Significant Violators List
• Twenty-three cases,  or 79
percent, were not resolved
within the target 120 days Si
of the cases were unresolved
the time of our review and
exceeded EPA's target
resolution date by over one
year
•  Five cases, or 17 percent,
were  resolved within the targ
120 days The 120-day target
had not expired for one
unresolved case
  Assessment of about $3.3
million in cash penalties againa
13 violators was delayed  Whq
assessments were made, the
Region  was not documenting
and/or correctly calculating the
penalty amount, resulting in
economic benefit to the
violators
 76 million clean up of vaporized dioxins and furans caused by
smoke from an overheated PCB transformer that got into the
 ventilation system and was distributed throughout the New Mexico
 State Highway Building in Santa Fe.

 10

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We Recommended That
The Regional Administrator take
appropriate action to ensure that
cases are resolved within 120
days and that appropriate,
timely penalties are assessed
Region 5 should pursue joint
enforcement action cases with
the States or take the lead for
States that do not have
administrative  penalty authority
  Additionally, we
recommended that calculations
of penalties be fully
documented in accordance with
the Agency's civil penalty policy
so that the penalty recovers the
economic benefit to the
company as a  result of
noncompliance, plus an
additional amount sufficient to
deter future violations

What Action Was Taken
In response to our draft audit
report, the Regional
Administrator agreed to make
every possible effort to properly
address and resolve  cases
within 120 days and render
timely decisions on the
assessment of penalties The
Region will calculate penalties in
accordance with the Agency's
civil penalty policy and
accurately document the work
Our final audit report was
issued to the Regional
Administrator,  Region 5, on
March 11, 1988 A response to
the audit report is due by June
9, 1988
Construction
Grants
EPA's wastewater treatment
works construction grants
program is the largest single
program the Agency
administers Under the
provisions of P L  92-500, as
amended, the Agency is
authorized to make grants
covering 55 percent and, in
some instances,  up to 85
percent of the eligible costs of
constructing wastewater
treatment facilities
  During the first six months of
fiscal 1988, a total of $440
million was obligated on 73 new
grants and 349 increases to
existing grants At midyear,
there were 1,863 active
construction grant projects
representing $12  1 billion in
Federal obligations There were
1,569 projects totaling $9 7
billion in Federal obligations
where construction was
completed and operations
begun; 2,505 projects totaling
$131 billion in Federal
obligations were  in process of
being audited and/or closed out
  Amendments to the
construction grants program are
covered in Title II  of the Water
Quality Act of 1987  Section 212
creates a new Title VI in the
Clean Water Act,  which
addresses the process of
phasing out the construction
grants program by providing
incentives for development of
alternative funding mechanisms
by the States The new Title VI
charges EPA to develop and
implement a program to provide
grants to capitalize State
revolving funds for financing
wastewater treatment projects
  At midyear, EPA has awarded
2 capitalization grants
(Tennessee and Texas), is
reviewing  10 capitalization grant
applications; and expects to
award 9 additional capitalization
grants by fiscal year end
 Problems Prevented
 Completion of the
 Niagara Falls
 Wastewater
 Treatment  Plant for
 15 Years

 Problem

 Design deficiencies, operating
 difficulties and poor
 management of $66 million in
 grants over 15 years delayed
 completion of the Niagara
 Falls wastewater treatment
 works.
 We Found That
 The New York State
 Department of Environmental
 Conservation (NYSDEC) has not
 issued a current State Pollution
 Discharge Elimination System
 (SPDES) permit for the Niagara
 Falls treatment plant  A 1982
 SPDES was overturned in State
 court on a procedural challenge
 By State law, this resulted in
 the previous 1975 permit  being
 the recognized,  enforceable
 permit in effect NYSDEC
 proposed a new SPDES permit
 in 1985 identifying all point
 source discharges from the city
 of Niagara Falls  into the Niagara
 River and incorporating new
treatment standards.  This
propsed permit was later
withdrawn during public
hearings Although the
treatment plant  discharge
currently meets secondary
treatment requirements, the
grantee is in violation of the
Clean Water Act, since the 1975
permit does not cover all of the
city's 16 point source
discharges
  Policy determinations in
evaluating the failure of the
subsequent funding for the
rehabilitation of carbon beds
added to the delay in their
eventual reconstruction This
resulted in the continued
operation of the plant until
mid-1985 as a primary
treatment facility, discharging
pollutants into the Niagara River
in violation of its National
Pollutant Discharge Elimination
System permit
  Design deficiencies and
backlogs in preventive
maintenance contributed to the
plant's operation and
maintenance problems and
costs
  Lack of  proper justification for
noncompetitive procurements,
inadequate advertisements for
bids, and undocumented
selection rationale resulted in $2
million in potentially ineligible
costs. The grantee did not
record costs on a current basis,
submit timely requests for
reimbursement (in some cases
delaying up to three years), or
submit several required final
payment requests As a result,
$2 million  of costs to the city
lacked documentation and may
be ineligible
  EPA is pursuing action in
Federal court against the city for
discharging untreated
                                                                                                                         11

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polluntants from the Falls Street
Tunnel into the Niagara River in
violation of the Clean Water Act


We Recommended That
•  Provide the necessary
technical, policy, and legal
assistance to NYSDEC in
processing the city's draft
SPDES permit so that an
effective permit is adopted
«.  Not award future grants to
the city until it demonstrates
that it can manage them
•  Coordinate with NYSDEC the
city's  attainment of full plant
performance certification
•  Require the city to update its
project ledger to reflect all
current costs
•  Closely monitor and assist
the city in acting to correct and
reduce infiltration into the Falls
Street Tunnel

What Action Was Taken
The final audit report was
issued to the Regional
Administrator, Region 2, on
March 31, 1988 The response
to the audit report is due on
June 29, 1988
Final Construction
Grant Claim Includes
$6.6 Million of
Questioned Costs
City of San Jose, CA
i Audited Costs
Problem

The city of San Jose,
California, claimed $6.6
million of ineligible costs for
the plan, design, and
construction of a wastewater
treatment facility.

We Found That
EPA awarded grants to the city
of San Jose, California, for
upgrading and expanding its
existing treatment facility and
other equipment, and for design
of intermediate improvements
The grantee's final claim
included $6,628,301  of
unallowable costs as follows
•  $4,157,568 received by the
grantee (and not offset against
costs previously funded by  EPA)
as a  result of a settlement with
its design engineers,
•  $2,055,994 for engineering
costs in excess of the approved
engineering subagreement
amount, costs incurred after the
authorized construction
completion date,  costs allocable
to the ineligible portion of the
construction  project, ineligible
repair costs,  and  revenue (not
offset against the project costs)
related to the sale of plans  and
specifications,
•  $262,177 of construction
costs claimed in excess of  the
approved contract amount,  and
•  $152,562 of administrative
costs that were either
unsupported, allocable to
ineligible portions of the
construction project, or
represented  interest earned on
the use of excessive grant
funds

We Recommended That
The  Regional Administrator,
Region 9, determine that EPA
not participate in the  Federal
share of questioned costs of
$5,060,532 and recover the
applicable amount due from the
grantee

What Action Was Taken
The audit report was  issued to
the Regional Administrator,
Region 9, on March 22, 1988 A
response to  the audit report is
due on June 20,  1988
Litigation and
Unsupported Costs
Accounted for $4.7
Million  in Claims by
Detroit
Detroit WSD, Ml
Problem

The city of Detroit, Michigan,
claimed almost $2.6 million of
ineligible settlement and
additional construction costs
from litigation with its sewer
construction contractor. An
additional $2.1  million of
unsupported costs were set
aside.

We Found That
EPA awarded the city of  Detroit,
Michigan, a grant in June 1973
for the construction of the north
intercepter sewer system and
additions to its wastewater
treatment plant totaling $105 7
million  In 1976, the city's
sewer construction contractor
stopped construction with 2,518
linear feet of tunnel and related
work uncompleted  and filed a
lawsuit  alleging that tne city had
breached the contract  The city
subsequently negotiated  a
settlement with the contractor
that provided for dismissal of
the lawsuit and completion of
the project  The city claimed
$2,593,503 of costs associated
with the settlement that  were
ineligible because they were
outside  the project's scope,
were not approved  in advance
by EPA, and were incurred
because of the grantee's failure
to make timely progress
payments to the construction
contractor These ineligible
costs included
•  $1,493,503 of construction
costs claimed over and above
the original contract amount to
complete the remaining work,
and
•  $1,100,000 of additional costs
to settle all of the contractor's
claims arising out of the work
shutdown
  In addition, we set aside
$2,075,706 of claims pending
EPA's evaluations consisting o

• $1,883,467 of force account
costs for engineering services
incurred after the accepted
contract completion dates,
• $118,500 of construction
costs for spare parts included i
one construction contract, and
• $73,739 of unsupported cos
for settlements of
subcontractors' claims

We recommend That
The Chief, Grants and Financia
Management Branch, Region
• Determine that EPA not
participate in the Federal share
of the questioned costs
($1,945,127),
• Determine whether EPA
should participate in the Feder
share  of the set-aside costs
($1,556,780),  and
• Recover  the applicable
amounts due  from the grantee

What Action Was Taken
The audit report was issued to
the Chief, Grants and Financial
Management Branch, Region 5
on January 20, 1988 As of Ap
27, 1988, we had not received
response to the report that wa
due April 19, 1988
Ineligible and
Set-Aside Costs
Exceeded $1.5 Million
on Richmond, Virginia
Project
City of Richmond, VA
                                                               Millions of Delia's
                                                               Problem

                                                               The city of Richmond,
                                                               Virginia, claimed $584,885 Of
                                                               ineligible architectural and
                                                               construction costs that were
                                                               outside the contract's period
                                                               of performance, had not yet
 12

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been paid to the construction
contractor, or were
miscalculated. An  additional
$941,359 of costs were set
aside.

We Found That
EPA awarded three grants
totaling $30 5 million to the city
of Richmond, Virginia, for plans
and specifications and the
construction of diversion
conduits, a retention basin, and
a control building We
questioned $584,885 of costs
consisting primarily of
• $325,138 of architectural
engineering basic fees claimed
after the approved construction
completion date and in excess
of the amount allowed by EPA
regulations, and
• $234,010 of construction and
proiect improvement costs
claimed by the contractor
because of an unresolved
dispute, and costs incurred for
work outside the construction
contract's scope  or period of
performane
  In addition, we set aside
$941,359 of  claims  by the
grantee for (1) architectural
engineering fees  and
construction and  project
improvement costs primarily for
work under a change order that
EPA had determined to be
ineligible, (2) costs that were in
litigation, and (3)  costs paid to
the consulting engineer for
as-built drawings  pending
documentation to show the
drawings, benefit to the project

We Recommend That
The Regional Administrator,
Region 3
•  Determine that EPA not
participate in  the  Federal share
of questioned costs ($438,664),
•  Determine whether  EPA
should participate in the Federal
share of set-aside costs
($706,019),  and
•  Recover the applicable
amount due from the grantee

What Action Was  Taken
The audit report was issued to
the Regional Administrator,
Region 3, on January 29, 1988
A response to the audit report
due on April 28,  1988,  had not
been received by that date
Grantee Claimed
Almost $1.7 Million of
Ineligible and
Unsupported  Costs
 Western Monmouth UA, NJ
 Audited Costs
Problem

The Western Monmouth
Utilities Authority, New
Jersey, claimed over $730,000
of ineligible costs for
construction of an advanced
wastewater treatment facility.
Additionally, almost $1
million of unsupported costs
were claimed.

We Found That
EPA awarded grants totaling
$16,128,858 to the Western
Monmouth Utilities Authority,
New Jersey, for the
construction of interceptor
sewers, a pump  station, and
force main, and the upgrading
of an existing secondary
wastewater treatment facility to
a tertiary facility  The grantee
claimed $732,820 of ineligible
costs including
• $419,609 for construction
costs previously disallowed by
EPA and the New Jersey
Department of Environmental
Protection,  including costs for
an administration building that
was outside the grant's scope,
costs incurred under numerous
change orders, and costs for
ineligible shop tools and
equipment,
• $295,209 of architectural
engineering fees, including fees
in excess of EPA's eligible limit,
costs claimed for extra work
due to default by the contractor
for interceptor sewers, fees for
design and  modification of the
treatment plant's plans and
specifications for future
nitrification  facilities, and costs
associated with  making grant
applications and applying for
various permits, and
•  $18,002 of administrative
costs, including costs for
appealing EPA's denial of  a
grant for another treatment
facility and ineligible project
inspection fees
   In addition, we set aside
$960,005 of architectural
engineering  fees, preliminary
engineering  costs,
administrative expenses, and
inspection fees not supported
by adequate documentation,
incurred outside the grant
agreement period, or incurred
without a written agreement

We Recommended That
The  Regional Administrator,
Region 2, determine that EPA
not participate in the Federal
share of the questioned costs
($549,615), determine the
eligibility of Federal share  of the
set-aside costs  ($720,003), and
recover the applicable amount
from the grantee

What Action Was Taken
The audit report was issued to
the Regional Administrator,
Region 2, on December 28,
1987 As of April 27, 1988, we
had not received a response to
the report which was due on
March 28, 1988
Grantee Claims Over
Half Million  Dollars for
Facility That Was
Never Built
Rush-Ryan Sewer Auth, PA
 Audited Costs
                     I   JNnnFpH

                     ^•Federal
Problem

The Rush-Ryan Joint Sewer
Authority, Tamaqua,
Pennsylvania, claimed
$544,556 of ineligible
architectural/engineering fees.
Construction was never
started, and the grant was
terminated.
We Found That
EPA awarded Rush-Ryan Joint
Sewer Authority three grants
plus supplemental grant funding
that totaled $3,742,362 (Federal
share)  Grant 1 and the
supplemental funding provided
for the preparation of a facility
plan Grant 2 provided for the
preparation of construction
drawings and specifications, and
Grant 3 provided for the
construction of two secondary
treatment plants, interceptors,
and pump stations
  EPA terminated grant 3
because the grantee had not
complied with an EPA regulation
that requires the grantee to
meet the completion schedule
specified in the  grant agreement
and initiate construction not
later than 18 months after the
award of the grant
  EPA regulations also specify
that costs are allowable only to
the extent of benefits
attributable to the project
  We have questioned all the
engineering design and redesign
costs claimed under grants 2
and 3,  since no  construction
ever took place  and the ultimate
water pollution abatement
objectives were not  met.

We Recommended That
The Regional Administrator,
Region 3, determine that  EPA
not participate in the Federal
share of engineering costs
questioned ($406,077)

What Action Was Taken
The audit report was issued to
the Regional Administrator,
Region 3, on January 19,  1988
As of April 27, 1988, we had
not received a response to the
report that was  due April  18,
1988
                                                                                                                         13

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Superfund
Program
The Superfund program was
created by the Comprehensive
Environmental Response,
Compensation, and Liability Act
of 1980 (CERCLA)  The act
provided a $1 6 billion trust fund
for removal and remedial
actions, liability, compensation,
cleanup, and emergency
response for hazardous
substances released into  the
environment and uncontrolled
and abandoned waste sites
Taxing authority for the trust
fund expired on September 30,
1985 For more than a  year, the
Superfund program operated at
a reduced level from carryover
funds and temporary funds
provided by Congress
   On October 17, 1986, the
Superfund Amendments and
Reauthorization Act of  1986
(SARA) was enacted It provides
$8 5 billion to continue the
program for 5 more years and
makes many programmatic
changes
   The parties responsible  for
the hazardous substances are
liable for cleaning up the site
themselves or reimbursing the
Government for doing so
States in  which there is a
release of hazardous materials
are required to pay 10 percent
of the costs of fund-financed
remedial actions,  or 50 percent
if the source of the hazard was
operated by the State or local
government
   The enactment of SARA has
increased the audit
requirements for the Inspector
General In addition to providing
a much larger and more
complex program for which the
OIG needs to provide audit
coverage,  SARA gave the IG a
number of specific
responsibilities Mandatory
Superfund annual audit areas
include
• Audit of all payments,
obligations, reimbursements, or
other uses of the fund,
• Audit of Superfund claims,
• Examination of a sample of
agreements with States carrying
out response actions, and
• Examination of remedial
investigations and feasibility
studies prepared for  remedial
actions
  The Inspector General is
required to submit to the
Congress an annual IG  report
regarding the  mandated
Superfund annual audit work
described above, containing
such recommendations as the
IG deems appropriate The first
IG annual report, will be issued
in September 1988
  In addition,  the EPA
Administrator is  required to
submit a detailed Agency annual
report to the Congress  on
January 1 (starting in 1988) of
each year on the Agency's
Superfund progress achieved
during the preceding fiscal year
The OIG is required to review
the Agency's  report for
reasonableness  and accuracy
and the Agency  is required to
attach the results of  the OIG its
review to the Agency's annual
report  As of March 31, 1988,
the Agency's annual  Superfund
report to Congress was still in
draft
EPA Makes Needed
Improvements to
Manage Superfund
Cooperative
Agreements

Problem

Work under $136.3 million of
Superfund cooperative
agreements was not
effectively performed by the
recipients or monitored by
EPA regional offices.
Performance objectives were
often not attained, and
priority work was
substantially behind schedule
at some of the most serious
hazardous waste sites.

Background
During fiscal years 1985 through
1987, the OIG issued 33 audit
reports to 9 of the 10 EPA
regional offices on Superfund
cooperative agreements in 20
states and management of  the
agreements in 4 EPA regions
Recognizing the seriousness of
the issues raised in the
individual audit reports, Agency
administrative and program
offices joined together to
address the problems  We
summarized recurring problems
identified in the audits and
recommended national actions
or policy changes to alleviate
the problems

We Found That
•  Environmental objectives
were not achieved because
information to select sites for
the National  Priorities List was
not provided, performance of
prehstmg and remedial planning
activities was substantially
delayed, community
involvement was not at planned
levels,  and sampling and testing
programs needed improvement

•  Performance on all remedial
investigations and feasibility
studies we reviewed was
untimely and ineffective,
delaying cleanup of sites with
significant hazards
•  Preliminary assessments
were not completed within
established schedules, site
inspections were not always
accomplished in accordance
with EPA requirements, and the
hazard ranking system (MRS)
process was not consistently
followed
• Regions did not effectively
perform their oversight
responsibilities  We found a lac
of sufficient training and
guidance for remedial project
managers, failure to
aggressively assure the
completion of required work,
poor communication of
Superfund requirements to the
States, and inadequate
documentation of cooperative
agreement files
• States did not comply with
procurement requirements for
free and open competition,
adequate cost and price
considerations, adequate public
notice of competitive
procurements, EPA standard
clauses in contracts, and
references to applicable Federa
cost principles Still, many of
the State agencies had certifie
that their procurement systems
met EPA regulatory
requirements
• The regional offices did not
have procedures assuring that
the State agencies had
adequate financial  management
systems Some State agencies
had unacceptable timekeeping
and labor-charging practices an
failed  to maintain their
accounting systems in
accordance with EPA
regulations
• States and  regions  were not
adhering to letter-of-credit
payment or reporting
procedures Drawdowns were
not timely or calculated
properly, regional reviews were
not adequate, and  in one region
staff changed certified financial
reports without written
notification to the State agency
submitting them
• State agencies did not
comply with  reporting
procedures nor did regions
adequately monitor their
compliance EPA management
was not adequately apprised of
technical and financial progress
• Management of personal
property and equipment
purchased with Superfund
money did not meet Federal
requirements  Property was not
always recorded in the
recipient's property
management records, some
14

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items could not be located, and
lost or stolen items were not
reported to EPA

We Recommended That
The Assistant Administrator for
Solid Waste and Emergency
Response  review the MRS
scoring quality assurance
process to ascertain what
additional controls are needed.
All other recommendations in
the draft report were adequately
addressed by EPA before
issuance of the final report

What Action Was Taken
In response to Agency concerns
and its analysis of the individual
reports and our draft "capping"
report, the Agency had initiated
or scheduled action fully
addressing most our findings'
•  Management Assistance
Program (MAP) reviews of State
management systems.
•  Preparation of a revised
"Guide for Preparing and
Reviewing Superfund
Cooperative Agreements" and
development of a companion
guide for State use
•  Development of training
courses in Superfund
procurement and cooperative
agreement administration
•  Implementation of a core
cooperative agreement program
to help States improve their
Superfund management
•  Strengthening technical
assistance to States by moving
regional ass/stance
administration units into the
lead in directing administrative
oversight of cooperative
agreements, while remedial
project managers focus on
compliance with the National
Contingency Plan
•  Development of a Superfund
assistance regulation, effective
October 1,  1988
•  Development of a Superfund
administrative management
system to  automate the tracking
of corrective actions,
cooperative agreement audits,
regional oversight reviews, and
MAP reviews
•  Development of EPA/State
Superfund memorandums of
agreement clearly delineating
roles and responsibilities of
each agency for CERCLA
response activities
• Preparation and distribution of
"State Superfund Financial
Management and
Recordkeepmg Guidance " and
training of regional and State
personnel in this area.
• Issuance of a Comptroller's
policy announcement to
reemphasize letter-of-credit
requirements and implement
additional reconciliation controls.

• Review and provide guidance
on reporting requirements
• Naming of contacts,  at the
time of cooperative agreement
award, for administrative
management, finance, and
technical program questions,
establishment of systems for
tracking compliance with special
conditions
• Review of property
management procedures
leading to development of a
property management policy
manual
  The final audit report was
issued March 29, 1988, to the
Assistant Administrators for
Administration and Resources
Management and for Solid
Waste and Emergency
Response. A response to  the
audit report is due June 27,
1988.
More Improvements
Are Needed To
Ensure Accurate
Superfund Accounting


Problem
Although Agency guidance on
accounting for Superfund
costs has significantly
improved, further
improvements are needed to
ensure accurate accounting
for property management,
cost allocations, receivables,
obligations, disbursements,
and personnel compensation.
We Found That
Numerous weaknesses existed
in property controls  For
example
• 140 items purchased in fiscal
1986, costing about  $736,000,
were not recorded in the
personal property accounting
system
•  103 sampled items, valued at
about $252,000, that were
selected for physical inspection
could not be located.
  A significant procedural
weakness contributing to these
deficiencies was the lack of
Agency policies and procedures
requiring the reconciliation of
property and equipment
purchases recorded in the
financial management system
with items entered into the
personal property accounting
system.
  We also found that the
Agency's procedures for
allocating general support
services costs to Superfund
were not clearly defined At
Headquarters, disbursements
were allocated improperly, at
Region 3,  general support
services cost allocations were
overstated because an  incorrect
personnel ratio was used In
addition, the Superfund program
was not always charged its
proportionate share of support
services costs due to cost and
personnel ceilings  As a result,
distribution of support services
costs between Superfund and
EPA's other programs was
inaccurate
  Additionally, we  found that
amounts due Superfund from
cost recovery decrees and State
cost-sharing agreements were
not being  recorded timely  This
occurred because various EPA
offices failed to properly
coordinate and communicate
cost recovery decrees and
agreements as required by
existing Agency guidance This
precluded  the Agency from
adequately managing
receivables and collections and
could result in a material
amount of lost interest
  While we accepted the
majority of fiscal 1986 recorded
obligations of $393,272,582 and
disbursements of $416,685,493,
a statistical analysis of key
internal control and compliance
attributes disclosed a higher
than expected error rate of
nofTpayroll obligations,
nonpayroll disbursements, and
personnel  compensation
transactions This could result in
unauthorized or misstated
obligations being recorded,
improper or duplicate
disbursements, and misstated
personnel compensation costs

We Recommended That
The Acting Assistant
Administrator for Administration
and Resources Management
•  Establish policies and
procedures requiring (1)
reconciliation  of the personal
property account in the financial
management  system with
property recorded in the
personal property accounting
system and (2) annual  physical
inventories
•  Clarify cost allocation
procedures and ensure that
appropriate adjustments are
made to reflect proper
allocations.
•  Require cost settlement
documents and State
cost-sharing agreements be
forwarded immediately to  the
appropriate finance office
•  Reconcile receivables with
the Office of Waste Program
Enforcement's case
management  system to ensure
that all settlement documents
are recorded

What Action Was Taken
The final audit report was
issued to the Acting Assistant
Administrator for Administration
and Resources Management on
October 7, 1987  On January
15, 1988, the  Acting Assistant
Administrator provided a status
report on corrective actions that
were underway when we
issued the draft audit report,
and responses to the final audit
report's recommendations The
status report and the response
indicated that the Assistant
Administrator implemented our
Recommendations
  As part of our audit of EPA's
fiscal 1987 portion of the
hazardous substance Superfund,
we will follow up on these
findings and recommendations
to  determine the  adequacy of
the corrective actions
implemented
                                                                                                                        15

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Special And
Prospective
Reviews
This is a new section in our
semiannual report describing
sigificant and potentional
findings, deficiencies, and
recommendations which have
been identified through
evaluations, analyses, protects
and audits These projects are
intended to nelp Agency
managers correct problems and
recognize the potential for
savings before  resources are
fully committed

Special Reviews

Special reviews are narrowly
focused studies of programs or
activities providing management
a timely, informative
•ndependent  picture of
operations Special reviews are
not statistical research studies
or detailed audits Rather, thev
are information gathering
studies that seek to identify
issue areas for top management
attention
  Philadelphia's ash being readied for shipment
Plan to Ship
Philadelphia Municipal
Incinerator Ash to
Panama Halted

Problem

Philadelphia's municipal
incinerator ash—planned for
use as a road subbase
through an environmentally
sensitive wetlands in
Panama—contained dioxin,
lead, and cadmium.

We Found That
The city of Philadelphia planned
to export  up to 250,000 tons of
incinerator ash to Panama,
where it was to be used as a
road bed through a wetlands
The ash presented a  significant
potential danger  to human
health and the environment due
to high concentrations of dioxin
Samples of the ash have also
been shown to contain levels of
lead and cadmium which
occasionally exceeded
hazardous waste thresholds, as
well as a wide array of other
heavy metals and toxic
chemicals  significant amounts
of these substances in the ash
would have very hkelv washed
directly into the wetlands and
aquatic environments, possibly
damaging or killing aquatic life
and entering the human  food
chain
  Even though most municipal
incinerator ash is not currently
regulated by EPA because it is
not  classified as a hazardous
waste, we recommended EPA
involvement At the time of the
report, negotiations between
the  shipper of Philadelphia's ash
and Panama were at a standstill
pending U S assurances that
the  ash would not cause harm
in Panama

We Recommended That
EPA ensure that the most
complete,  current analyses of
the  ash be provided to the
appropriate Panamanian  officials
so a fully informed decision
would be made regarding
acceptance and use of the ash

What Action  Was Taken
We issued a special review
flash report to the Deputy
Administrator  of EPA on
Octobers, 1987
  The Deputy Administrator
responded that Philadelphia's
incinerator operations did not
present a current danger to
human health or the
environment in Philadelphia am
that tests previously performec
on the municipal ash from the
Philadelphia incinerator showec
it to be a nor/hazardous waste
not subject to EPA regulation
Even so, EPA agreed, upon
request, to provide any
accepting country with a/I
available data on the ash and,
the extent possible, technical
assistance
16

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Construction Grant
Early Warning System
77?/s relatively new program is
designed to identify potent/a/
problem construction projects
early in their life cycle so that
EPA management can take
appropriate corrective action
  The long range goal of the
construction  grants program is
to reduce the discharge of
municipal wastewater pollutants
to improve water quality and
protect public health EPA
provides grants to municipal
agencies to assist in financing
the construction of wastewater
treatment works, which may
take from 2 to TO years
  Because audits are generally
performed after the project is
complete, problems which
affect the efficient design,
construction, management, or
operation of a treatment plant
are  not disclosed until
thousands or millions of dollars
are  spent  The OIG early
warning system reviews
projects before construction
begins to identify problems and
preclude the ineffective
expenditure of funds Our
reviews focus on certain
indicators and attributes that
can suggest  the likelihood of a
potential problem  Three early
warning reports  completed
during this semiannual period
are  described below
Grantee Proposes
Building Unneeded
Wastewater
Treatment  Project

Problem

The San Jacinto Mountain
Area Water Study Agency
proposed a $14 million
increase in an existing grant
for the expansion of
wastewater treatment
facilities to serve only a small
number  of residents whose
water  quality was already
acceptable.

Background
The grantee was awarded a
facilities planning grant to study
the need for sewers in the area
of Idyllwild County, Pine  Cove
County, and Fern Valley water
districts of California On
September 30, 1981, the
grantee was awarded a
$2,106,450 follow-on grant for
the design and construction of a
wastewater collection system
and the expansion of the
treatment and disposal facilities
On July 15, 1987, the grantee
submitted an  application  to
amend the project to
approximately $14 million,
however.  Region 9 had not
approved the  amendment at the
time of our review

We Found That
The grantee has not
demonstrated that the proposed
project represented the most
cost-effective alternative. The
bases for the  original grant
award and the need to improve
the water quality were
inadequately documented or
unsupported  Our engineers,
performing a technical review,
further found  that the water
quality  in the affected area
meets  the water quality
standards of the State of
California's basin plan
  In our prior  interim audit, we
recommended that Region 9
define the intended scope of
the project to be funded  under
the grant  The Region stated
that the scope of the project
remained the  same as
described in the 1983 concept
approval letter However, since
a 1980 cost-effectiveness study
and the concept's 1983
approval,  the proposed project's
scope has increased in size,
capacity, and cost without a
commensurate
cost-effectiveness analysis of all
viable alternatives Instead, only
a value engineering study of the
selected alternative was
performed leading to the $14
million proposal, servicing only
1,526 households

We Recommended That
The Acting Regional
Administrator, Region 9, take
actions to
•  Reexamme the proposed size
and necessity for this project
based on possible health
hazards,  water quality, or other
factors and terminate the grant
if it is not clearly justified
•  Require an analysis of cost
effectiveness based on the
actual, viable alternatives that
could solve possible health or
water quality problems of the
community  Additionally, the
Region should evaluate the
reasonableness of the  user
charges for the currently
proposed project

What Action Was Taken

The construction  grant early
warning review report was
issued on February 25, 1988 As
of April 27, 7988, we had not
received a response to the
report which was due on March
31, 1988. Howeer, on April 1,
1988, Region 9 stated that it
was transmitting  the report to
the delgated State Agency for
comment.
$8 Million  in Proposed
Grants For Ocean
Monitoring Vessels
Should Not Be
Awarded

Problem

The city of Los Angeles and
the Los Angeles County
Sanitation District proposed
grants totaling $8 million to
purchase ocean monitoring
vessels that would not be an
efficient use of Federal, State,
and local funds.

We Found That
The proposed purchase of
ocean monitoring vessels by the
municipalities did not qualify for
EPA funding because the city's
vessel would not be used  solely
under the construction grant
program and specific ocean
monitoring  requirements have
not been established for the
county's vessels In  addition,
our review  of the California
State Water Resources Control
Board's evaluation of the
funding requests disclosed that
the Board failed to (1) fully
explore  the possibility of
consolidating the city's and
county's requests to avoid
duplicative  requirements, (2)
document whether it was  more
economical to upgrade the
municipalities' existing vessels,
and (3) support its conclusion
that the grants could be
grandfathered in at the higher
75 percent  Federal funding level
versus the current lower level of
matching Federal funds
Responding to our inquiries,  the
Board determined not to fund
the municipalities' requests for
ocean monitoring vessels
However, the State agency's
determination left open the
possibility of future funding of
these vessels

We Recommended That
The Regional Administrator,
Region 9
• Deny the city and county
requests for funding of the
ocean monitoring vessels under
the EPA Construction Grant
Program
• Ensure that municipalities
adequately  document the need
and cost effectiveness of their
proposed projects
                                                                                                                        17

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                                                                      Section   2—
• Adequately document the
basis for allowing grantees to
grandfather their grants at the
higher 75 percent Federal
funding share

What Action Was Taken
The early warning review report
was issued on March 29, 1988
A response to the early warning
review is due on May 2, 1988
Grantee's Request for
a  $13.5 Million Plant
Expansion to  Service
190 Eligible Dwelling
Units Needs Further
Review

Problem

The Valley Center  Municipal
Water District, California,
proposed a $13.5 million
wastewater treatment plant
expansion  to serve only 190
dwelling units. The proposed
high cost may exceed the
grantee's ability to fund its
share of the project.

We Found  That
A $7 4 million grant was hastily
awarded without the normal
review for a project of this size
so that it could qualify for 75
percent Federal funding
Although design has been
completed, construction has not
started on the expansion of the
wastewater treatment facility
that is estimated to cost
approximately $135 million.  The
project report included inflated
and unsupported data on the
actual number of discharges to
be serviced and did not address
cost-effective alternative
solutions
   If at least 80 percent,
or 278, of the existing 348
dischargers do not agree to  be
connected  (a  special condition
of the grant award), the grantee
will be in default of the grant
Currently, only 190 of the  348
existing dischargers have
contracted  to hook up to the
proposed system, at an average
cost of $71,000 each
  The project appears to
promote and stimulate
development instead of
eliminating a potential health
hazard  Local land developers
owning large undeveloped
parcels of land may realize a
financial bonanza from this
project which could eventually
provide sewerage service for
the undeveloped lots  As a
result, we question whether
spending $13 5 million to
service a small number of
existing dwellings is an efficient
use of tax dollars, particularly
since many owners of
undeveloped properties will
realize huge windfall profits

We Recommended That
The Regional Administrator,
Region 9'
•  Evaluate the grantee's ability
to pay its share of the costs
•  Assess the cost effectiveness
of the proposed  project in view
of its potentially high capital
costs for existing users
•  Determine the likelihood  of
the grantee complying with the
special grant condition relating
to number of unit connections
•  Ensure that the  costs of
developers will not be borne by
EPA

What Action Was Taken

The construction grant early
warning review report was
issued on March 30, 1988 A
response is due  on May 3,
1988
As required by the Inspector
General Act, this section
describes significant problems
identified in previous
semiannual reports which
remain unresolved. Also, as
required by the Supplemental
Appropriations and Rescission
Acts of 1980 and 1981, this
section includes a summary
of unresolved audit reports
and a list of officials
responsible for resolving audit
findings over 6 months old.
Overdue Audit
Resolutions Remain
Low

Once again, EPA management
and the Office of Inspector
General report a decrease in the
level of overdue audit
resolutions during the past 6
months  Overdue resolutions as
of March 31, 1988,  totaled
25—down from  the 35 reported
at the end of fiscal  1987  Dunne
the first half of fiscal 1988, the'
Office of Inspector  General
issued 915 new audit reports
and closed 1,010, with 356
audit reports remaining in  the
Agency followup system for
resolution during the next  six
months
  Of the  audits closed, $37 3
million of questioned costs
were sustained,  including  $33 4
million to be recovered and $3
million in cost efficiencies  In
addition, cost recoveries from
current and prior periods
included $3 3 million in cash
collections and at least $104
million in offsets against billings
  As we  discussed  in our  last
report, EPA had  formed a  task
force to develop quality training
materials and an approach for al
managers to help them improv
their audit management skills
and the performance of their
programs. This effort is called
"Strengthening the  Audit
Management Ability of EPA
Managers "
  Products in their  final stages
of development  to improve the
audit manage- ment process
include an early  warning system
to alert management to critical
audit findings, a  centralized
automated audit tracking
system to monitor corrective
actions, a "how to" handbook
on being audited, and
videotaped training  for both
appointed officials and career
managers
  The task force plans to
complete these  products in
June. EPA will hold a national
conference to promote the
handbook, early warning
network, and audit  tracking
system and schedule training
dates to  show the videos  and
distribute the materials
throughout the regional and
Headquarters offices
 18

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Previously Reported
Items—Corrective
Actions Not Taken
The Inspector General Act
requires that each semiannual
report identify unresolved audits
discussed in previous reports  In
all previous reports 162 audit
reports were discussed, 155
have been resolved  The seven
audit reports listed below had
not been resolved as of March
31,1988
Audit
Number
60091
70972
71265
71266
71358
71992
71985
Grantee/Contractor
Baltimore, Maryland
EPA Region 9 RCRA Consent
Agrmt
Upper Occoquan, Virginia
Upper Occoquan, Virginia
Ahso Water Mgmt Agency, CA
Region 8 SF Coop Agreement
Kauai County, Hawai
Issue Date
1 0/24/85
03/31/87
06/02/87
06/02/87
06/16/87
09/30/87
09/29/87
Status*
Incomplete
Response
No Response
No Response
No Response
No Response
No Response*
No Response
"Incomplete audit responses open 90 days or more past report date will be handled as
a nonresponse in accordance with EPA Directive 2750, "Management of EPA Audit
Reports and Follow-up Actions " All of the reports under this category would be
considered nonresponse
Resolution of Significant Audits from Prior Periods
Midit       Number            Grantee         Federal Share'
Report Date                                   Questioned
                           Costs
                        Sustained
                      for Recovery
                           Stockton, CA    $18,357,974 $18,357,974
                           Garland, TX
             864,533     864,533
                           Abmgton Township,  887,276     887,276
                           PA
                           North Haledon, NJ   531,542
                           Fairfield, NJ
             436,872
06/25/87  S2CW6090075-
         71424
09/27/85  E2CW4060103-
         51573
08/31/87  P2CW6030064-
         71807
06/26/87  P2CW5020216-
         71437
06/26/87  P2CW5020225-
         71436
04/17/87  P2CW6020020-     Tonawanda, NY     415,019
         71069
"Federal share questioned increased up to the amount of costs sustained for recovery
in those cases where costs sustained for  recovery exceeded Federal share questioned
and were the result of action taken on Federal share set aside
Action Officials for Audit Reports Outstanding More Than Six
Months as of March 31, 1988                         -5 =  1
                                                      =.2  fc
                        523,309
436,872
                                                       414,341
Action Official
                                                sg
                                               -Scco
                      11  58
                      
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      Section  3—Prosecutive  Actions
The following is a summary
of investigative activities
during this reporting period.
These include investigations
of alleged criminal violations
which may result in
prosecution and conviction,
investigations of alleged
violations of Agency
regulations and policies, and
OIG personnel security
investigations. The Office  of
Investigations tracks
investigations in  the following
categories: preliminary and
regular investigations, joint
investigations with other
agencies, and OIG
background investigations.
Summary Of
Investigative
Activity
During this period, we closed
139 investigations At the same
time, we continued emphasizing
long-term, major-impact
initiatives and improving the
quality of investigative work

Pending Investigations
as of September 30, 1987 216

New Investigations
Opened This Period        124

Investigations Closed
This Period               139

Pending Investigations
as of March 31, 1988     201
                                                            Prosecutive and
                                                            Administrative
                                                            Actions
                                                            In this period investigative
                                                            efforts resulted in 9 indictments
                                                            and 9 convictions Fines and
                                                            recoveries amounted to
                                                            $798,398 including civil actions
                                                            A total of 17* administrative
                                                            actions were taken as a result
                                                            of investigations

                                                            Resignations               1

                                                            Reprimands/Admonishments 10
                                                            Other                     6
                                                            *Does not include suspensions and
                                                            debarments resulting from Office of
                                                            Investigations activities or actions resulting
                                                            from reviews of personnel security
                                                            investigations
            Profile of Pending Active
            Investigations by Type
                                     Procurement Fraud 22  10 9%
                              Profile of Pending Active
                              Investigations by EPA Office
                              Unit

                             Solid Waste 40  199%.

                             Toxics 8 4 0%
                                                Program Fraud/
                                                Other 52  25 9%
                                                                                             nf & Compl/Regional 3  1 5%
                                                                                                    Air 34  169%
                                                                        Research 9 4 5%


                                                                      Other/MuIti Prog 9 4 5°/

                                                                   Administration 13  6 5%


                                                              Personnel Security 3  1 5%
 20
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Description  Of
Selected
Prosecutive
Actions
Below is a brief description of
some of the prosecutive actions
which occurred during the
reporting period  Some of these
actions resulted from
investigations :nitiated before
October 7, ^987
Twenty-Five Arrested
in New York Asbestos
Bribery Case

"wenty-five asbestos removal
contractors in the metropolitan
New York City area were
arrested and  charged January 5,
'988, with bribing an EPA
'nspector
  The arrest  complaints charged
that the bribes were paid to
mduce the inspector to overlook:
violations of Federal rules and
regulations with regard to
asbestos removal conducted by
the defendants, and to stay
away from job sites being
worked by their companies The
bribes occurred between 1983
and 1987, and totaled more than
$170,000  The largest  single
bribe was $25,000 The
defendants represented 22
companies, both local  and
national, which perform the
ma|onty of asbestos removal
and disposal  in New York, New
Jersey, and Long  Island.
  Subseguently, on February 3,
1988, six bribery indictments
were returned against nine
individuals from six of  the
asbestos companies Action on
additional indictments  is in
process
  The arrests and subsequent
indictments are the result of a
continuing investigation being
conducted by the  Department
of Labor's Office of Labor
Racketeering, with special
assistance provided by the  EPA
Office of Inspector General
  EPA regulations require that
specific work practices be used
during demolition and
renovation of structures
involving asbestos these
practices minimize the potential
exposure of workers and the
general public in the vicinity of
the project to asbestos fibers
resulting from removal and
disposal operations Asbestos is
a toxic substance regulated
through the Clean Air Act
Impersonation of
Federal Officer

  Aleiandnno Santino Ramos
•A/as mdicted on March  18,
 i988, on charges of mail'fraud,
false personation of a Federal
employee, and  imoroper use of
Government seals to defraud
A/ater Wise, me , a supplier of
water purification equipment
and supplies, and the Federal
Government Ramos, working
for National Environmental
Protection Services, Lafayette,
Louisiana, mailed an order to
purchase some water distillation
equipment from Water  Wise
inc , for delivery on open
account; in so doing, he
represented himself as  an agent
of the U S Environmental
Protection Agency Ramos
further communicated that he
would provide Water Wise with
a General Services
Administration purchase order
number authorizing payment for
the  products by the  U S
Government Based on  these
false representations, Water
Wise shipped equipment and
accessories valued at $1,077 to
Ramos  In addition, Ramos
further communicated with
Water Wise through the U S
mail using a personal business
card and stationery bearing the
seal of the U S  Environmental
Protection Agency
Two  New Haven,
Connecticut,
Policemen  Plead
Guilty to Fraud and
Conspiracy Charges

Two New Haven, Connecticut
patrol officers, Thomas
Nuterangelo and Joseph Savino,
pleaded guilty on December 17
and December  10, 1987,
respectively  Nuterangelo
admitted making false, fictitious,
or fraudulent claims and aiding
and abetting, Savino admitting
making a  fraudulent demand
against the United States
Nuterangelo was sentenced on
January 22, 1988, to one year
.mprisonment ;suspenaed), 'we
years of probation, payment of
$1,750  restitution, and the
performance of 500 hours of
community service
  As a  result of an investigation
conducted by the EPA OIG and
the Internal Affairs Division of
the New Haven Police
Department,  indictments had
previously been returned on
March  10, 1987, against four
New Haven,  policemen ana a
former  construction company
employee for conspiracy and
submission of false  claims  for
payment to the U S EPA in
connection with the EPA-funded
Boulevard/East Street sewage
treatment improvement proiect
m New Haven The  officers
were charged at that time with
submitting fraudulent claims for
extra-duty pay on work not
performed at the site, i e ,
on-site  traffic control
responsibilities
Company President
Sentenced for Selling
Defective Products,
Excluded for Life
From Doing Business
with Federal
Government

Alan Blane Grant, president of
Polymer Chemicals, Inc , of
Atlanta, Georgia, was sentenced
on November 5, 1987, to a
five-year suspended prison
term, six months in a halfway
nouse at his own expense, and
^ $10,000 fine
  Additionally, Grant, along with
several coconspirators entered a
.ifetime settlement agreement
for voluntary exclusion from
doing grout- related business
through their or any other
names on any federally funded
programs or projects This
action, ,/vhich was accepted  by
the court and made part  of the
sentence, is the first lifetime
exclusion  of a person or  firm
from doing business with the
Federal Government resulting
from an investigation by  EPA's
Office of inspector General
  Grant and his company
pleaded guilty on September 24,
1987, to conspiring to defraud
the United States by selling
underweight bags of chemical
grout to sewer contractors and
making false statements on
U S Government forms
regarding  the origin of the grout
From 1981 to 1987, Polymer
Chemicals was  in the business
of mixing  and selling Chem G-9
acryiamide grout, a
waterproofing sealant for sewer
                                                            Underweight bags of Chem-9
                                                                                                                     21
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lines. Investigation revealed that
Polymer Chemicals short
weighted bags of Chem G-9
grout used by contractors on
EPA and other federally funded
sewer rehabilitation projects,
thereby risking compromise of
the sealant's effectiveness
under certain conditions.
  Polymer Chemicals also
falsely represented to EPA,
Department of Defense, and
other contracting officials, as
well as insurance earners, that it
was an importer, warehouser,
distributor, wholesaler, and
reshipper of Chem G-9 grout
manufactured in England
Actually, Polymer Chemicals
imported the chemical
components and mixed them in
the United States to create  the
grout
Inspector and
Company President
Indicted Again

Ronald R. Connelly, president of
REO Construction Company,
and Marlon L. Robinson,
inspector with McClendon
Engineering Company, were
remdicted on charges of
conspiracy, false statements,
and aiding and abetting on
December 18, 1987, following
their August 24, 1987,
indictment for making false
statements These indictments
charged Connelly with
submitting claims for over 100
repairs that were not performed
under a $1,184,000 EPA-funded
sewer rehabilitation grant for
testing, repairing, and replacing
sewer lines in Shubuta,
Mississippi Robinson was
charged with falsely stating that
he inspected and found that
sewer lines had been repaired
or replaced according to
specifications
Manager of EPA
Contractor Convicted
and Sentenced
Robert Allen, field manager of Y
& M Steel Contractors, Inc.,
was given a three-year
suspended sentence, three
years probation, ordered to

22
undergo counseling, and
ordered to file an amended tax
return with the Internal Revenue
Service within 60 days of the
Januar/8, 1988, sentencing.
The defendant, Allen,  pleaded
guilty on November 20, 1987, to
fraudulent use of a Social
Security number to add fictitious
employees to the payrolls
claimed on an EPA-funded
construction  project in
Westwood, Massachusetts
Illegal Gray Market
Cars and Emissions
Labs

Since our last semiannual
report, we continued working
jointly with Federal and State
agencies investigating "gray
market" auto dealers and
emissions modifications and
testing facilities who illegally
sell, modify, or test imported
cars that have been falsely
certified to meet Federal
standards  Gray market auto
dealers import cars to the
United States, modify them to
meet U S  safety and  EPA
emission standards, and resell
them for far less than U S
franchised dealers  The problem
concerning EPA is that many
conversions of gray market cars
do not meet emission
standards  The OIG is
concerned with modifiers and
certifiers of gray market cars
who  submit or induce others to
submit false statements to EPA
claiming that such cars meet
these standards  Examples of
schemes to defraud EPA follow
Major Air Emission
Test Lab and Its
President Sentenced

Import Certification Laboratory,
Inc (ICL), Orange, California,
which tested air emissions for
imported gray market cars, was
fined $50,000; its president,
Andrew G.  Krum, was fined
$50,000, sentenced to one year
imprisonment, and placed on
five additional years probation.
Twenty-three other employees
received sentences ranging
from six months imprisonment,
$2,500 fines, four years
probation, and 200 hours of
community service, to $100
fines and one year probation
  These sentences were
imposed on November 9, 1987,
after the company pleaded
guilty to five  counts of false
statements and Mr Krumm
pleaded guilty to one count of
conspiracy and one count of
submitting false statements  In
addition, six other defendants
previously entered guilty pleas
for felony violations and 17
remaining defendants previously
entered guilty pleas for
misdemeanor violations
  ICL cheated on its testing
procedures and falsified and
fabricated test results to EPA on
gray market cars including
Ferraris, Rolls-Royces,
Mercedes-Benzes, Porsches,
and BMWs.
Corporate President
Convicted for
Falsifying  Emissions
Tests

Emission Engineering, Inc  (EEI),
Huntmgton Beach, California, a
major laboratory testing
emissions on imported cars for
compliance with environmental
emission standards, and its
president, Vernon Lindholm,
were indicted  on August 27,
1987, for conspiring to submit
false and fabricated test data to
EPA. The false statements
consisted of certifications for
about 1,000 cars stating that the
cars were successfully tested
by EEI, under  Federal test
procedures, and met EPA
emission standards. Many  of
these cars had pollution  control
equipment installed at EEI
before they were tested at
EEl's laboratory  Most of the
cars certified by EEI were
foreign makes, including Ferrari,
Rolls Royce, Mercedes-Benz,
Porsche, and BMW.  EEI
generally charged importers and
dealers several thousand dollars
for each car they modified and
certified. Vernon Lindholm was
convicted on December 2,
1987, of conspiring with other
employees of EEI to defraud
EPA by submitting false test
results for hundreds  of cars
tested by EEI  between 1984
and 1986. Many of these cars
were not tested using Federal
procedures, and EEI employee:
at Lindholm's direction,
fabricated and falsified test
results and supporting records
for submission to EPA
Conviction and
Sentencing of  Import
Firm

CVN. Companies, (CVN) Inc,
of North Plymouth, Minnesota
pleaded guilty on November 11
1987, to making false
statements to illegally import
cars which violated the
emissions standards of the
Clean Air Act  CVN was charg
with  a direct marketing by mail
scheme to import 48 Land
Rovers and avoid meeting EP
pollution control requirements
on those  cars. CVN was fined
$5,025 on December 17, 1987
  Stuart Liben, owner of CVN,
was  fined $1,000 and
sentenced to three years
probation on May 8,  1987, for
aiding and abetting in
connection with the
above-mentioned scheme
Car Dealer, Wife, and
Firm Indicted for Gra
Market Car Scheme

Car dealer Jerry Glenn Hocutt,
his wife Judith, and their firm,
Metal Building Systems, also
doing business as Luxury Auto
International, were indicted on
February 23, 1988  The
defendants were charged with
allegedly importing 26 luxury
vehicles for resale that evaded
EPA emission  standards by
making false statements that
the cars were  purchased by
individuals  EPA provides for a
one-time exclusion from the
emission standards for foreign
cars that are five or more yean
old and are certified as being
imported for private use only
   The indictments,
accompanied by arrest warrant
charged the defendants with
conspiring to make false
statements, making forged or
counterfeit writings, and aiding
and abetting to import goods
 into the United States.
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Description Of
Selected
Prosecutive And
Administrative
Actions
Concerning EPA
Employees
The OIG investigates and
reports information, allegations,
and indications of possible
wrongdoing or misconduct by
EPA employees and persons or
firms acting in an official
capacity directly with EPA or
through its grantees In edition,
the Senate Report of the
Supplemental Appropriations
and Rescission Act of  1980
states that appropriate
administrative action is
expected to be taken in cases
where employees have acted
improperly
  Selected administrative
actions taken against EPA
employees as a result  of OIG
investigations are shown below
Former EPA
Purchasing Agent
Violates Probation
and  Is  Imprisoned

As reported in previous
semiannual reports, James
Richard Crossgrove, a former
purchasing agent with EPA, Gulf
Breeze, Florida, was convicted
for creating his own supply
company under his
stepdaughter's name from
which he used his official
capacity to purchase almost
$40,000 worth of materials for
EPA
  Mr  Crossgrove was fined
$3,000, sentenced to a
suspended prison term, and
placed on five years probation
on August 8, 1986 However,
on November 5,  1987, a
judgment and
probation/commitment order,
citing  violations of his probation,
revoked his previous  probation
and sentenced him to 15
months imprisonment
Civil And
Administrative
Actions To
Recover EPA
Funds
Investigations and audits
performed 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 (OGC), the OIG uses a
variety of tools to obtain
restitution  These include
cooperative efforts with the
Department of Justice in filing
civil suits under the False
Claims Act 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 determent
actions
  The tools available for
recovering funds fraudulently
obtained from the Agency have
been enhanced by the
enactment of the Program
Fraud Civil Remedies Act That
statute provides an
administrative remedy for
smaller false claims and false
statements in connection with
claims  Through the Inspector
General Division, the OIG
provided leadership in the
mteragency effort to develop
model regulations to implement
the act  That model has now
been adapted for use by EPA;
publication of final regulations is
imminent.
  Civil and administrative
actions to recover funds usually
extend over several semiannual
reporting periods  What follows
is a brief description of the
progress being made during this
semiannual reporting period
EPA Receives
$600,000 from
Chattanooga's Bid
Rigging  Suit

The city of Chattanooga paid
EPA $532,000 from the proceeds
of its settlements of an antitrust
suit against several contractors
who rigged  bids on EPA-funded
sewer projects in Chattanooga
The city will pay EPA about
$100,000 more as it receives
future payments from those
contractors  EPA received these
payments pursuant to an
agreement with Chattanooga
signed on October 27, 1987
  Chattanooga settled its
ambitious antitrust suit against
McDowell, CFW, Alman, Cash,
and other construction
contractors  for approximately $4
million between 1984 and 1987
The city agreed to share its
recoveries with EPA because
EPA contributed about 35
percent of the cost of the
rigged contracts
  Chattanooga's suit was
initially based on John Bruff
Wilson's conviction for
conspiring to rig the bid on the
$6 million Hixson  intercepter
contract on  behalf of one of the
contractors. During the course
of its litigation, Chattanooga
uncovered evidence of bid
rigging on a number of other
contracts as well
  The Inspector General
Division of the Office of General
Counsel praised the spirit of
cooperation between EPA and
Chattanooga Instead of
squabbling over the division of
the proceeds, which would have
only benefited the bid riggers,
Chattanooga and EPA worked
together to  obtain the greatest
recovery from bid riggers while
maximizing  deterrence The
approach of allowing a grantee
to take the lead role in bid
rigging litigation after agreeing
to a formula for splitting the
proceeds with EPA is a new
weapon  in EPA's war on bid
riggers
                                                                                                                    23
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   S0Ction  4 —Fraud  Prevention  and Resource Management  Improvemen
This section describes several
activities of the Office of
Inspector General to promote
economy and efficiency and
to prevent and detect fraud,
waste, and abuse in the
administration of EPA
programs and operations.
This section includes
information required  by
statute, recommended by
Senate report, or deemed
appropriate by the Inspector
General.
Review Of
Proposed
Legislation And
Regulations
Section 4(a)(2> of the Inspector
General Act of 1978 specifies
that it is the duty and
responsibility of the Office of
Inspector General to review
existing and proposed legislation
and regulations relating to
programs and operations
concerning their impact on
economy and efficiency or the
prevention and detection of
fraud and abuse  We reviewed
75 items for this semiannual
reporting period, 48 legislative
and 27 regulatory  Major
comments are discussed in the
sections that follow
Proposed
Amendments to the
Inspector General Act
of 1978

The Inspector General Act of
1978 (P L  95-452) created an
Office of Inspector General at
EPA and several other
departments and agencies to
consolidate existing
investigative and audit
resources into an independent
organization headed by the
Inspector General
  The Senate has passed an
amending act (S. 908) which
would establish new  IG offices
in several agencies; provide for
uniform IG salaries, specify the
authority vested in the Treasury
IG, establish internal audit units
in certain Federal entities and
clarify the authority of such
units,  specify the content of IG
reports, and change some
administrative provisions It
would also provide oath
administration authority to
investigators assigned to IG
staffs
  During this reporting period,
we commented on the House
version of the amendment
proposal (H  R  4054)
• Section 4(a)(6) calls for listing
"unsupported costs"  found in
audits  We disagreed with using
this term, as defined  in the
legislation, because it does not
include all the benefits we
recognize under the term
"set-aside costs " For example,
we have frequently identified
underutilized, unused, or
inoperable facilities
Management's typical response
is to get the facilities working
This type of finding and
corrective action would not
appear in the listing called for in
this section, nor would cost
efficiencies  or cost savings,
which might be substantial
• Section 4(a)(8) and 4(a)(10)
would establish reporting
requirements on audits for
which a determination has  not
been made  six  months after
issuance, and for significant
audits where the Inspector
General and the Agency are in
disagreement on the
determination  We agree in
principle with these
requirements,  however, we
believe that the Agency should
be required to furnish to the 1C
information regarding the
reasons for any significant
revised audit determinations
The IG would then include this
information in the semiannual
report to Congress

• Section 4(b) would require
semiannual listings of audits n
resolved within one year The
listing would include an
explanation of cause, the
amount of disallowed costs in
dispute, and the amount of
disallowed costs returned or
offset by the Government W
concur in this requirement bu
believe this information shoul
be submitted in time for
inclusion in the semiannual
report
• Section 5 would provide
oath-administration authority t
IG employees. We strongly
support this section, as it will
provide the necessary tools f
the performance of efficient a
effective investigations
                                                                                          Comprehensive
                                                                                          Federal Law
                                                                                          Enforcement
                                                                                          Improvements Act o
                                                                                          1987
                                                                                          We reviewed Senate Bill 1975
                                                                                          "Comprehensive Law
                                                                                          Enforcement Improvements A
                                                                                          of I987 " The bill would amen
                                                                                          the Inspector General Act of
                                                                                          I978 to authorize investigators
                                                                                          of the agency Inspectors
                                                                                          General to obtain and serve
                                                                                          subpoenas and summonses,
                                                                                          obtain and execute search  and
                                                                                          arrest warrants, carry firearms
                                                                                          and make arrests for felonies
                                                                                          misdemeanors,  if the latter ar
                                                                                          committed in the presence of
                                                                                          the investigator We  support  th
                                                                                          mtent of S.1975 but believe th,
                                                                                          it does not go far enough in
                                                                                          providing the IG offices with  th
                                                                                          full extent of needed law
                                                                                          enforcement authority
                                                                                            Specifically, we  suggest that
                                                                                          section  103  be amended to gi\.
                                                                                          Inspectors General of
                                                                                          independent agencies, such as
                                                                                          EPA, the authority to admmiste
                                                                                          oaths in the  course of
                                                                                          investigations
                                                                                            We objected to  sections 10E
                                                                                          through 108, which would
24
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 provide the Comptroller General
 A/ith explicit authority to
 nvestigate criminal violations
 Phis authority would include
 ssumg subpoenas, carrying
 irearms,  and administering
 Daths and affirmations Our
 :oncern is that because law
 snforcement authority is an
 Executive Branch function, this
 smpowerment of the
 Comptroller General may
 epresent a breach in the
 separation of powers between
 he legislative and executive
 tranches
  We strongly supported the
 concept of a National Advisory
 Commission on Law
 Enforcement, also contained in
 S  1975 The commission would
 De established for a six month
 Deriod to study the methods
 and  rates of compensation of
 :ederal law enforcement
 officers
 :ederal Financial
 /lanagement
 mprovement Act of
  987
  We supported the concept
 md objectives of a draft bill
 rom the Comptroller General
 sntitled the "Federal Financial
 vlanagement Improvement Act
 )f 1987 " The bill calls for
 seating a Chief Financial Officer
 )f the United States,  requiring
 sach agency and the
 3overnment as a whole to
 Jevelop corporate-type financial
 statements,  requiring annual
 audits of such statements,  and
 sstablishing independent agency
 ;ontrollers to conduct,
 supervise, and coordinate all
 mancial management activities
  Specifically, we  said that  a
 Zhief Financial Officer would
 Drovide the needed focus to
 develop the framework  and
 strategic plan for improving
 mancial management in
government  A single authority
on financial management policy
could reduce conflicting
interpretations at the agency
level
  We backed the requirement
for financial statements
Agencies of the Federal
Government should be required
to produce accurate financial
information concerning their
operations Such information
should clearly show the sources
of funding and how these
resources were used to
accomplish the purposes for
which they were appropriated or
otherwise made available.
  While we said that audits of
these financial statements
would be of substantial value,
we also stated that the
Inspectors General are not
staffed to perform  such annual
audits, and requiring them to do
so would deny them the
freedom to choose the most
cost-effective audit subjects
  We agreed with  the concept
of establishing independent
agency controllers  to conduct,
supervise, and coordinate all
financial management activities
and operations of an agency and
be  responsible for  preparing the
anuual agency financial
statements We believe that the
legislation should clearly affirm
the controller's independence to
implement the improved
financial management initiatives
established by the  Chief
Financial Officer, and grant the
authority to report serious
noncompliance to the Chief
Financial Officer and in the
annual report to Congress
  We also stated that the
legislation should clearly state
that only the Inspector General
of each agency has the
authority to determine how the
annual audits would be
performed
Hatch Act
Amendments

We opposed this legislation,
H R  3400, which would expand
the rights of Federal employees
to participate in political
activities
  Permitting Government
employees to engage in partisan
political activity could result in
subtle forms of coercion
Specifically, civil servants may
feel, or actually be, pressured
by superiors into political
conformity to ensure
advancement of their careers In
addition. Government
employees would create
self-imposed pressure in
recognition of the advantages of
political partisanship when
competing for  promotions and
job vacancies
  Enactment of this bill could
have a particularly severe
impact on IG offices Audit and
investigative personnel must
function as impartial factfmders
to retain their credibility If the
public or news media
representatives believe or
perceive that our audits or
investigations are affected in
any way by political
considerations, we would be
unable to fulfill the basic
purpose for which our offices
were created
  In addition, if IG employees
are  able to actively engage in
partisan political activity,
situations would arise in which
accusations  of conflict of
interest could flourish  Also,
H R  3400 does not  provide
sufficient safeguards to prevent
political coercion from becoming
a reality for auditors and
investigators
  In sum, we believe that the
current Hatch Act strikes an
appropriate balance between a
Federal worker's ability to
participate in partisan politics
and the public's right to an
objective Federal workforce free
from political influence, and
should not be changed
Federal Employees
Liability Reform and
Tort Compensation
Act of 1988

A recent Supreme Court
decision (Westfall v  Ervm)
severely restricted the scope of
the judicially created doctrine of
common law immunity for
Federal employees  It is our
opinion that this legislation,
drafted by the Department  of
Justice,  provides a proper
balance  between a Federal
worker's right to protection
from personal liability for
common law torts committed
within his scope of
employment, and the right  of a
victim of these torts to
appropriate compensation from
the United States
  However, we believe that the
protection offered Federal
employees from personal
liability should not extend to
cases of willful gross personal
negligence or willful, vindictive,
defaming, or injurious personal
conduct beyond the explicit
authority of the office
Computer Matching
and Privacy Protection
Act

We reviewed a House of
Representatives version of
S 496, the Computer Matching
and Privacy Protection  Act of
1987 The intent of the
legislation is to ensure privacy,
integrity, and verification of data
disclosed for computer
matching, and to establish Data
Integrity Boards within Federal
agencies
  We expressed our concern
that several  portions of the act
could compromise the
independence of the Inspectors
General For example,  section 4
of the draft bill requires that the
IG be a member of each
agency's Data Integrity Board,
which would review and
approve all agency matching
agreements  with other
agencies Since these  matches
could at some later date be the
subject of an IG audit or
investigation, it is inappropriate
for the IG  to be a member of
this board
  Another section of the
legislation requires that a
cost-benefit  analysis be
conducted of any proposed
matching program to
demonstrate that it is cost
effective Many IG efforts
involve reviews of compliance
with laws, policies, and
regulations, and might involve
computer  matching  It  is
inappropriate that the Inspector
General be required  to seek
Data Integrity Board approval for
such matching We suggested
that the legislation be changed
to exclude computer matches
performed by the Office of
Inspector General
Telephone Monitoring
Protection Act
We do not support H R 1950,
the Telephone Monitoring
Protection Act, which would
require that telephone
monitoring by employers be
accompanied by a regular
audible warning tone  We feel
                                                                                                                         25
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that such a requirement should
recognize that certain instances,
such as consensual monitoring,
court orders, law enforcement,
and public service may
necessitate exceptions, and that
the legislation should be revised
to establish these exemptions
GSA Draft Bill to Test
a Commercial Charge
Card Payment System

This proposed legislation from
the General Services
Administration would allow GSA
to use a charge card for a
two-year test period to pay for
fueling and repair services for
its 100,000 vehicles  The
legislation would allow for
payment of invoices upon
receipt, without prior
certification The Government
would recover any payments
stemming from unauthorized
purchases directly from
employees after reconciliation of
charges
  We ob|ected to this
legislation  We do not believe
that the precedent should be
established for a Government
agency to assume liability for
the unauthorized acts of its
employees  Further, in light of
the expectation that the rate of
unauthorized purchases would
be less than one-half of one
percent, GSA's inability to
assume liability for these
purchases would  not appear to
warrant legislative relief
GSA Draft Bill on
Certification of
Telephone Bills
We supported GSA's draft
legislation that would repeal 31
USC 1348(b), a I939 statute that
requires agency heads to certify
long-distance telephone  bills
We agree with GSA that the
expanded use of computerized
switching equipment has
provided  more cost-effective
ways to control  long-distance
telephone costs, such as
automatic route selection, which
transfers calls from the
commercial network to the
more economical FTS intercity
network, and exception
reporting The latter will allow
agencies to verify a sample of
calls placed from the FTS
intercity network
Construction Manual

We reviewed a revision of the
Agency's construction manual
and suggested that security
requirements be considered in
every request for buildings and
facilities projects in excess of
$25,000 We also suggested
that a procedure be established
to ensure a review of the
Agency's Suspension and
Debarment list before the award
of any contract
Suspension And
Debarment
Activities
EPA's policy is to do business
only with contractors and
grantees who are honest and
responsible, and who comply
with applicable rules and
regulations  EPA enforces this
policy by suspending or
debarring organizations or
persons who have acted
improperly,  have a history of
substandard work, or have
willfully failed  to perform on
contracts funded by EPA (or in
some cases contracts that are
funded by other Federal
agencies) The convicted felon
is by far the most frequent
subject of an EPA debarment
Suspensions, debarments, and
voluntary exclusions deny
participation in Agency
programs and activities to those
who represent a risk of cheating
the Government Such actions
aid in  preventing our tax dollars
from being  given to dishonest
or nonresponsible contractors
and grantees
  The EPA  Grants
Administration Division operates
the suspension and debarment
program in  EPA  Acting by
Agency request or by its own
authority, the OIG conducts
audits, investigations, and
engineering studies,  obtains
documents, and  provides
information  and evidence used
in determining whether there is
a cause for suspension or
debarment
  A summary of suspension
and debarment activities for this
reporting  period is shown on
the chart  below

	Period
Cases Opened             42
Cases Completed
Debarments               27
Voluntary exclusions         1
Settlement agreements      20
Closed after investigation    62
                               Total
                         110

                   Active Cases
                   as of 3/31/88
Under investigation         87
Under program
or counsel review         234
Proposed for debarment     21
Suspended or
suspended and proposed
for debarment              22
Total
364
Actions To
Exclude Persons
Or Firms
• James Electric Company, Inc ,
of  Huntmgton, West Virginia,
was debarred for three years
beginning on December 12,
1987, following conviction for
bid rigging on an  EPA-funded
construction project in
Huntmgton, West Virginia
• Herbst Electric Co of Cleveland,
Ohio, was debarred for three
years beginning on February 24,
1988, following conviction for
bid rigging on a General Electric
construction project in Brook
Park, Ohio
• Darrell A Duisen  of San Diego,
California, was debarred for
three years beginning on
October 16,  1987, following his
conviction for making false
statements to Customs officials
The false statements related to
the illegal transportation and
disposal of hazardous wastes in
Mexico
• Eight inspectors for the Ne\A
York City Department of
Environmental Protection were
debarred for three years,
beginning in November 1988,
following their conviction for
various offenses that related tc
the unlawful use of their officu
positions to issue certificates
inspection for sewer projects i
exchange for cash bribes from
contractors The inspectors
were Frank and Ralph Bortugn
Jack Schilhzzi, and Rene
Morales of  Bronx,  New York,
Lawrence O'Mara  of Hicksvill
New York,  Nick DeLuca of
Staten Island,  New York,
Vincent  Carreccia of
Farmmgdale, New York, and
Nandlal Jethani of Williston
Park, New York
• Joseph L DiLiberto of Fairl
Hills, Pennsylvania, was
debarred from December 12,
1987, until July 15, 1988
DiLiberto was an  employee of
Litton Systems, Inc , which is
headquartered in  Beverly Hills
California  DiLiberto's
debarment followed his
conviction for conspiring to
obtain monies from the
Department of Defense by
presenting documents
containing false and fraudulen
representations about a Litton
contract with the Department
Defense
•  Robert Cummins and Jame
Payne of Enid, Oklahoma, we
debarred beginning on
December 2,  1987 Mr
Cummins' debarment will end
on June 3,  1988,  and Mr
Payne's will end on October 1
1988 Their debarments
followed the conviction  of
Cummins Construction Co ,  In
for bid rigging on road
construction projects in  the
State of Oklahoma The
debarred individuals were
officials of Cummins
Construction Co ,  Inc
• Seven companies and two
individuals were debarred for
life on November  2, 1987 The
debarred companies, all of
Atlanta, Georgia,  are Polymer
Chemicals, Inc , Polymer Grou
Ltd., Polymer Industries, Inc ,
X-Chem, Inc ; G B Industries;
Gredig Industries, Inc, and
 26
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 Gametromcs,  Inc The
 individuals are Alan Blane Grant
 and Cynthia A Sheldon, also of
 Atlanta The debarments were
 voluntarily accepted as part of a
 settlement agreement  They
 followed guilty pleas by Alan
 Blane Grant and Polymer
 Chemicals, Inc , to charges of
 conspiring to defraud the
 Government on sewer
 rehabilitation projects  All of the
 debarred companies were
 controlled  by  Grant and/or
 Sheldon
 • Hummel Engineering
 Corporation of Philadelphia,
 Pennsylvania,  was debarred for
 three years beginning on March
 31,  1988, following conviction
 for bid rigging on construction
 projects for the Atlantic
 Richfield Company  (ARCO) in
 Philadelphia
 • Sikes Concrete Pipe Company
 of Panama City, Florida, was
 debarred for 30 days following
 conviction of conspiring to fix
 the  price of ready-mix concrete
 in the State of Florida
 • As was  reported  in our report
 for the period ending on
 September 30, 1987, two
 project foremen for Gates and
 Fox, Ltd , of Loomis, California,
 were debarred based on their
 conviction for giving false
 statements in connection with
 work on an EPA-funded project
 at Corning, California, for which
 Gates and Fox was the prime
 contractor On March 31, 1988,
 William B  Kruse, a project
 manager/superintendent at
 Gates and Fox, Ltd , voluntarily
 excluded  himself from
 participating on any EPA-funded
 project for a period of six
 months He had been under
 suspension at EPA  since July
 1987  The voluntary exclusion
 followed an agreement between
 Kruse and  the Justice
 Department for a deferred
 prosecution relative to  Kruse's
 role in the violations on the
 Corning project
 • J  N Futia Company of Albany,
\New York, was to be awarded
 an EPA-funded contract on
 Monday, March 14, 1988  Since
 the company had recently been
 convicted of filing false claims,
 making false statements to the
 Government, mail fraud, and
 aiding and  abetting, and Joseph
 N Futia, Jr, the corporate vice
president, had been convicted
of misdemeanor violations
relative to the same set of
facts, EPA's Grants
Administration Division
processed a suspension action
on March 11, 1988, which
prevented the award of the
contract to the Futia Company
• EPA Region 5 and Kenny
Construction  Company, the
largest contractor on the
Chicago Metropolitan Sanitary
District's billion dollar Tunnel
and Reservoir Project (TARP),
entered into an innovative and
precedent-setting
debarment/suspension
settlement agreement on
February 25,  1988 Following
the indictment of  Kenny on
charges of violating
Occupational  Safety and  Health
Administration (OSHA)
workplace safety standards (in
particular, failure to monitor
underground  air quality levels,
leading to the suffocation death
of a construction worker), EPA
proposed a suspension and
debarment action against
Kenny As a result, Kenny
entered into a settlement
agreement requiring it to
implement detailed worker
safety procedures for its
existing projects as well as for
any future EPA-funded contract
it may be awarded The
settlement agreement, as the
first of its kind and in the  tough
standards imposed, represents
a creative and aggressive  use of
the debarment and suspension
authority by EPA
• EPA Region 5 also developed
and entered into a
memorandum of understanding
with OSHA Region 5 The
agreement, signed by the two
Regional  Administrators,
provides for a greater exchange
of information between the two
agencies and  increased
coordination to improve the
oversight of job-site safety and
reduce the potential of
accidents on  EPA-funded
construction projects
Employee And
Public Awareness
A continuing priority of the
Office of Inspector General is to
enhance its presence among
EPA employees, grantees, firms
participating in EPA programs,
and the public In this process,
we are trying to make these
groups aware of their
responsibility to prevent, detect,
and report instances of  fraud,
waste, and abuse We have
found that while most EPA
employees, grantees, and
contractors are conscientious
about the economy, efficiency,
and effectiveness of their work,
they have little knowledge about
the DIG  These groups are often
in the best position to detect,
prevent, and report fraud,
waste, and abuse if they know
how to identify and report it
  We have used a variety of
mediums to provide information
and encourage participation by
specific segments of the
concerned population In
addition,  OIG-developed
publications, videotapes, and
training in fraud detection
prepare every project or
program  manager to identify
and report suspected indicators
of fraud that may have
otherwise gone unnoticed

Semiannual Report
Over 1,500 copies of our
semiannual report to Congress
for the period ending
September 30, 1987, were
distributed to employees,
citizens, news services, the
Army Corps of Engineers, State
agencies administering EPA
programs, selected
environmental associations, and
EPA libraries We have also
expanded our distribution  of
semiannual reports to all
members of EPA-concerned
committees in both houses of
Congress  The distribution of
these reports to news services
resulted in the publication of
articles concerning the DIG and
increased interest by the public
We are particularly interested in
getting State agencies and
grantees more involved  in the
prevention and detection of
 wasteful or fraudulent activities
 and have distributed this
 semiannual report to all State
 attorney general offices along
 with letters requesting referrals
 of persons or firms that have
 been convicted or debarred for
 consideration of debarment by
 EPA The EPA Office of Public
 Affairs has helped us identify
 interested audiences and
 distribute the semiannual
 reports to those groups.

 Presentations to Management
 and Associations
 The Inspector General, Deputy
 Inspector General, and other
 OIG managers have participated
 in a vigorous schedule of
 presentations and briefings to
 EPA management in
 Headquarters and in the field  In
 addition, presentations have
 been made to grantees,
 professional and governmental
 associations, State and local
 government officials, and
 educational institutions

 EPA OIG Represents U.S. at
 Anticorruption Conference in
 Hong Hong
 John C  Martin,  Inspector
 General, and  John E Barden,
 Assistant Inspector  General for
 Investigations, represented the
 United States with
 presentations at the third
 international anticorruption
 conference sponsored by the
 Independent  Commission
 Against Corruption (ICAC) in
 Hong Kong, China, November
 2-6, 1987
  The presentations by Martin
 and Barden about the  Inspector
 General concept, simultaneously
 interpreted in several languages,
 created a great deal of
 enthusiasm in representatives
 from 32 countries, many of
 whom were interested in  using
 the Inspector General Act as a
 model for improving their
 government's ability to fight
 corruption
  Other presentation highlights
 included  an EPA OIG exhibit at
 the International Association  of
 Chiefs of Police in Canada, a
 presentation by John E Barden
 at the Hazardous Waste
 Conference in  Denver, Colorado,
 and presentations by OIG  staff
 members at a Suspension and
 Debarment Conference in Las
Vegas, Nevada
                                                                                                                           27
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New Hotline Poster
During this semiannual reporting
period we designed  and
distributed 200 new OIG Hotline
posters to all  EPA facilities An
example of this new design is
printed on the back cover of this
report. We hope that by
periodically updating the  look
and distribution of the Hotline
poster, EPA employees and
on-site contractors will be
encouraged to call the OIG
Hotline when they suspect any
possible fraud, waste, or abuse

IG Highlights of Fiscal 1987
A digest version of our two
semiannual reports to Congress
for fiscal 1987 was produced
and distributed to  all EPA
employees in November 1987
IG Highlights  provides
information about  statutory
duties, authorities, and
independent status of the Office
of Inspector General It presents
a summary of significant
activities of the Office of
Inspector General, including
problems,  deficiencies,
recommendations, and
prosecutive and administrative
actions reported to EPA
management  and  Congress IG
Highlights  includes an
organizational chart of the Office
of Inspector General along with
telephone  numbers of the
Divisional Inspectors General
and the OIG  Hotline

EPA Celebrates Second
Annual "OIG Week"
PA's Office of Inspector  General
celebrated its eighth anniversary
by holding its second annual
"OIG Week"  from February 9 to
13, 1988 The purpose of OIG
Week was to stimulate interest
in the mission of the OIG in
EPA employees and managers
through the theme of "working
together to promote efficiency,
effectiveness, and integrity in
EPA "
  OIG  Week  began  on Monday,
February 9, with a reception for
EPA Administrator Lee Thomas
and top EPA officials hosted by
Inspector General John Martin
and key OIG staff During the
reception, both John Martin and
Lee Thomas addressed the
more  than 100 persons in
attendance on the importance
of teamwork  between the OIG
 Kitty belle Rivera, Assitant Regional Counsel, Region 4, receiving
 "OIG Recognition Award "
and Agency management to
carry out EPA's mission  Also at
the reception, three EPA
managers were presented the
"Office of Inspector General
Recognition Award" for their
work exemplifying teamwork
between Agency management
and the  OIG to promote
efficiency, effectiveness, and
integrity in EPA They were
Pasquale (Pat) A Albenco,
Deputy Director, Compliance
and Program Operations, Office
of Enforcement and Compliance
Monitoring, Kittybelle Rivera,
Assistant Regional Counsel,
Region 4, and, Harold W
Hopkins, Chief,  Facilities
Construction Branch, Water
Management Division, Region 4
  Other activities of OIG Week
included an OIG exhibit on
Tuesday, Wednesday, and
Thursday in the commercial  area
of Waterside Mall The exhibit
included copies of OIG
publications, a graphic display
and a continuous showing of
several videotapes on EPA's
OIG, the PCIE  videotape "A
Force for Sound Government",
and a tape of John  Martin's
presentation of testimony
before the Senate Committee
on Environment and Public
Works OIG Week concluded
with a luncheon on Friday,
February 13, 1987,  for OIG
staff  During the luncheon, John
Martin summarized the
accomplishments of the OIG
and presented awards to
several OIG employees for their
work on the OIG Human
Resources Council  OIG Week
was also celebrated in our field
offices by the showing of "A
Force for Sound Government,"
to EPA regional employees and
management
  The OIG Week concept is
designed to increase the
awareness of the OIG mission
in EPA By recognizing the work
of Agency management to
improve the economy,
efficiency, and effectiveness of
EPA's operations, becoming
more visible to EPA's
employees, and recognizing the
outstanding work of our own
staff, we believe that we  are
encouraging new levels of
cooperation and productivity

Articles and Publications
We have been working with
several professional associations
to develop and improve
publications which  have a wide
audience in the areas of
environmental protection,
auditing,  and investigating We
have also continued to develop
and publish articles for EPA
managers and employees by
working with  the Office of
Public Affairs, and for the public
and specific professional groups
through professional
associations and publishing
services  During this semiannual
reporting period, we have
initiated articles in more than 10
different publications In
addition, numerous articles hav
been published by newspapers
nationwide concerning the
results of our most significant
audits and investigations  Dunn
this period we also issued an
updated version of a popular
publication, "What to do Befor
and After the Auditors Arrive "
We also distributed a new
publication, "What an
Investigation Means to You" t
all EPA and contract employee

Presentation of Fraud
Detection and Awareness
Course to Agency Managers
and Contract Specialists
This semiannual period, we
gave several presentations of
course entitled "Fraud
Detection  and Prevention in
EPA Projects and Contracts  "
This course was originally
developed for  presentation to
independent public accountant
who perform audits  for the Ol
on a contract basis, to mcreas
their awareness of and ability t
detect and refer indicators of
fraud to our Office of
Investigations However, the
course has also been
constructed for presentation to
a variety of audiences
concerned with the ability to
detect and prevent fraud in
contracts and projects We hav
recently received requests to
present this course to various
groups and organizations,
including the EPA Institute,  an
will continue presenting this
course during  fiscal  1988
  The OIG fraud awareness
course includes sections on
• The definition and
characteristics of fraud,
• Motivations and conditions
conducive to Iraud,
• General indicators of fraud,
and detection  techniques,
• Types of fraud and schemes
EPA is most vulnerable to,
• How and when to refer
suspected fraud to the OIG,
• Case studies of fraud and
abuse  in EPA; and
• Prevention techniques and
remedies
 28
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Personnel
Security Program
The personnel security program
is one of the Agency's first-line
defenses against fraud, using
background and National
Agency Checks and Inquiries
investigations to review the
integrity of EPA employees and
contractors
  During this  semiannual
reporting period, the Personnel
Security Staff reviewed 345
investigations The following
conditions were identified and
administrative actions taken
• Six EPA employees were
required to submit corrected
Standard Forms 171, Application
for Employment, after
investigation proved that they
had falsified those forms Three
employees falsely claimed
college degrees not earned, two
failed to disclose terminations
from previous jobs, and one
failed to disclose a conviction
for driving while intoxicated
• One applicant was selected
for a critical sensitive position
but subsequently withdrew
because of falsifying his SF-86,
security data questionnaire, for
a sensitive position The
applicant claimed a college
degree which was a
requirement of employment
However, we determined that
the applicant never attended the
university he claimed to have
graduated from
• Another employee withdrew
his application for employment
in a critical sensitive job when
we determined that he had
been a regular user of an
assortment of illegal drugs
• One employee resigned,
pending administrative removal,
after not disclosing previous
convictions for writing bad
checks on a SF-171 used for a
promotion  The employee
continued  providing false
testimony  during interviews and
failed to make restitution to the
court for the bad checks issued

  We continued working closely
with Agency program officials
on the  implementation of the
0PM regulations regarding
position sensitivity designations
and granting of clearances
  We are also putting security
information and data on a
computer data base which  will
provide easy retrieval and
access to personnel security
and clearance information
President's
Council on
Integrity  and
Efficiency
President Reagan established
the President's Council on
Integrity and Efficiency (PCIE)
by Executive Order in  March
1981 to attack waste and fraud
and improve management in the
Federal Government  The PCIE
coordinates mteragency
activities, addressing common
issues and developing
approaches and techniques to
strength the effectiveness of
the entire Inspector General
community Headed by the
Deputy Director,  Office of
Management and Budget, the
PCIE includes the 19 statutory
Inspectors General and other
key Federal officials
  John C Martin, the  Inspector
General, is the chair of the
Administration, Inspections,  and
Special Reviews  Committee,
one of PCIE's standing
committees  The standing
committees are the means PCIE
uses to get its work
accomplished  Martin's
committee, as reorganized in
February 1988, incorporates
activities of the former
Prevention Committee,
Inspections and Special
Reviews  Committee, Training
Committee, and Standards
Committee The functions of
the committee are to
• Serve as the focus to
promote good administrative
practices within the Offices of
Inspector General,
• Facilitate an effective training
function within IG offices, and
serve as focal point for training
and career development within
the IG community,
• Revise and amend the
published quality standards for
investigations and Office of
Inspector General,
• Provide a focal point for
issues developed from the
Committee's special reviews,
contribute to a common
understanding of  these issues,
and promote development of
shared IG positions on such
issues,
•  Serve as a repository of
mteragency data obtained from
surveys conducted by Offices of
Inspector General,  and
•  Increase the sensitivity of
Federal personnel and external
groups to waste, fraud, and
abuse by using effective
communication techniques to
promote awareness of Council
activities and initiatives
   In addition to  leading the
Committee in performing its
functions,  Mr Martin and his
staff participated in,
coordinated, or conducted
special reviews to advance PCIE
goals
   Two subcommittees, the
Training Subcommittee and the
Communications Subcommittee,
carry out projects in their
assigned areas The Training
Subcommittee promotes
standardized training and
encourages career  development
throughout the IG Community
through its permanent work
groups on auditor training,
investigator training, support
activities training, and executive
development The
Communications Subcommittee
advance PCIE's goals by
publishing compendiums of
PCIE publications, providing
speakers to discuss fraud,
waste, abuse, and
mismanagement topics,
   EPA OIG staff also
participated as members of the
Legislation, Computer,
Coordination, Investigation and
Law Enforcement Committees
Our staff represented the OIG
on the Training Subcommittee,
actively assisting the Executive
Development work group and
the Support Activities Training
work group
   Staff of the EPA  Office of
Inspector General participated in
or led a number of  Committee
special reviews during this
semiannual reporting period
Some of these reviews are
summarized  below

Forwarding Penalty
Information to the IRS
The EPA OIG is  leading a study
to determine if Federal agencies
which collect penalties should
be forwarding this information
to the Internal Revenue Service
Doing so could better ensure
that violators do not deduct
penalties as business expenses
                                                                                                                         29
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When this occurs, the penalties'
deterrent effect is lessened and
the agency's goal of obtaining
equity within the regulated
community by removing any
benefit resulting from violating
the regulations is defeated

IG Awards Program
IGs may grant cash awards to
agency employees whose
disclosures to the IG of waste,
fraud, abuse, or
mismanagement have resulted
in cost savings The  IGs may
also nominate agency
employees, through  the agency
head, to receive a Presidential
award, greater than the IG is
authorized to grant, for
disclosures that resulted in
substantial cost savings As a
Committee project, the Health
and Human Services OIG is
examining the IG awards
program to determine whether
it is operating as intended and
whether improvements could be
made to enhance its
effectiveness

Establishing Regional
Councils of the PCIE
A suggestion was made that
PCIE consider establishing PCIE
regional councils We conducted
a preliminary survey and then a
survey of all statutory IGs to ask
for their views on the subject
Most respondents believed
there was no compelling need
to set up regional councils  IGs
felt there are sufficient local
forums for exchange of ideas,
that the policymakmg nature of
PCIE work calls for a centralized
structure, and expenditure of
scarce PCIE resources would
not justify the expected return
As a result of the survey,
several suggestions  for
improved communication with
field offices were made to the
PCIE members

Premium Pay for Investigators

We surveyed other IGs to
determine which ones are
compensating criminal
investigators for irregular and
unscheduled overtime Premium
pay may be one of the major
reasons that special agents
transfer from one Federal
agency to another We found
that six agencies are currently
compensating their investigators
with premium pay for
administratively uncontrolled
overtime, and two more have
plans to implement premium
pay in the future  We offered
assistance to any OIGs
interested in utilizing premium
pay to compensate investigators
for irregular and unscheduled
overtime and offered to provide
copies of the implementing
regulations

Providing Information to
Employees on Legal
Developments
We looked into whether OIGs
are  providing information to
their employees on current legal
developments relating to the
staff's work  The  majority of the
IGs who responded to our
questionnaire receive
informational material on legal
developments A  summary of
the responses was provided for
PCIE members to assist them in
determining how  their offices
can best provide  legal reference
material to the staff

Proposed Multiple ("Mirror
Image) IGs in Some Agencies
There are a number of recent
congressional initiatives to
establish additional Inspectors
General with jurisdiction for
particular programs in Federal
agencies which already have
statutory Inspectors General In
surveying the Inspector General
community, we found that PCIE
members believed that it was
generally inappropriate to place
multiple Offices of Inspector
General in the same agency
This consensus was used  by
PCIE's  Legislation Committee to
formulate letters  which were
sent to congressional leaders
concerning the proposed
legislation
Committee On
Integrity And
Management
Improvement
The Committee on Integrity and
Management Improvement
(CIMI) was established in 1984
by EPA Order 1130 1  The
purpose of CIMI is to coordinate
the Agency's effort to minimize
the opportunities for fraud,
waste, and mismanagement in
EPA programs  and to advise the
administrator on policies to
improve the  efficiency and
effectiveness of EPA  programs
and activities The committee is
chaired by the  Inspector
General  The following
describes examples of projects
completed during this reporting
period for distribution in spring
1988

Awareness Bulletin on New
Antifraud Legislation
Congress enacted legislation
which has given Federal
agencies significant new
strength in dealing with and
deterring fraud Because it is
important that  Agency
managers, their employees, and
contractors be  aware of these
new laws and  how they should
be used to attain relief in cases
of fraud against the
Government, the CIMI has
developed an Awareness
Bulletin on new antifraud
legislation outlining the False
Claims Act Amendments of
1986, the Program Fraud Civil
Remedies Act  of 1986, and the
Anti-Kickback Act of 1986
Ethics in a Nutshell
"Ethics in a Nutshell" is a
15-page booklet developed wit
the assistance of EPA's
Designated and  Alternate
Agency Ethics Officials for
distribution to all EPA
employees and contract
employees as a  straightforward
presentation on  what is and  is
not acceptable conduct based
on current laws  and regulation
Written in a lively,
easy-to-understand format,
"Ethics in a Nutshell" provides
quick reference  to EPA
employees, contract employee
and former employees on mos
personal  and professional
activities concerning their
employment with  EPA  By
informing or reminding
employees and  contract
employees of their obligations
to adhere to standards of
conduct and by  encouraging
them to report possible
violations, the CIMI is actively
promoting the highest degree
integrity in EPA
 30
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IG employees and Agency
managers, making OIG work
products more useful to
EPA managers

•  The Internal Audit  Survey
Process
This course, developed jointly
by members of our Northern
Audit Division and Headquarters
staff, reviews the purpose and
process of making effective
internal audit surveys  The
course, featuring a videotape
introduction by Donald E
Kirkendall, Deputy IG, was
presented during this period to
members of our Office of Audit
  A condensed version of this
course was also presented to
the auditing community in
Washington, D C , through the
Institute of Internal Auditors

  The OIG also arranged for
two contract courses
(1) EPA Basic Auditor Training,
on fundamentals and personal
skills required to be an effective
Government auditor, with
orientation to EPA and the OIG,
and
(2) Project Management,
combining instruction on
planning, scheduling , and
controlling skills required by
effective Government auditors
  In November 1987, the EPA
Institute gave an Instructor
Symposium, Recognition
Ceremony In the recognition
ceremony Juanita Cherry (from
OIG  Office of Audits), Edwin
Canady, and Michael Binder
(both from the OIG Office of
Management and Technical
Assessment) were honored as
EPA instructors

Human Resources Council
The OIG Human Resources
Council, composed of 16 OIG
employees representing all
grade levels and geographic
locations, advises and assists
the Inspector General in
developing effective policies,
strategies, and programs for
employee development and
workforce management  The
Council  is chaired by the
Assistant Inspector General for
Management and Technical
Assessment
  As a result of the HRC's 1987
projects'
• Orientation handbooks are
being distributed to all  new
 Hotline Activities
 The OIG Hotline Center
 received 26 new complaints and
 completed  and closed 29 cases
 during the reporting period Of
 he 29 cases closed, 7 cases
 'esulted in  environmental,
 Drosecutive, or administrative
 :orrective action, while 22 were
 not valid and did not require
 action Cases that did not have
 mmediate  validity due to
 insufficient information may be
 jsed  to identify trends or
 Datterns of potentially vulnerable
 areas for future review  The
 notline also received 421
 elephone calls where callers
 were  referred to the appropriate
 Drogram office,  State agency, or
 Dther Federal agency for
 assistance
  The following are  examples of
 corrective action taken as a
 result of information provided to
 he OIG Hotline Center
 • A complaint alleged that an
 EPA project officer improperly
 influenced the Agency to award
 a contract because of a financial
 relationship with an  employee
 of the contractor A  review of
 this complaint disclosed that the
 EPA project officer failed to file
 a complete  financial disclosure
 statement,  and also  created the
 appearance of a conflict of
 interest As a result, several
 administrative actions were
 taken, including  issuance of a
 formal letter of reprimand and
 prohibiting the employee from
serving as a project officer or
task manager for one year
• A complaint alleged that an
EPA subcontractor was
simultaneously representing the
Agency and a private company
on a related issue A review of
the complaint disclosed  that a
subcontractor employee made
remarks at a public meeting
which gave the appearance of a
conflict of interest The
employee also used a draft EPA
manual not available to the
public,  which was in direct
violation of contractual terms
with the prime contractor  As a
result, the prime  contractor
issued written  instructions to
subcontractors clarifying
contractual requirements  In
addition, the subcontractor
reprimanded the  employee
involved and took steps  to
prevent the situation from
recurring
Professional And
Organizational
Development
During this semiannual period,
the EPA OIG has expanded on a
number of initiatives started in
the previous 6-month period
while initiating several new
actions to increase our skills,
improve our relationships and
offer greater opportunities
Areas of the greatest activity
include the development and
presentation of several technical
and management courses by
our staff, projects of our Human
Resources Council, and
publication and distribution of
our own training catalog  For
this semiannual period, we
approved 248 training
enrollments for a total of 891
days of training and participation
in professional development
seminars and conferences

OIG-Developed Courses

•  Detection and Prevention of
Fraud in EPA  Programs and
Contracts
This course was developed to
better prepare independent
public accountants  doing work
for the EPA OIG to detect and
refer possible fraud to the OIG
for investigation We prepared
staff members in each divisional
office to present this course in
their geographic locations This
course is scheduled for
nationwide presentation during
fiscal 1988 to our staff, to the
independent public accountants
doing work for the  OIG, and to
EPA managers, through the  EPA
Institute

•  Briefings and Presentations
for Managers
This course is designed to
prepare managers and
supervisors to  give effective and
persuasive presentations and
deal with confrontation  This
course includes sections on
effective oral communications,
use of visual imagery,
confrontational management,
and a video workshop This
course has been expanded to
emphasize auditor/investigator
client relationships  for improving
the teamwork  concept between
                          31
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                                 Section  5  —Delinquent  Debts
employees  These manuals
explain the history and functions
of the OIG and its relationship
to the Agency, EPA travel
procedures, the Human
Resources Council, and the OIG
issuance system  The
handbooks also provide copies
of OIG brochures, the OIG
quarterly newsletter, and the
OIG telephone directory
• In  March 1988, a one and
one-half day orientation session
was held at Headquarters for all
employees hired since
September 1987  The new
employees met OIG's top
managers, toured EPA's
Waterside Mall facility, and
were briefed on important EPA
programs
• OIG employees are
participating in a 5/4-9
compressed workweek
program This project \s being
undertaken on a 6-month trial
In June, OIG management will
determine whether the work
schedule is of overall benefit to
the OIG and should continue
past the scheduled July cutoff
  In January 1988, the Council
met to develop its annual plan
Six new projects  are now
underway.
• Secretarial  training—
developing profiles and
reference materials,  studying
the feasibility  of OIG
workshops
• Cash awards for passing
professional certification—
studying the feasibility of such
a program
• Employee retention—
determining who is leaving
the OIG and  the reasons
for departure
• Work-at-home  policy—
studying the feasibility of
allowing ill or  temporarily
disabled employees  who are
expected to return to full-  or
part-time  work and who have
used up their accumulated leave
to work out of their homes
• Employee wellness—
developing  information on
EPA-provided  health services
• Recruitment—developing
methods  to attract high-quality
applicants for positions with the
OIG
The Supplemental
Appropriations and Rescission
Act of 1980 (Public Law
96-304) requires the Inspector
General to report on EPA's
delinquent debts and efforts
to improve the collection of
such debts.
Agencywide Accounts
Receivable Activity

Major Audit Effort
During this semiannual period,
we issued a comprehensive
report on the effectiveness of
the Agency's controls over
accounts receivable  We found
that recorded balances were
frequently incorrect and
collection action was lacking
For further detail, see Section 1,
Agency  Management, "Money
Due EPA Not Accurately
Recorded or Collected," of this
report

Claims Office Actions
When the Agency's  Servicing
Finance Offices (SFOs)
determine that debts are
uncollectible, they forward the
debts to the EPA Claims Officer
for disposition. The Claims
Officer may compromise,
terminate, or suspend further
collection efforts on  debts under
$20,000  Debts over $20,000
generally must be forwarded to
the General Accounting Office
or the Department of Justice for
approval of the final  resolution
of debts However, the Claims
Officer need not immediately
refer debts over $20,000 until
Agency collection actions hav
been taken
  As of March 31, 1988, the
Claims Officer reported  44
accounts receivable valued at
$3,447,882 For this reporting
period, the Claims Officer
• Suspended collection actio
on 12 debts totaling
$1,319,926;
• Referred 6  debts totaling
$356,372 to the Department
Justice;
• Collected one debt for
$50,995, and
• Compromised a $13,222 d
for $7,979.
  The OIG did not verify the
figures reported by the  Claim
Officer.

Agency Collection Efforts
The Financial  Management
Division provided the  followm
summary of EPA's collection
efforts for October 1, 1987,
through March 31, 1988, and
accounts receivable as of Ma
31,  1988 The OIG did not ve
the amounts presented belo\
                               Collections
                               Amounts Written Off
                               Interest Assessed
                               Interest Collected

                               Accounts Receivable

                                 Non-Federal
                                   90 days or less
                                   Over 90 days


                                 Subtotal1
                                 Interagency Agreements2
                                                $52,394,09
                                                     76,32
                                                    520,11
                                                    469,35
                                                $22,270,00
                                                 73,257,81


                                                 95,527,82
                                                  1,750,54
                               Total
                                                $97,278,37
                               1 Agency records show that 61 percent of this amount is receivables which are being
                               appealed Collection actions are suspended until the appeals process is complete

                               2This amount is for debts owed EPA by other agencies Although these debts do not
                               have an impact on the U S Treasury, they do impact the Agency budget
                               Approximately 28 percent of the total in this category is over 90 days old
 32
-------
 'HE INSPECTOR GENERAL ACT REQUIRES THE IDENTIFICATION OF EACH AUDIT REPORT COMPLETED OR ISSUED BY THE OIG DURING THE REPORTING
 >ERIOD THE FOLLOWING LISTING CATEGORIZES AUDIT REPORTS BY TYPE AND REGION
 \udit Control Number
                              Auditee
                                                Final Report Issued
                                                                     Audit Control Number
                                                                                                  Auditee
                                                                                                  Final Report Issued
 .  INTERNAL & MANAGEMENT AUDITS

 1H26010106-80853
 1CW7020094-80851


 1K27040138-80759


 1 K67050449-80743
 1K27050462-80821
 1D37050456-80855


 1K27090115-80511
NPDES PERMIT-REGION 1   MA
 TOTAL OF REGION 01 = 1

NIAGARA FALLS NY
 TOTAL OF REGION 02 = 1

NESHAP-REGION 4 GA
 TOTAL OF REGION 04 = 1

STATIONARY SOURCES
NESHAP
EXPORT OF HAZARDOUS WASTES
 TOTAL OF REGION 05 = 3

NESHAP-REGION 9 CA
 TOTAL OF REGION 09 = 1
 1L48110021-80373    ERA'S 1987 FMFIA ACTIVITY
 1B58110031-80674    CONSULTING SERVICES
 1A67110029-80779    + + ACCOUNTS RECEIVABLE
 1E57110024-80780    PCB TRANSFORMER FIRES RULE
                  TOTAL OF HEADQUARTERS =  4
           TOTAL INTERNAL & MANAGEMENT AUDITS = 11
 !. CONSTRUCTION GRANT AUDITS
 '2CW6010279-80209
 '2CW6010082-80549
 '2CW6010110-80550
 '2CW6010134-80565
 '2CW6010192-80812
 '2 CW7010073-80823
 '2CW6010261-80824
 2CW6020048-80057
 2CW6020106-80208
 2CW6020102-80224
 2CW6020096-80311
 2CW6020034-80317
 2CW6020107-80325
 2CW6020101-80326
 2CW6020112-80348
 2CW6020105-80349
 2CW5020150-80381
 2CW6020166-80382
 2CW6020016-80383
 2CW60201 56-80399
 2CW6020018-80449
 2CW6020197-80450
 I2CW6020164-80813
 2AW7030105-89001
 12CW6030033-80023
 '2CW6030032-80035
 '2CW5030290-80036
 '2CW5030297-80037
 '2DW6030293-80075
 '2CW5030310-80233
 '2CW6030227-80279
 '2CW60301 52-80446
 '2CW6030017-80535
 '2CW6030311-80658
 '2CW7030054-80677
 '2CW6030342-80713
 '2CW7030160-80748
 '2CW7030010-80777
 '2CW7030241 -80796
:2BW7040330-80755
!2CW5040311-88007
J2CW6040308-88012
J2CW7040259-88031
12CW6040293-88032
^2CW7040233-88042
32CW6040081-80055
32CW7040019-80111
32CW7040020-80180
32CW7040068-80226
D2CW7040017-80288
32CW5040019-80497
32CW7040096-80522
D2CW7040048-80539
32CW6040022-80179
32BW4040282-80616
32CW4040302-80817
 NORWALK CT
 CHESHIRE CT
 NARRAGANSETT Rl
 EAGLE LAKE WATER & SEWER DIS Ml
 MONTAGUE MA
 PEABODY MA
 PEABODY MA
 TOTAL OF REGION 01 = 7

WALL TOWNSHIP NJ
ATLANTIC CO UA NJ
MARLBOROUGH NY
SHAWANGUNK NY
WATERLOO NY
PHILMONT NY
CHEEKTOWAGA NY
ONONDAGA CO NY
BRIELLE BOROUGH NJ
BARNEGAT NJ
WESTERN MONMOUTH UA NJ
BETHLEHEM NY
ONONDAGA COUNTY  NY
SHERRILL NY
CRAWFORD NY
NYSEFC/HANCOCK NY
 TOTAL OF REGION 02 =  16

DALLAS AREA MUN'EARLY WARN-PA
BALTIMORE MAYOR & CITY-MD
ALLEGANY COUNTY-MD
ALLEGANY-MD
ALLEGANY-MD
NEW HANOVER TOWNSHIP AUTH - PA
DC GOVERNMENT-DC
BUCHANAN COUNTY PUB SERV-VA
RUSH/RYAN SEWER AUTHORITY-PA
RICHMOND CITY-VA
HAGERSTOWN-CITY OF-MD
DOVER CITY OF-DE
MIDDLESEX TOWNSHIP MUN AUTH-PA
SUSSEX COUNTY COUNCIL-DE
ANNE ARUNDEL COUNTY-MD
FRIENDLY PUB  SERV DISTRICT-WV
 TOTAL OF REGION 03-16

OWENSBORO KY
SHEPHERDSVILLE KY
CONWAY NC
HICKMAN KY
STARKE  FL
WCRSA SC
CAMPBELL & KENTON CO KY
BROWARD CO FL
PENSACOLA FL
BURLINGTON NC
CYNTHIANA KY
BERKELEY CO WSA SC
DARIEN GA
HOPKINSVILLE KY
CLARKSVILLETN
CHATTANOOGA TN
OAK RIDGE TN
TOTAL OF REGION 04 = 17
03-31:88


0331/88


03/16/88


03/11/88
03/24/88
03/31/88


01/25/88


12/23/87
02-24/88
03/17/88
03/17/88
 11,12/87
 02/03/88
 02/03/88
 02/05/88
 03/24/88
 03/25/88
 03/25/88
10'15;87
11/12/87
11/16/87
12/08/87
12/09/87
12/10/87
12,10/87
12-21/87
12'21/87
12'28/87
12/28,87
12'28'87
01/04/88
01'19'88
01,19/88
03 24/88
03<25'88
10'07/87
10'08/87
10/08/87
10'08'87
10,16/87
11 18/87
11,25/87
01 19'88
01,29'88
02,23/88
02,24/88
03,01,88
03 11,88
03/16/88
03 '22/88
03 15'88
11 03'87
12 08'87
01 20'88
01 2688
03,'02'88
10 13'87
10,26/87
11'09'87
11 17/87
11 30/87
01,22/88
01'28'88
02 01,88
11 '09/87
02 17 88
03 24'88
                                                  E2CW5050320-80005
                                                  E2CW6050241-88048
                                                  P2DW5050132-80464
P2CW5060048-80076
P2AW7060149-80519
P2BW7070096-80669
P2CW6080023-80178
P2CW6080039-80183
P2CW6080077-80408
P2CW6080079-80642
E2CW6090033-80230
E2CW6090213-80420
E2CW7090220-80421
E2CW6090080-80659
E2AW8090068-80684
E2CW6090060-80822
E2AW7090249-80837
E2AW7090172-80848
E2CW5090017-88003
I2EM8090061-80389
P2CW6090097-80056
S2CW6090022-80078
S2CW6090176-80079
S2CW6090035-80088
S2CW6090045-80416
S2CW6090066-80418
S2CW5090197-80598
S2CW6090034-80599
S2CW6090056-80802
       DELAFIELD-HARTLAND WPCC Wl
       CARMEL IN
       DETROIT WSD Ml
        TOTAL OF REGION 05 = 3

       SAN ANTONIO TX
       MCGOODWIN WILLIAMS & YATES AR
        TOTAL OF REGION 06 = 2

       KANSAS CITY KS
        TOTAL OF REGION 07 = 1

       PUEBLO CITY OF CO
       MONTROSE CITY OF CO
       SUMMIT/COUNTY/SILVERTHORNE CO
       FORT COLLINS CITY OF CO
        TOTAL OF REGION 08 = 4

       TUOLUMNE REG WATER DIST CA
       LAS VEGAS CITY OF NV
       HONOLULU CITY & COUNTY OF HI
       STATE WATER RESOURCES CB CA
       SAN JACINTO MAWSA CA
       IMPERIAL CITY OF CA
       EARLY WARNING-LOS ANGELES CA
       VALLEY CENTER/EARLY WARNING CA
       SUPERIOR SANITARY DISTRICT AZ
       GUAM GOVERNMENT OF
       HOLBROOK CITY OF AZ
       EAST BAY DISCHARGERS AUTH CA
       SANTA ANA WPA CA
       EAST BAY DISCHARGERS AUTH CA
       VISTA SAN DIST CA
       LIVERMORE CITY OF CA
       LOS ANGELES CSD CA
       LOS ANGELES CSD CA
       SAN JOSE CITY OF CA
       TOTAL OF REGION 09  = 19
P2CW6100019-80103
P2CW7100006-80177
P2CW6100105-80409
P2CW6100004-80793
       HOQUIAM CITY OF WA
       KUNA CITY OF ID
       OROFINO CITY OF ID
       JUNEAU CITY AND BOROUGH OF AK
        TOTAL OF REGION 10 = 4
TOTAL CONSTRUCTION GRANT AUDITS  =  89
3. OTHER GRANT AUDITS
C3EC7010217-80034
C3EC7010218-80043
C3EC7010219-80104
C3EC7010220-80105
C3EC7010221-80106
C3EC7010222-80107
C3EC7010223-80138
C3EC7010224-80142
C3EC7010225-80143
C3EC8010101-80415
C3EC8010102-80432
C3EC8010104-80433
C3EC8010105-80434
C3EC8010103-80441
C3EC8010109-80499
C3EC8010108-80514
C3EC8010111-80518
C3EC8010112-80530
C3EC8010149-80559
C3EC8010150-80560
N3GC801001 5-80221
N3GC801001 6-80222
N3GC8010017-80271
N3GC8010018-80282
N3GC8010019-80297
N3GC8010050-80347
N3GC8010100-80414
N3GC8010107-80427
N3GC8010106-8051 5
N3GC8010152-80561
N3GC8010154-80594
N3GC8010158-80615
N3GC8010184-80797
N3GC8010185-80798
N3GC8010186-80799
N3GC8010187-80825
       BRISTOL
       ACUSHNET MA
       HILLSBOROUGH NH
       BERLIN VT
       BERLIN VT
       MILFORD NH
       WEBSTER MA
       CLAREMONT NH
       MATTABASSETT DIST CT
       PROCTOR VT
       MATTABASSETT DISTRICT CT
       TOWN OF CHATHAM MA
       EPPING NH WASTE WATER TREAT NH
       TOWN OF WINDSOR LOCKS CT
       GUILFORD-SANGERVILLE SAN  DISM
       ST ALBANS VT
       NORTH HAVEN CT
       WALLINGFORD
       DERRY NH
       HANOVER NH
       MONTACHUSETT PLANNING COMM MA
       MONTACHUSETT PLANNING COMM MA
       WATERBURY CT
       NANTUCKET MA
       BRIDGEPORT CT
       SOUTHERN NEW  HAMPSHIRE SC NH
       NEW HAVEN CT
       CAMBRIDGE MA
       MA DEPT ENVIRONMENTAL ENG
       UNIV OF MAINE SYSTEM
       METROPOLITAN AREA PLNG
       STATE OF MASSACHUSETTS MA
       BERLIN NH
       NANTUCKET MA
       NASHUA NH
       VALLEY REG PLNG CT
       TOTAL OF REGION 01 - 36
                                                                     100287
                                                                     03 15'88
                                                                     01,2088
 10,19'87
 01 '27,88
                                                        02/23/88
11/17/87
01/11/88
01/11/88
02/23/88
02/25/88
03/24/88
03/29/88
03/30/88
10/08/87
12/31/87
10/13/87
10/19/87
10/19/87
10/21/87
01/07/88
01/07/88
02/10/88
02/10/88
03/22/88
10/08/87
10/09/87
10/23/87
10/23/87
10/23/87
10/23/87
10/27/87
10/29/87
10/29/87
01/07/88
01/14/88
01/19/88
01/19/88
01/19/88
01/22/88
01/25/88
01/27/88
01/28/88
02/04/88
02/04/88
11 ,'13/87
11  1387
11  1387
11'25 87
12,02,87
12'18 87
01  07 88
01/1288
01/2588
02  05 88
02  10,88
02  1788
03,22 88
03'23'88
03  23 88
03,2588
                                                                                                                                          33
-------
Audit Control Number
                              Auditee
                                                 Final Report Issued
                                                                      Audit Control Number
                                                                                                    Auditee
                                                                                                   Final Report Issued
C3EC7020268-80020
C3EC7020271-80021
C3EC7020275-80022
C3EC7020278-80029
C3EC7020279-80031
C3EC7020286-80042
C3EC7020295-80044
C3EC7020298-80045
C3EC7020281-80046
C3EC7020296-80080
C3EC7020299-80139
C3EC7020297-80140
C3EC8020011-80148
C3EC802001 2-80149
C3EC8020013-80152
C3EC802001 5-80203
C3EC8020014-80204
C3EC8020040-80205
C3EC8020039-80206
C3EC8020041-80207
C3EC8020050-80289
C3EC8020053-80307
C3EC8020052-80316
C3EC8020054-80324
C3EC8020071-80372
C3EC8020075-80386
C3EC8020076-80387
C3EC8020078-80388
C3EC8020084-80397
C3EC8020085-80398
C3EC8020102-80443
C3EC8020104-80444
C3EC8020103-80445
C3EC8020107-80452
C3EC8020118-80533
C3EC8020119-80536
C3EC8020105-80541
C3EC8020101-80562
C3EC8020122-80573
C3EC8020124-80574
C3EC8020123-80593
C3EC8020129-80637
C3EC8020130-80639
C3EC8020132-80640
C3EC8020131-80641
C3EC8020138-80726
C3EC8020140-80736
C3EC8020144-80814
C3EC8020145-80815
C3EC8020153-80852
C3EC8020139-80854
N3GC8020051-80290
N3GC8020070-80366
N3GC8020100-80442
N3GC8020106-80451
N3GC8020117-80500
N3GC8020121-80572
N3GC8020128-80638
N3GC8020134-80655
N3GC8020135-80656
N3GC8020136-80657
N3GC8020137-80718
N3GC8020152-80794
C3EC8030037-80150
C3EC8030038-80151
C3EC803001 2-88001
C3EC8030013-88002
C3EC8030025-88004
C3EC8030026-88005
C3EC8030034-88006
C3EC8030041-88008
C3EC8030051-88011
C3EC8030059-88017
C3EC8030063-88020
C3EC8030067-88023
C3EC8030069-88025
C3EC8030074-88026
C3EC8030077-88028
C3EC8030083-88029
C3EC8030084-88030
C3EC8030106-88035
C3EC8030115-88039
C3EC8030116-88040
C3GC8030121-88043
C3EC8030122-88044
C3EC8030123-88045
C3GC8030124-88046
C3GC8030125-88047
C3GC8030133-88051
C3EC8030134-88052
C3GC8030136-88053
C3GC8030138-88055
N3GC8030001-88000
N3GC8030044-88009
N3GC8030050-88010
N3GC8030052-88013
N3GC8030053-88014
LONG BRANCH SA NJ                   10-05/87
GREENE NY                           1005'87
LIBERTY NY                           1005/87
DELAWARE RIVE BASIN COMM NJ        10.08'87
DELAWARE RIVER BASIN COMM NJ       10/08,87
SOUTH MONMOUTH REG SA NJ          10 09'87
FLORHAM PARK SA NJ                  10'13,87
WASHINGTONVILLE NY                  10<1387
BRANT NY                            1013'87
FREEVILLENY                         10.19'87
MIDDLETOWN NY                      1027-87
CHITTENANGO NY                      1027/87
FALCONER NY                         11-02'87
CATSKILL NY                          11 02 87
HANOVER SEWERAGE AUTH NJ          11 '02-87
HAMBURG NY                         11 12/87
SUBURBAN REG HEALTH COMM NJ       11'12/87
DELAWARE RIVER BASIN COMM NJ       11 12/87
PERU NY                             11:12-87
ROCKLAND NY                         11 12/87
WILSON NY                           11/30/87
NEW WINDSOR NY                     12'08/87
HORNELL NY                          1209/87
AKRON NY                            12-09/87
MARLBOROUGH NY                    1222-87
CLARENCE NY                         12-29/87
BEACHWOOD NJ                      1229-87
TRI-MUNICIPAL SEWER  COMM NY        12-29/87
WEBSTER NY                          01/04-88
CATTARAUGUS NY                     01 '04/88
RIPLEYNY                            0119/88
LIBERTY NY                           01-19/88
BINGHAMTON NY                      01'19/88
KINGSTON NY                         01-19/88
ELLENVILLE NY                        01-29/88
OCEAN SA NJ                         01 '29/88
EQB PR                              02/02/88
WARWICK NY                         02/04/88
ROCKAWAY VALLEY REG SA NJ          02/08/88
LANCASTER NY                        02/08/88
PLEASANTVILLE NY                     02/10/88
SANFORD NY                          02/18/88
SAN FORD                            02-18/88
LEWISTON NY                         02/18/88
BAT AVI A NY                          02-18/88
ATTICA NY                            03/07/88
NEW BALTILMORE NY                  03/09/88
NEW BALTIMORE NY                   03/24/88
GOWANDA NY                         03/24/88
GLENS FALLS                         03/31/88
SAUGERTIES NY                       0331/88
SCH EN ECTADY NY                     11 '30/87
SARATOGA COUNTY NY                12'22/87
VESTAL NY                           01 19/88
KINGSTON NY                         01/19/88
FULTON NY                           01/22/88
SENECA COUNTY NY                   02/08/88
ROCHESTER NY                       02/18/88
ROCKLAND CO NY                     02/22/88
ONONDAGA CO NY                     02-22/88
CHEEKTOWAGA NY                     02-22/88
GENEVA NY                           03/03/88
JAMESTOWN NY                      03/21/88
TOTAL OF REGION 02 = 63

 LEOLA SEWER AUTHORITY-PA            11/02/87
 WASH SUBURBAN SANITARY COMM-MD   11/02/87
 BUCHANAN COUNTY OF-VA              10/02/87
 QUAKERTOWN BOROUGH OF-PA          10/07/87
 TAZEWELL COUNTY OF-VA               10/15/87
 AMHERST COUNTY OF-VA                10/15/87
 HANOVER COUNTY-VA                   10/27/87
 SCRANTON SEWER AUTHORITY-PA        11,18/87
 LEESBURG TOWN OF-VA                12/07/87
 HAVRE DE GRACE CITY OF-MD            12/15/87
 HURLOCK MAYOR & COUNCIL OF-MD      12/24/87
 MONTROSE MUNICIPAL AUTH-PA         12/24/87
 HARRISBURG SEWER AUTHORITY-PA      01/11/88
 SUMMIT TOWNSHIP SEWER AUTH-PA      01/14/88
 BERKELY COUNTY SEWER  DIST-WV        01/15/88
 LAUREL TOWN OF-DE                   01/19/88
 SPRINGETTSBURY TWNSP SEWER-PA      01/20/88
 GETTYSBURG MUNICIPAL AUTH-PA        02/18/88
 BUCHANAN COUNTY/FYE 6/87-VA         02/25/88
 SUSQUEHANNA RIVER/FYE 6/87-PA        02/25/88
 DC DEPT OF ENVIRO SERVICES-DC        03/08/88
 PRINCE WILLIAM CO/FYE 6/87-VA         03/10/88
 VA STATE WATER CON/FYE 6/87-VA        03/14/88
 DELMONT BOROUGH/CY 12/85-86-PA      03/15/88
 BUENA VISTA CITY/FYE 6/87-VA           03/1 5/88
 TAZEWELL CO PSA/FYE 12/87-VA          03/25/88
 CHESTERFIELD CO/FYE 6/87-VA           03/28/88
 NORTON-CITY OF/FYE 6/87-VA            03/29/88
 DOVER CITY OF/FYE  6/86-DE              03/30/88
 VA DEPT OF HEALTH-VA                 10/02/87
 VA DEPT OF STATE  POLICE-VA            11/19/87
 GEORGE UNIVERSITY-VA                12/01/87
 VA COMMONWEALTH  UNIVERSITY-VA     12/09/87
 VA PO^YTECH INST & ST UNIV-VA         12/09/87
N3GC8030055-88015
N3GC8030058-88016
N3GC8030061-88018
N3GC8030062-88019
N3GC8030064-88021
N3GC8030065-88022
N3GC8030068-88024
N3GC8030075-88027
N3GC8030092-88033
N3GC8030105-88034
N3GC8030107-88036
N3GC8030113-88037
N3GC8030114-88038
N3GC8030118-88041
N3FC8030126-88049
N3GC8030137-88054
C3EG7040331-80052
C3EG7040329-80054
C3EG7040324-80101
C3EG8040019-80108
C3EG8040026-80114
C3EG8040058-80115
C3EG7040328-80116
C3EG8040025-80117
C3EG8040020-80182
C3EG8040067-80184
C3EG8040063-80185
C3EG8040068-80186
C3EG8040074-80187
C3EG8040070-80190
C3EG8040073-80191
C3EG8040072-80192
C3EG8040053-80194
C3EG8040062-80198
C3EG8040059-80199
C3EG8040057-80201
C3EG8040050-80202
C3EG8040069-80228
C3EG8040081-80229
C3EG7040320-80286
C3EG8040079-80287
C3EG8040076-80291
C3EG8040084-80293
C3EG8040088-80308
C3EG8040095-80332
C3EG8040087-80333
C3EG8040096-80334
C3EG8040101-80355
C3EG8040104-80356
C3EG8040102-80357
C3EG8040110-80358
C3EG8040109-80362
C3EG8040108-80363
C3EG8040113-80364
C3EG8040105-80365
C3EG8040112-80367
C3EG8040107-80368
C3EG8040116-80369
C3EG8040115-80370
C3EG8040103-80378
C3EG8040118-80379
C3EG8040117-80380
C3EG8040119-80428
C3EG8040132-80466
C3EG8040133-80467
C3EG8040120-80468
C3EG8040128-80469
C3EG8040127-80470
C3EG8040139-80498
C3EG8040142-80520
C3EG8040135-80521
C3EG8040145-80538
C3EG8040152-80547
C3EG8040144-80548
C3EG8040153-80579
C3EG8040160-80583
C3EG8040168-80584
C3EG8040166-80585
C3EG80401 54-80586
C3EG8040164-80588
C3EG8040169-80589
C3EG80401 56-80590
C3EG8040173-80591
C3EG8040170-80592
C3EG8040159-80613
C3EG8040162-80614
C3EG8040167-80629
C3EG8040179-80631
C3EG8040182-80632
C3EG8040165-80634
C3EG8040177-80643
C3EG8040184-80715
C3EG8040185-8071 6
C3EG8040196-80733
C3EG8040194-80735
C3EG8040203-80756
C3EG8040205-80757
WESTMINSTER CITY OF-MD              12-11,87
ABERDEEN TOWN OF-MD                12'11/87
PENNSYLVANIA COMMONWEALTH-PA     12-21/87
FREDERICK CITY OF-MD                  12/21/87
MT AlRY TOWN OF-MD                  12/24/87
HAGERSTOWN CITY OF-MD              12/24/87
MARYLAND STATE OF-MD                12/24/87
RIDGELY-TOWN OF-MD                  01/14/88
SOUTHEASTERN VA PLANNING-VA         01/29/88
ROANOKE CITY OF-VA                   02'17/88
LEBANON CITY OF/CY 1986-PA            02/18/88
ALEXANDRIA-CITY OF/FYE 6/87-VA         02/25/88
HENRICO COUNTY/FYE 6/87-VA            02/25/88
NEW CASTLE COUNTY/FYE 6/87-DE        03/01/88
DELAWARE-STATE OF/FYE 6/87-DE         03/16/88
MONTGOMERY COUNTY/FYE 6,'86-MD      03/30/88
TOTAL OF REGION 03  = 50$

CRAMERTON NC                        10/13/87
PUNTAGORDAFL                      10/13/87
DOTH AN  AL                            10/22/87
WALLACE NC                           10/26/87
CLERMONT FL                         10/26/87
COBB CO GA                           10/26/87
ATLANTIC BEACH FL                    10/26/87
BRADENTON FL                        10/26/87
ANNISTON WWS BD ALA                 11/09/87
ALABAMA DEM AL                      11/10/87
BOONEVILLEMS                        11/10/87
POOLER  GA                            11/10/87
MONCKS CORNER WWSS SC             11/10/87
ATHENS TN                            11/10/87
FORT MILL SC                         11/10/87
LAKE CITY FL                           11/10/87
JACKSONVILLE FL                      11/10/87
GAUTIER UTILITY DIST MS                11/10/87
ONEONTA UTILITY BD AL                 11/10/87
ST ANDREWS PSD CHARLESTON SC       11/10/87
LUDOWICI GA                          11/10/87
WAVELAND REG WASTEWATER MS       11-17/87
ROME GA                             11/17/87
PEARL MISSISSIPPI                      11/30/87
EUSTIS FL                             11/30/87
PENSACOLAFL                         12/01/87
PALATKA FL                            12/01/87
MONTICELLO  KY                        12/08/87
HINESVILLE GA                         12/11/87
ANNISTON WWSP AL                    12/11/87
JOHN UMSTEAD HOSPITAL NC            1 2/11187
ATHENS AL                            12/21/87
JACKSONVILLE BEACHFL                 12/21/87
GAUTIER UTILITY DISTRICT MS            12/21/87
N EWTON CO WSA GA                   12/21 /87
CLYDE NORTH CAROLINA                12/21/87
RALEIGH MS                           12/22/87
CHARLOTTE TN                         12/22/87
MORTON MS                           12/22/87
EASLEY COMBINED UTIL SYS SC          12/22/87
CENTERTOWN KY                       1 2/22/87
SAVANNAH TN                         12/22/87
PETAL MS                             12/22/87
MAGGIE  VALLEY NC                    1 2/28/87
NEW CASTLE  KY                        12/28/87
MIDDLESBOROUGH KY                  12/28/87
HARRODSBURG KY                     01/13/88
LAKE  CITY TN                          01/21/88
THOMASVILLE GA                      01/21/88
RICHMOND WGSW KY                  01/21/88
METROPOLITAN SEWERAGE DIST NC      01/21/88
GEORGETOWN SC                      01/21/88
TALLAHASSEE FL                       01/22/88
CANDOR NC                           01/28/88
HARRISON CO WWM MS                01/28/88
CLEVELAND MS                        02/01/88
SOUTH FLA WMD FL                    02/03/88
HARTSVILLE SC                        02/03/88
WASHINGTON                         02/09/88
SPARTANBURG SWD SC                 02/09/88
GREENSBORO NC                      02/09/88
MIDWAY KY                           02/09/88
VIENNA GA                            02/09/88
NASHVILLE & DAVID TN                  02/09/88
MT PLEASANT SC                      02/09/88
MORRISTOWN TN                      02/09/88
LEWISBURG TN                        02/09/88
MT PLEASANT SC                      02/10/88
AIKENSSC                            02/17/88
STANTONSBURG NC                    02/17/88
 GRAND STRAD WSA SC                  02/17/88
 MILANTN                             02/18/88
 ROANOKE RSD NC                      02/18/88
 CARROLLTON VC KY                    02/18/88
 SUMTER SC                           02/18/88
 COLUMBIA SC                         03/02/88
JACKSON TN                           03/02/88
 LONDON KY                           03/09/88
 RADCLIFF KY                           03/09/88
 DAUPHIN ISLAND WSFPA AL             03/15/88
 ATLANTA GA                           03/1 5/88
 34
-------
 Audit Control Number
                               Auditee
                                                  Final Report Issued
                                                                       Audit Control Number
                                                                                                      Auditee
                                                                                                     Final Report Issued
C3EG8040192-80758
C3EG8040213-80760
C3EG8040191-80761
C3EG8040190-80762
C3EG8040195-80763
C3EG8040200-80764
C3EG8040204-80765
C3EG8040197-80766
C3EG8040188-80767
C3EG8040199-80768
C3EG8040201-80778
C3EG8040216-80782
C3EG8040214-80784
C3EG804021 5-80785
C3EG8040218-80804
C3EG8040224-80805
C3EG8040225-80816
C3EG8040227-80818
C3EG8040226-80819
C3EG8040211-80820
C3EG8040230-80833
C3EG8040202-80842
C3EG8040232-80843
C3EG8040231-80845
H3CU7040323-80053
H3CU8040056-80200
N3GG8040016-80100
N3GG8040017-80102
N3GG8040049-80109
N3GG8040054-80110
N3GG8040055-80112
N3GG8040018-80113
N3GG8040024-80181
N3GG8040066-80189
N3GG8040048-80193
N3GG8040075-80195
N3GG8040065-80196
N3GG8040064-80197
N3GG8040077-80225
N3GG8040078-80227
N3GG8040071-80234
N3GG8040083-80292
N3GG8040082-80310
N3GG8040111-80371
N3GG8040106-80376
N3GG8040114-80377
N3GG8040131-80471
N3GG8040126-80472
N3GG8040130-80473
N3GG8040134-80517
N3GG8040151-80546
N3GG8040157-80563
N3GG8040171-80564
N3GG8040172-80580
N3GG8040161-80581
N3GG8040158-80582
N3GG8040163-80587
N3GG8040180-80628
N3GG8040183-80630
N3GG8040178-80635
N3GG8040181-80714
N3GG8040187-80731
N3GG8040193-80732
N3GG8040198-80734
N3GG8040219-80783
C3EC7050778-80010
C3FC7050779-80011
C3EC7050805-80014
C3FC7050806-80015
C3EC7050648-80018
C3FC7050822-80019
C3EC7050783-80024
C3FC7050784-80025
C3EC7050785-80026
C3FC7050786-80027
C3EC7050803-80066
C3FC7050804-80067
C3EC7050807-80068
C3FC7050808-80069
C3EC7050809-80070
C3FC7050810-80071
C3EC7050812-80072
C3FC7050813-80073
C3EC7050818-80074
C3EC7050819-80091
C3EC7050820-80092
C3FC7050821-80093
C3EC8050038-80121
C3FC8050039-80122
C3EC8050040-80123
C3FC8050041-80124
C3EC8050042-80125
C3EC8050043-80126
C3EC8050044-80127
C3EC8050058-80136
C3FC8050059-80137
C3EC8050069-80147
OZARKAL                             03/1 5'88
FOUNTAIN RUN WD #1 KY               03 16/88
ANDALUSIA AL                         03'16/88
HARTSELLE UTIL BD ALA                 0316'88
DEKALB CO GA                         03:16:88
ROCKY MOUNT NC                      03'16'88
EDGEFIELD CO WSD SC                 03'16'88
CAVELAND SANITATION AUTH KY         03-1 6'88
COVINGTON GA                         03:16/88
ABBEVILLE SC                         03,16/88
MOULTRIE GA                          03,17,88
MORTON MS                           03,18/88
LEXINGTON FAYETTE VCG KY             03,18/88
CLEVELAND UTILITIES TN                 03,18/88
COLLINS                              03'23/88
FLEMING-NEON KY                      03 23'88
BAXLEY GA                            03/24/88
GEORGETOWN CO WSD SC              03'24'88
MTCARMELTN                         03-24-88
SEA PINES SVC DIST SC                  03,24/88
LAGRANGE GA                         03,25/88
CONYERS GA                           03-30/88
CONYERS GA                           03'30'88
VALDOSTA GA                          03 30/88
MISS MED CTR (UNIVOF)  MS             10,13/87
NORTH CAROLINA STATE  UNIV NC        11/10/87
NC DEPT ADMINISTRATION              10/22/87
CHATTANOOGA TN                      10/22/87
CLANTON AL                           10/26/87
LINEVILLEAL                           10,26,87
ALAMANCE NC                         10,26,87
COVINGTON TN                         10/26,87
KENTUCKY (COMMONWEALTH)           11/09/87
AUGUSTAGA                           11/10/87
CLEMSON UNIV SC                      11,10/87
KENTUCKY (COMMONWEALTH)           11,10/87
JEFFERSON CO COMMAL               11,10/87
LAKELAND FL                          11/10/87
HUNTSVILLE AL                         11/17/87
SARASOTA FL                          11/17/87
KENLY NC                             11/18/87
NC DNR AND COMMUNIRTY DEV NC       12,01,87
MISS DEPT NAT RES MS                 12/08/87
SC DEPT HLTH & EC SC                  12-22/87
STATE OF FLORIDA                      12/28/87
TRIANGLE J COUNCIL  OF GOV NC         12/28/87
MISSISSIPPI (STATE OF)                  01/21/88
JEFFERSON CO DEPT OF HEALTH AL       01 -21 '88
MOREHEAD CITY NC                     01/21/88
RICHLAND COUNTY SC                  01/26/88
KENLEY NC                            02/03/88
HICKORY NC                           02/05/88
CALERA AL                            02/05/88
SALISBURY                            02/09/88
MERIDIAN MS                          02/09/88
LIVERMORE KY                         02/09/88
SARATOGA NC                         02'09/88
WESTERN KENTUCKY UNIV KY            02/17/88
METRO  DADE COUNTY FL                02/17/88
ENFIELD NC                            02/18/88
NC DEPT NAT RES & COMM DEV NC       03/02/88
DORCHESTER CO SC                    03/09/88
NORTH CAROLINA (UNIV OF) NC           03/09/88
DURHAM NC                           03/09/88
KNOXVILLETN                          03'18/88
TOTAL OF REGION 04  =  146

SAG IN AW CO Ml (CY 86)                  10/03/87
SAGINAW CO Ml (CY 86)                  10/03/87
KENT CO Ml (CY 86)                      10/03/87
KENT CO Ml (CY 86)                      10/03/87
LORAIN  OH (CY 85)                      10/03/87
LORAIN  OH (CY 85)                      10/03/87
AKRON OH (CY 86)                      10/07/87
AKRON OH (CY 86)                      10/07/87
RANTOUL IL (FY 87)                      10/07/87
RANTOUL IL (FY 87)                      10/07/87
COLUMBIA IL (FY 87)                     10/16/87
COLUMBIA IL (FY 87)                     10/16/87
PERU IL (FY 87)                         10/16/87
PERU IL (FY87)                         10/16/87
MORRIS IL (FY 87)                       10/16/87
MORRIS IL (FY 87)                       10,16/87
GREENWOOD IN (CY 86)                  10/16/87
GREENWOOD IN (CY 86)                  10/16/87
ALBERTVILLE MN (CY 86)                 10/16/87
THIENSVILLE Wl (CY 86)                  10/21/87
CAIRO IL (FY 87)                         10/21/87
CAIRO IL (FY 87)                         10/21/87
SCHERERVILLE IN (CY 86)                 10/26/87
SCHERERVILLE IN (CY 86)                 10/26/87
SHELBYVILLE IL (FY 87)                  10/26/87
SHELBYVILLE IL (FY 87)                  10/26/87
FARMER CITY IL (FY 87)                  10/26/87
SAGINAW TWP SAGINAW Ml (FY  87)       10/26/87
HARBOR BEACH Ml (FY 87)               10/26/87
CHESTERTON IN (CY 86)                  10/27/87
CHESTERTON IN (CY 86)                  10/27/87
PETERSBURG IN (CY 86)                  10/30/87
C3EC8050064-80153
C3FC8050091-80154
C3EC8050067-80155
C3FC8050068-80156
C3EC8050072-80168
C3FC8050073-80169
C3EC8050076-80170
C3FC8050077-80171
C3EC8050078-80172
C3FC8050079-80173
C3EC8050060-80212
C3FC8050061-80213
C3EC8050074-80214
C3FC8050075-80215
C3EC8050096-80217
C3FC8050097-80218
C3EC8050100-80219
C3FC8050101-80220
C3EC8050071-80238
C3EC8050088-80239
C3FC8050089-80240
C3EC8050092-80241
C3FC8050093-80242
C3EC8050094-80243
C3FC8050095-80244
C3EC8050098-80249
C3FC8050099-80250
C3EC80501 02-80251
C3FC80501 03-80252
C3EC8050104-80253
C3FC80501 05-80254
C3EC80501 06-80255
C3FC8050107-80256
C3EC8050110-80257
C3FC8050111-80258
C3EC8050114-80259
C3FC8050115-80260
C3EC8050117-80261
C3FC8050118-80262
C3EC80501 20-80263
C3FC80501 21-80264
C3EC8050122-80265
C3EC8050083-80277
C3FC80501 24-80278
C3EC8050146-80319
C3FC8050109-80320
C3EC80501 47-80321
C3FC80501 57-80322
C3EC8050156-80323
C3EC8050161-80336
C3EC8050162-80341
C3EC8050169-80391
C3EC8050177-80392
C3EC8050178-80393
C3EC8050182-80394
C3EC8050173-80412
C3FC80501 74-80413
C3EC8050181-80429
C3EC8050165-80463
C3FC8050166-80474
C3EC8050168-80475
C3FC8050313-80476
C3EC8050185-80477
C3EC8050188-80478
C3FC8050195-80485
C3EC8050197-80486
C3FC8050198-80487
C3EC8050203-80523
C3FC8050204-80524
C3EC8050208-80526
C3EC8050218-80553
C3EC8050219-80554
C3FC8050220-80555
C3EC8050228-80556
C3EC8050229-80557
C3EC8050223-80596
C3EC8050233-80597
C3EC8050236-80619
C3EC8050237-80620
C3EC8050242-80621
C3EC8050244-80622
C3FC8050245-80623
C3EC8050251-80661
C3EC8050256-80682
C3EC8050257-80683
C3EC8050258-80705
C3EC8050260-80706
C3EC8050261-80707
C3FC8050262-80708
C3EC8050263-80709
C3EC8050274-80710
C3FC8050275-80711
C3EC8050123-80739
C3FC8050311-80740
C3EC8050131-80787
C3EC8050295-80789
C3EC8050297-80790
C3EC8050298-80791
C3FC8050299-80792
WIXOM Ml (FY 87)                       11/02/87
WIXOM Ml (FY 87)                       11/02/87
BRIGHTON Ml (FY 87)                    11,02'87
BRIGHTON Ml (FY 87)                    11/02/87
ADDISON IL (FY 87)                      11/05/87
ADDISON IL (FY87)                      11/05/87
MICHIGAN CITY IN (CY 86)                11/05/87
MICHIGAN CITY IN (CY 86)                11,05/87
NAPPANEE IN (CY 86)                    11 '05/87
NAPPANEE IN (CY 86)                    11/05/87
KALAMAZOO Ml (CY 86)                  11/12/87
KALAMAZOO Ml (CY 86)                  11,12/87
JORDAN MN (CY 86)                     11/12/87
JORDAN MN (CY 86)                     11'12'87
AUBURN IN (CY 86)                      11'13'87
AUBURN IN (CY 86)                      11'13<87
BRAZIL IN (CY86)                       11/13/87
BRAZIL IN (CY86)                       11/13/87
MWCC ST PAUL MN (CY 86)              11/19/87
DELTA TWP LANSING Ml (CY 86)          11/19/87
DELTA TWP LANSING Ml (CY 86)          11/19/87
TELL CITY IN (CY 86)                     11/19/87
TELL CITY IN (CY 86)                     11/19/87
FT WAYNE IN (CY 86)                    1M9'87
FT WAYNE IN (CY 86)                    11'19'87
HIGHLAND IN (CY 86)                    11/21 87
HIGHLAND IN (CY 86)                    11/21-87
BATESVILLE IN (CY 86)                   11/21/87
BATESVILLE IN (CY 86)                   11/21 '87
HAMMOND IN (CY 86)                   11/21/87
HAMMOND IN (CY 86)                   11/21/87
BROWNSBURG IN (CY 86)                11/21/87
BROWNSBURG IN (CY 86)                11/21/87
GREENCASTLE IN (CY 86)                11/21 '87
GREENCASTLE IN (CY 86)                11/21/87
LOWELL Ml (FY 87)                      11/21/87
LOWELL Ml (FY 87)                      11/21/87
PARIS IL (FY 87)                         11/21/87
PARIS IL (FY 87)                         11/21/87
WABASH  IN (CY86)                      11/21/87
WABASH  IN (CY 86)                      11/21/87
DECATUR SD IL (FY 87)                   11/21-87
MADISON IN (CY 86)                     11/25/87
MADISON IN (CY 86)                     11/25/87
WILLOUGHBY OH (CY 86)                12/09/87
WILLOUGHBY OH (CY 86)                12/09/87
ST JOSEPH MN (CY 86)                   12/09/87
KANKAKEE IL (FY 87)                     12/09/87
KANKAKEE IL (FY 87)                     12/09/87
MUSKEGO Wl (CY86)                    1214/87
GENESEO IL (FY 87)                      12/15/87
SALINE Ml (FY 87)                       01/04/88
GROVE CITY OH (CY 86)                  01/04/88
OTTER TAIL LAKES SD MN  (CY 86)         01/04/88
OGDEN IL (FY 86)                       01/04/88
SPRINGFIELD IL (FY 87)                   01/06/88
SPRINGFIELD IL (FY 87)                   01/06/88
GALLIPOLIS OH (CY 86)                  01/13/88
GRAND RAPIDS Ml (FY 86)                01/20/88
GRAND RAPIDS Ml (FY 86)                01/21/88
ROSCOMMON CO Ml (CY 86)             01/21/88
RACINE Wl (CY86)                      01/21/88
W CHICAGO  IL (FY 87)                   01/21/88
MOKENA IL (FY87)                      01/21/88
NEW HAVEN IL (FY 87)                   01/21/88
FERGUS FALLS MN (CY 86)               01/21/88
FERGUS FALLS MN (CY 86)               01/21/88
BLOOMINGTON IN (CY 86)                01/28/88
BLOOMINGTON IN (CY 86)                01/28/88
FORTVILLE IN (CY 86)                    01/28/88
CUYAHOGA FALLS OH (CY  86)             02/03/88
MONON IN (CY 86)                      02/03/88
MONON IN (CY 86)                      02/03/88
WESTFIELD IN (CY 85)                   02/03/88
WESTFIELD IN (CY 86)                   02/03/88
DOVER OH (CY 86)                      02/10/88
PLANO IL (FY 87)                        02/10/88
BURTON Ml (FY 87)                      02/17/88
TAYLORVILLE SD IL (FY 87)               02/17/88
IRONTON OH (CY 86)                    02/17/88
LANSING  Ml (FY87)                      02/17/88
LANSING  Ml (FY87)                      02/17/88
ROCKY RIVER OH (CY 86)                02/23/88
NEENAH-MENASHA Wl (CY 85)            02/25/88
NEENAH-MENASHA Wl (CY 86)            02/25/88
CARVER CO MN (CY 86)                  03/01/88
TUSCOLA CO Ml (CY 86)                 03/01/88
TUSCOLA CO Ml (CY 86)                 03/01/88
OLNEY IL(FY87)                        03/01/88
OLNEY IL (FY 87)                        03/01/88
OWENDALE Ml (FY 87)                   03/01/88
OWENDALE Ml (FY 87)                   03/01/88
STEEN MN (CY 85/86)                    03/10/88
STEEN MN (CY 85/86)                    03/10/88
GLENWOOD  MN (CY 86)                 03/19/88
FAiRMOUNT  IN (CY 85)                   03/19/88
TREMONT IL (FY 87)                     03/19/88
WARREN  OH (CY 86)                     03/19/88
WARREN  OH (CY 86)                     03/19/88
                                                                                                                                     35
-------
 Audit Control Number
                               Auditee
                                                 Final Report Issued
                                                                      Audit Control Number
                                                                                                    Auditee
                                                                                                                       Final Report Issued
C3FC8050289-80795
C3EC8050295-80828
C3EC8050300-80829
C3EC8050317-80830
C3FC8050312-80831
D3DW7050781-80008
D3DW8050253-80653
H3CB8050207-80525
H3CB8050224-80527
H3CB8050252-80662
N3GC7050562-80012
N3GC7050612-80065
N3GC7050423-80089
N3GC7050758-80090
N3GC7050718-80216
N3GC8050028-80247
N3GC8050036-80390
N3GC7050713-80395
N3GC7050814-80396
N3GC8050158-80551
N3GC8050176-80552
N3GC7050759-80570
N3GC8050081 -80595
N3GC8050186-80660
N3GC8050250-80681
N3GC8050254-80704
N3GC8050246-80788
N3GC8050277-80826
N3GC7050294-80827
C3EG8060035-80135
C3EG8060036-80141
C3EG8060039-80161
C3EG8060040-80167
C3EG8060044-80245
C3EG8060048-80304
C3EG8060047-80305
C3EG8060051-80329
C3EG8060052-80342
C3EG8060053-80350
C3EG8060054-80351
C3EG8060055-80352
C3EG8060056-80353
C3EG8060046-80403
C3EG8060060-80404
C3EG8060061-80405
C3EG8060064-80426
C3EG806Q067-80447
C3EG8060069-80453
C3EG8060080-80459
C3EG8060073-80488
C3EG8060075-80537
C3EG8060087-80685
C3EG8060088-80686
C3EG8060089-80687
C3EG8060093-80712
C3EG8060095-80727
C3EG8060097-80729
C3EG8060098-80730
C3EG8060099-80737
C3EG8060102-80746
C3EG8060103-80747
C3EG80601 04-80754
C3EG8060109-80806
N3GG8060019-80048
N3GG806Q020-80049
N3GG8060021-80050
N3GG8060022-80051
N3GG8060031-80095
N3GG8060032-80096
N3GG8060050-80328
N3GG8060065-80435
N3GG8060066-80436
N3GG8060078-80543
N3GG8060079-80544
N3GG8060080-80545
C3FC8050189-80479
C3FC8050190-80480
C3EC8050191-80481
C3EC8050192-80482
C3FC8050193-80483
C3EC8050194-80484
N3GG8060085-80667
N3GG8060086-80668
N3GG8060091-80693
N3GG8060096-80728
N3GG8060100-80744
N3GG8060101-80745
N3GG8060113-80840
N3GG8060110-80841
P3BW7060138-80738
C3GG8070017-80047
C3EG8070035-80134
C3EG8070042-80159
C3EG8070046-80160
C3EG8070047-80165
WAUKEGAN IL (FY 87)                   0322-88
BRUNSWICK CITY SD OH (FY 867)         03/25 88
THORN CREEK SD IL (FY 87)              0325,88
CANTON OH (CY 86)                    03'24'88
CANTON OH (CY 86)                    03 25/88
SPAULDING DEDECKER (CY 78/85)         10/03,87
GREELEY & HANSEN IL (FY 85)            02,22 88
BALL ST U  IN (FY 86)                    01 28'88
BALL ST U  IN (FY 86)                    01,2888
LOYOLA U  IL (FY 86,87)                  02,23,88
WALKERTON IN (FY 85)                  10'03,'87
WISCONSIN DOHSS (FY 86)              10'16/87
MUSKEGON CO Ml (CY 85)               10/21/87
MUNCIE IN (CY85)                      10'21/87
SPEEDWAY IN  (CY 86)                   11'13'87
S LYON Ml (FY 87)                      11 '21 '87
MUSKEGON CO Ml (CY 86)               01 '04/88
MARQUETTE CO Ml (CY 86)              01 '04/88
EAU CLAIRE Wl (CY 86)                  01 '04/88
GARY IN (CY 86)                        02-'03/88
TOLEDO OH (CY 86)                    02 03'88
MN CHIPPEWA TRIBE (FY 86)             02/08/88
WHITE EARTH  RESERVE MN  (FY 86)       02-10 88
CLEVELAND OH (CY 86)                  02/23/88
CHICAGO IL (CY 86)                     0275/88
LICKING CO OH (CY 86)                  03'01'88
MICHIGAN  DNR Ml  (FY 83/85)            03/19/88
OAKLAND CO Ml (CY 86)                 03'25/88
NEW CASTLE IN (CY 85)                  03-25/88
TOTAL OF REGION  05 =  171

BRAZORIA  COUNTY  FRESH WATER TX     10-27/87
HONDO TX                            10/28/87
GAINESVILLE TX                       11/03'87
KENNEDALETX                        11 05/87
MOORE OK                           11,-20-87
COOPER TX                           12/04/87
LAS CRUCES NM                       12/04/87
BILLINGS OK                          12/11'87
WESTWEGO LA                        12/15/87
MERIDIAN TX                          12/21/87
SEARCY WATER & SEWER SYSTEM AR     12/21/87
PINEHURSTTX                        12/21/87
CENTERVILLE TX                       12/21/87
SULPHUR LA                          01'05/88
LYTLE TX                             01 /05/88
LAKE CHARLES LA                      01/05/88
HARRIS COUNTY MUD NO 50 TX         01/12-88
ADRIAN TX                            01/19/88
CLUTETX                             01/20'88
EL PASO WATER UTILITIES TX            01/21-88
POTEETTX                            01/21/88
LEAGUE CITY TX                       02'01-88
HEBER SPRINGS W&S DEPT AR           02/24/88
LAKE CITIES MUNICIPAL UTILIT T         02/25/88
STRUCTURAL PEST CONTROL BOARD     02/25/88
PARISH OF POINTE COUPEE SD2A L       03/01 '88
QUITMAN TX                          03/02/88
CEDER PARK TX                       03/08/88
TALIHINA OK                          03/08/88
KILGORE TX                           03-09/88
MIDWEST CITY OK                     03/11/88
TEXAS WATER DEVELOPMT BOARD TX     03/11/88
TALIHINA OK                          03/15/88
BRAZOS RIVER AUTHORITY TX           03-23-88
AFTON OK                            10/13/87
OKLAHOMA CITY OK                   10/13/87
BATON ROUGE LA                      10-13'87
NATURAL RESOURCES DEPT NM         10-13/87
FAYETTEVILLE AR                      10/22-87
ALBUQUERQUE NM                    10/22,87
TAOS NM                             12(11.87
PORT ARTHUR TX                      0115'88
FORT WORTH  TX                      01/15/88
EL PASO TX                           02/03/88
DALLAS TX                           02/03/88
TERREBONNE PARISH CONSOL GVT L     02'03/88
MOKENA IL (FY87)                     01'21/88
ELYRIA OH (CY 86)                     01/21/88
ELYRIAOH (CY86)                     01/21/88
BREMEN IN (CY 85)                     01/21/88
BREMEN IN (CY 85)                     01-21/88
NEW HAVEN IL (FY 87)                  01,21/88
DEPARTMENT OF HEALTH               02/23/88
MONROE LA                          02/23/88
STATE OF LOUISIANA LA                02/29/88
ASSOCIAT OF  CENTROL OK GOVTS       03/08/88
FARMINGTON NM                      03/11/88
TULSA OK                             03/11/88
OSAGE OK                            03/30/88
TEXAS WATER COMMISSION TX          03/30/88
NEW MEXICO ENVIRON IMPROV DIV      03/09/88
 TOTAL OF REGION  06 = 56

DUBUQUE IA                          10/13/87
SEDALIA MO                          10/27/87
WEST DES MOINES IA                  11/02/87
SPRINGVILLE IA                       11/02/87
JOPLIN MO                           11/05'87
C3EG8070048-80166
C3EG8070056-80354
C3EG8070059-80406
C3EG8070060-80407
C3EG8070063-80430
C3EG8070068-80460
C3EG8070069-80461
C3EG8070070-80462
C3EG8070071-80516
C3EG8070072-80534
C3EG8070073-80617
C3EG8070077-80651
C3EG8070078-80654
C3EG8070083-80676
C3EG8070081-80678
C3EG8070082-80679
C3EG8070084-80680
C3EG8070086-80692
C3EG8070087-80694
C3EG8070088-80695
C3EG8070089-80719
C3EG8070090-80720
C3EG8070092-80741
C3EG8070093-80742
C3EG8070101-80835
C3EG8070104-80849
H3CU8070097-80847
N3GG8070032-80097
N3GG8070033-80098
N3GG8070034-80099
N3GG8070040-80157
N3GG8070041-80158
N3GG8070053-80327
N3GG8070079-80666
N3GG8070085-80688
N3GG8070099-80844
N3GG8070096-80846
C3EG8080001-80001
C3EG8080007-80084
C3EG8080009-80129
C3EG8080011-80146
N3GC8050029-80248
N3GC7050748-80276
N3GC8050112-80318
N3GC8050129-80335
N3GC7050689-80337
C3EG8080023-80300
C3EG8080027-80346
C3EG8080029-80374
C3EG8080033-80400
C3EG8080035-80438
C3EG8080034-80439
C3EG8080041-80508
C3EG8080045-80567
C3EG8080046-80575
C3EG8080047-80576
C3EG8080054-80671
C3EG8080066-80856
H3BH8080005-80082
H3BH8080006-80083
H3BH8080012-801 63
H3BH8080036-80454
H3BH8080063-80807
H3BH8080064-80839
N3GG8080003-80038
N3GG8080004-80064
N3GG8080008-80128
N3GG8080010-80144
N3GG8080014-80223
N3GG8080016-80235
N3GG8080017-80236
N3GG8080020-80272
N3GG8080025-80338
N3GG8080026-80339
N3GG8080028-80345
N3GG8080038-80489
N3GG8080039-80490
N3GG8080040-80491
N3GG8080042-80509
N3GG8080043-80510
N3GG8080044-80566
N3GG8080048-80604
N3GG8080050-80624
N3GG8080051-80644
N3GG8080053-80670
N3GG8080055-80696
N3GG8080056-80723
N3GG8080057-80749
N3GG8080060-80769
N3GG8080061-80770
N3GG8080067-80857
C3EG8090032-80164
C3EG8090049-80301
C3EG8090050-80302
C3EG8090053-80314
CEDAR RAPIDS IA
PAOLA KS
NEODESHA KS
MONONA IA
SIDNEY NE
BISMARK MO
BISMARCK MO
DOUGLAS COUNTY SID#135 NB
BONNER SPRINGS KS
SULLIVAN MO
CENTERVILLE IA
PERRYVILLE MO
GARNETT KS
NEW FRANKLIN MO
LAKE OZARK MO
RICHMOND MO
ST PAUL KS
HUTCHINSON KS
BRANSON MO
VANDALIA MO
ALLIANCE NE
EMPORIA KS
KAHOKA MO
KAHOKA MO
DOUGLAS COUNTY SID #135
EXCELSIOR SPRINGS MO
STATE UNIVERSITY IA
ST LOUIS MO
DAVENPORT IA
DEPT OF EDUCATION NE
JEFFERSON CITY MO
LEAVENWORTH KS
LINCOLN NE
UNIVERSITY OF MISSOURI MO
DES MOINES  IA
FREDERICKTOWN MO
LAWRENCE KS
TOTAL OF  REGION 07  = 42

NOME CITY OF ND
DRAKE CITY OF ND
MANDAN CITY OF ND
WATER & NATURAL RES DEPT OF SD
MIDDLETOWN OH (CY  86)
LAPORTE IN (CY 86)
BATTLE CREEK Ml (FY 87)
LAKEWOOD OH (CY 86)
HUTCHISON MN (CY 86)
ENVIRONMENTAL QUAL DEPT OF WY
LONGMONT CITY OF CO
MADDOCK CITY OF ND
CASSELTON CITY OF ND
DENVER METRO SWG  DD 1 CO
IDAHO SPRING CITY OF CO
CODY CITY OF WY
GILLETTE CITY OF WY
CASPER CITY OF WY
RIVERTON CITY OF WY
NEWCASTLE CITY OF WY
EVANSTON CITY OF WY
SO DAKOTA STATE UNIV SD
SO DAKOTA SCHOOL OF MINES SD
NORTH DAKOTA STATE UNIV ND
CASPER COLLEGE WY
NORTH DAKOTA UNIV OF ND
NORTH DAKOTA STATE UNIV ND
GRAND FORKS CITY OF ND
BILLINGS CITY OF MT
SIOUX FALLS CITY OF SD
UTAH STATE OF UT
AGRICULTURE DEPT OF ND
BISMARCK CITY OF ND
BISMARCK CITY OF ND
DELTA CITY OF CO
AGRICULTURE DEPT OF SD
LOWER BRULE SIOUX  TRIBE SD
SHERIDAN  COUNTY OF MT
WORLAND CITY OF WY
DENVER CITY & COUNTY OF CO
DURANGO CITY OF CO
OREM CITY OF UT
NORTH DAKOTA DEPT OF HEALTH ND
WESTMINSTER CITY OF CO
WYOMING DEPT OF HEALTH WY
COLORADO STATE OF CO
BOULDER CITY OF CO
WY DEPT OF  HEALTH & SOC SVCS
STERLING CITY OF CO
KALISPELL CITY OF MT
WELD COUNTY CO
RAPID CITY CITY OF SD
RAPID CITY CITY OF SD
OGLALA SIOUX TRIBE SD
TOTAL OF  REGION 08  = 49

TRACY CITY OF CA
CENTRAL CONTRA COSTA SD CA
NOVATO SANITARY DISTRICT CA
MONTEREY BAY UNIFIED APCD CA
11/0587
12/21/87
01/05(88
01/0588
01.-14 88
01/20,88
01/20-88
01/20/88
01 ''25/88
01/29,88
02,17/88
02,22,88
02'22/88
02/24,88
02 '25/88
02/24-88
02/25/88
02,26/88
02,29/88
02.79.88
03/04/88
03/04/88
03 10.88
03/09/88
03'28''88
03/30/88
03.30/88
1072/87
10 22.87
10/22/87
11 '02/87
11/02/87
12/11/87
02/23/88
02/25/88
03/30/88
03,30/88
10/02/87
10/20/87
10/26/87
10/29/87
11/21/87
11 /25/87
12/09/87
12/14/87
12/14/87
12/03/87
12/16/87
12/24-87
01/04/88
01/15-88
01/15/88
01/25/88
02/05/88
02/08/88
02/08'88
02/23-88
03/31-88
10/20-87
10/20-87
11/04/87
01/20/88
03/23/88
03/23-88
10/08/87
10/15/87
10'26/87
10/2987
11,1387
11-1887
11  1887
11/2387
12 14/87
12/14-87
12/1687
01/21/88
01/21'88
01/21 88
01/25/88
01/25'88
02/05/88
02/12/88
02/16/88
02/19/88
02/23-88
02/29-88
03/04/88
03/14/88
03/16/88
03/16/88
03/31/88
36
-------
 Audit Control Number
                              Auditee
                                                Final Report Issued
                                                                     Audit Control Number
                                                                                                  Auditee
                                                                                                                     Final Report Issued
C3EG8090056-80359
C3EG8080057-80360
C3EG8090059-80375
C3FG8090065-80411
C3EG8090074-80501
C3EG8090075-80502
C3EG8090078-80512
C3EG8090081-80577
C3FG8090085-80645
C3EG8090088-80648
C3FG8090096-80750
H3BH8090063-80402
H3BH8090064-80410
H3BH8090102-80808
N3GG8090017-80062
N3GG8090016-80063
N3GG8090019-80085
N3GG8090034-80273
N3GG8090043-80283
N3GG8090044-80284
N3GG8090045-80285
N3GG8090047-80294
N3GG8090048-80296
N3GG8090051-80313
N3GG8090054-80331
N3GG8090055-80340
N3GG8090058-80361
N3GG8090060-80384
N3GG8090062-80401
N3GG8090069-80455
N3GG8090070-80456
N3GG8090071-80457
N3GG8090073-80492
N3GG8090076-80503
N3GG8090077-80504
N3GG8090080-80568
N3GG8090082-80605
N3GG8090083-80625
N3GG8090084-80626
N3GG8090086-80646
N3GG8090087-80647
N3GG8090089-80672
N3GG8090093-80697
N3GG8090100-80774
N3GG8090101-80775
N3GG8090105-80859
C3EG8100001-80002
C3EG8100005-80087
C3EG8100010-80131
C3EG8100014-80274
C3EG8100016-80315
C3EG8100017-80344
C3EG8100020-80385
C3EG8100026-80458
C3EG8100030-80513
C3EG8100033-80569
C3EG8100035-80606
C3EG8100038-80627
C3FG8100040-80650
C3EG8100041-80673
C3EG8100043-80698
C3EG8100044-80699
C3EG8100045-80700
C3EG8100046-80701
C3EG8100047-80702
C3EG8100050-80751
C3EG8100051-80752
C3EG8100055-80810
C3EG8100058-80860
C3EG8100059-80861
N3GG8100002-80041
N3GG8100011-80145
N3GG8100015-80303
N3GG81 00024-80437
N3GG8100025-80440
N3GG8100027-80493
N3GG8100028-80505
N3GG8100029-80506
N3GG8100031-80531
N3GG8100032-80532
N3GG8100034-80578
N3GG8100036-80607
N3GG8100039-80649
N3GG8100048-80724
N3GG8100049-80725
N3GG8100052-80753
N3GG8100053-80776
N3GG8100054-80809
N3GG8100056-80811
CHINO BASIN MUNI WATER DIST CA       12<21 87
JACKSON CITY OF CA                   12-2187
GRASS VALLEY CITY OF CA              12'24;87
SANTA ANA WATERSHED PROJ CA        01 06'88
SOUTH EAST REG RECLAM AUTH CA       01'22 88
PINETOP-LAKESID SAN! DIST AZ           01 22 88
HENDERSON CITY OF NV                01,25-88
GOLETA SANITARY DIST CA              02/08 88
RANCHO CALIF WATER DIST CA          02-1988
GUSTINE CITY  OF CA                    02,19'88
PALO ALTO CITY OF CA                 03,1 4:88
CALIF UNIV OF-RIVERSIDE CA            01-04,88
CALIF AT SAN  DIEGO  UNIV OF CA         01,06:88
PIMA COUNTY COMM COLL AZ           03 23'88
MARICOPA COUNTY OF AZ              10,1487
SAN JOSE  CITY OF CA                  10/15,87
GUAMGOVTOF                        10'20'87
KINGS COUNTY OF CA                  11'23'87
LAKE COUNTY OF CA                   11 27'87
SAN BERNARDINO COUNTY OF CA        112787
VENTURA COUNTY OF CA                11'27'87
SACRAMENTO COUNTY OF CA            11:30'87
SAN FRANCISCO CITY & CTY CA          1201 '87
CLARK COUNTY HEALTH DIST NV          12 08'87
SANTA BARBARA CITY OF CA             12'10'87
SANTA BARBARA COUNTY OF CA          12 14:87
PETALUMA CITY  OF CA                  12/2V87
BOULDER CITY CITY OF NV              12<28'87
CHICO CITY OF CA                     01'04'88
KERN COUNCIL OF GOVTS CA             01 20'88
BURLINGAME CITY OF CA                01 20/88
NOGALES CITY OF AZ                   01'20/88
KAUAI COUNTY OF HI                   0121:88
SAN JOAQUIN  COUNCIL OF GOVTS        01 22/88
SAN CARLOS APACHE TRIBE AZ           01'22'88
QUECHAN  INDIAN TRIBE AZ              02'05'88
RENO CITY OF NV                      0212-88
PHOENIX CITY  OF AZ                    0216,88
CALIFORNIA STATE OF CA               0216:88
SAN DIEGO ASSOC OF GOVTS CA         02 1 9:88
SOUTHERN CA ASSOC OF GOVTS CA       0219:88
SANTA BARBARA CITY OF CA             0223,88
SANTA BARBARA CITY OF CA             02 29,88
FLAGSTAFF CITY OF AZ                  0316'88
CRESCENT CITY OF CA                  03'16,88
KAUAI COUNTY OF HI                   03,31,88
TOTAL OF  REGION 09 = 50


KETHCIKAN CITY OF AK                  100287
ENV CONSERVATION DEPT OF AK         1020 87
COLLEGE PLACE CITY OF WA             1026:87
LANE REG AIR  POLLUTION AUTH OR       11 23:87
MOSES LAKE IRRIG RHB DIS WA          12'08'87
CHELAN CITY OF WA                    121687
SILVERTON CITY  OF OR                 1228-87
TIETON TOWN  OF WA                  01 20:88
DAVENPORT CITY OF WA                01 25/88
RAYMOND CITY OF WA                  02'05'88
PAYETTE LAKES WATER & SEWER I        02 12'88
METROPOLITAN  PARK DISTRICT WA       02 16,88
SPRINGFIELD CITY OF OR                02,19,88
ESTACADA CITY OF OR                  02 23/88
TRI-CITY SERVICE DIST OR               02 29/88
CLACKAMAS CO  SVC  DIST #1 OR          02 29 88
DRAIN OR                             0229,88
METRO WASTEWATER MGMT COMM OR   02 29,88
SALMON CITY  OF ID                    02'29'88
FREMONT COUNTY OF ID                031488
COUER D'ALENE  CITY OF ID              031488
PETERSBURG CITY OF AK                0323,88
ENUMCLAW CITY OF WA                03'31 88
FAIRBANKS NORTH STAR AK             03 31,88
ANCHORAGE MUNICIPALITY OF AK        10 08,87
JUNEAU CITY & BOROUGH AK            10,2987
WASHINGTON  STATE  UNIV WA            12 03:87
DEPARTMENT OF EDUCATION AK          01,15'88
SHOSHONE-BANNOCK TRIBES ID          011588
EUGENE CITY OF OR                    01 21 88
KLAMATH FALLS CITY OF OR             01 22'88
BUHL CITY OF  ID                       01 22'88
OLYMPIA CITY  OF WA                   01'28'88
YAKIMA  CITY OF  WA                    01 28'88
TACOMA CITY OF WA                   02,0888
KING COUNTY WA                      0212-88
POCATELLO CITY OF ID                  0219'88
SPOKANE COUNTY OF WA               03;04'88
LEWISTON CITY OF ID                   03'04'88
COLVILLE CONFED TRIBE WA             03 14'88
YAKIMA COUNTY OF WA                 03 16/88
SEATTLE CITY OF WA                    03 23'88
SPOKANE CITY OF WA                  03 23'88
TOTAL OF  REGION 10 = 43
5. SUPERFUND GRANT & INTERNAL AUDITS

E5EH7020217-80664
E5EH7050566-80330
E5EE8090018-80838
E5E47090225-89000
           REGION II-BOSSERT MFG NY
            TOTAL OF REGION 02 = 1

           SITE REV CAM OR
            TOTAL OF REGION 05 - 1

           CAPPING REPORT SUPERFUND CA
           EPA R-9 OSC REVIEW CA
            TOTAL OF REGION 09 = 2
M5BH8110032-80571
M5BG8110040-80781
M5BH8110027-80803
P5EH7110022-80028
P5EH8110035-80608
P5EH8110036-80611
P5EH7110034-80612
P5EH8110034-80633
           SF IAG-COMMERCE
           SF-IAG AIDEX SITE
           SUPERFUND IAGS WITH DOT
           SF FY1986 AUDIT
           REGION 3 ADJUSTED SF PC&B COST
           REGION 3 SF INDIRECT COST RATE
           REGION 4 ADJUSTED SF PC&B COST
           REGION 4 SF INDIRECT COST RATE
         TOTAL OF HEADQUARTERS = 8
TOTAL SUPEPFUND GRANT & INTERNAL AUDITS
                                                  - 12
8. OTHER CONTRACT AUDITS
D8AT8020042-80210
D8AT8020043-80211
D8CT8020115-80528
D8CT8020116-80529
D8CT8020125-80636
D8AT8030019-80030
D8AT8030020-80032
D8AT8030021-80033
D8AT8030027-80058
D8CT8030028-80059
D8AT8030029-80060
D8AT8030030-80061
D8AT8030033-80081
D8AT8030035-80132
D8AT8030036-80133
D8AT8030042-80231
D8AT8030043-80232
D8AT8030046-80280
D8AT8030047-80281
D8CT8030070-80422
D8CT8030071-80423
D8DT8030072-80424
D8CT8030073-80425
D8DT8030076-80431
D8AT8030086-80494
D8AT8030087-80495
D8AT8030088-80496
D8CT8030089-80507
D8AT8030097-80600
D8AT8030098-80601
D8CT8030099-80602
D8AT8030100-80603
D8CT80301 03-80609
D8AT8030104-80610
D8CT8030110-80663
D8CT8030111-80665
D8CT8030117-80703
D8DT8030142-80850
D8AT8040090-80306
D8AT8040094-80309
D8AT8040212-80786
P8CT60401 01-80077
D8AT7050797-80006
D8AT7050798-80007
D8AT705081 5-80013
D8AT7050802-80016
D8AT7050817-80017
D8AT7050831-80094
D8AT8050030-80118
D8AT8050031-80119
D8AT8050037-80120
D8BT8050132-80266
D8AT8050130-80267
D8BT8050134-80268
D8AT8050127-80269
D8BT8050133-80270
D8BT8050247-80652
D8CT8050278-80717
H8CT8050235-80558
                TOTAL OTHER GRANT AUDITS = 706
           ECOLOGY & ENVIRONMENT NY
           ECOLOGY & ENVIRONMENT NY
           BURNS & ROE NJ
           BURNS & ROE NJ
           MATHTECH INC NJ
            TOTAL OF REGION 02 = 5

           DYNAMAC CORPORATION-MD
           GANNETT FLEMING ENVIRO-PA
           SRA TECHNOLOGIES INC-VA
           AUTOMETRIC SERVICES COMPANY-VA
           DYNAMAC CORPORATION/MD
           PACIFIC ENVIRONMENTAL SERV-VA
           PACIFIC ENVIRONMENTAL SERV-VA
           AMERICAN SCIENTIFIC INTER-VA
           NATIONAL INSTITUTE FOR DISP-DC
           AMERICAN SCIENTIFIC INTER-VA
           BIONETICS CORPORATION-VA
           BIONETICS CORPORATION-VA
           WAPORA INC-VA
           RONSON MANAGEMENT CORP-VA
           GANNETT FLEMING ENVIRO ENG-PA
           DYNAMAC CORPORATION-MD
           CRCS INCORPORATED-MD
           GANNETT FLEMING ENVIRO ENG-PA
           ENERGY & ENVIRO ANALYSIS-VA
           POLICY PLANNING & EVAL-VA
           JACA CORPORATION-PA
           GREELEY-POLHEMUS GROUP INC-PA
           GANNETT FLEMING ENVIRO ENG-PA
           INFO SYSTEMS & NETWORK COR-MD
           KAAREN JOHNSON ASSOCIATES-MD
           BIONETICS CORPORATION-VA
           KAAREN JOHNSON ASSOCIATES-MD
           DYNAMAC CORPORATION-MD
           ROY F WESTON INC -PA
           WESTINGHOUSE ELECTRIC CORP-PA
           WESTINGHOUSE ELECTRIC CORP-PA
           DYNAMAC CORPORATION-MD
           ODD COMPANY-MD
           TOTAL OF REGION 03 = 33

           UNITED TECHNOLOGIES FL
           NORTHROP SERVICES INC NC
           RESEARCH AND EVALUATION NC
           IT CORPORATION TN
           TOTAL OF REGION 04 = 4

           AT KEARNEY CHICAGO IL
           BMI COLUMBUS OH
           AT KEARNEY CHICAGO IL
           BMI COLUMBUS OH
           ARTHUR ANDERSEN & CO
           AT KEARNEY CHICAGO IL
           COLEJON MECH CORP OH
           LIFE SYSTEMS INC OH
           LIFE SYSTEMS INC OH
           LIFE SYSTEMS INC OH-LABOR
           LIFE SYSTEMS INC OH
           LIFE SYSTEMS INC OH-LABOR
           JOHN MATHES & ASSOC
           LIFE SYSTEMS INC OH-LABOR
           AT KEARNEY CHICAGO IL
           MITTELHAUSER CORP
           CINCINNATI U OF OH
           TOTAL OF REGION 05 = 17
                                                        02-23'88
                                                        12 10/87
03,29/88
12:30/87
02/05:88
03:18/88
03/22/88
10:08:87
02,16/88
02,16/88
02/16'88
02/17/88
10,08/87
10,08/87
10/08/87
10/15/87
10,1 5/87
10,15/87
10/15/87
10,20/87
10/27-87
1027/87
11 18/87
11:18/87
11 25/87
11 25,87
01,11/88
01 11/88
01,11/88
01'11-88
01 14/88
01,22'88
01 22'88
01,22/88
01,25/88
02 12/88
02/12/88
02/12/88
02/12/88
02-16/88
02,16/88
02'23/88
02/23/88
03:01,88
03 30/88
10/03/87
10/03/87
10/03/87
10/03/87
10/03:87
10/21/87
10/26/87
10/26/87
10/26/87
11 -23/87
11 -23/87
11 ,'23/87
11 '23/87
11 '23/87
02/22/88
03/03/88
02/03/88
                                                                                                                                37
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  Audit Control Number
                               Auditee
                                                 Final Report Issued
  D8AT8060015-80000
  D8CT8060077-80542
  D8CT8060107-80800
  D8CT8060108-80801
  D8AT8070076-80618
  D8CT8070080-80675
  H8AT8080018-80237
  D8AT8090012-80003
  D8AT8090013-80004
  D8AT8090014-80039
  D8AT8090015-80040
  D8AT8090031-80162
  D8AM8090046-80295
  D8AT8090052-80312
  D8AT8090067-8041 7
  D8BT8090066-80419
  D8BT8090079-80540
  D8DT8090090-80689
  D8CT8090091-80690
  D8AT8090092-80691
  D8CT8090094-80721
  D8AT8090095-80722
  D8AT8090097-80771
  D8CT8090098-80772
  D8AT8090099-80773
  D8AT8090103-80834
  D8CT8090104-80858
     LEE WILSON & ASSOCIATES INC N
     SOUTHWEST RESEARCH INSTITUTE T
     RADIAN CORPORATION TX
     RADIAN CORPORATION TX
      TOTAL OF REGION 06  = 4

     MIDWEST RESEARCH INSTI  MO
     MIDWEST RESEARACH INSTITUTE MO
     TOTAL OF REGION 07-2

     COLORADO STATE UNIV CO
      TOTAL OF REGION 08  = 1

     ENV MONITORING & SVCS CA
     SCI APPLICATIONS INC CA
     AQUA TERRA CONSULTANTS CA
     ENV MONITORING & SVCS INC CA
     DAMES & MOORE CA
     ROCKWELL INTL CORP CA
     JONES & STOKES ASSO INC CA
     WESTEC  SERVICES INC VA
     LOCKHEED  ENG  & MGMT SVCS TX
     LOCKHEED  ENG  & MGMT SVCS CO TX
     BECHTEL GROUP INC CA
     TRW INC SPACE  & TECH GP CA
     WOODSIDE SUMMIT GROUP INC CA
     MIDWEST RSRCH INST MO
     IT CORP CA
     BECHTEL GROUP INC CA
     JM MONTGOMERY CONSUL ENG CA
     TETRA TECH INC CA
     BECHTEL GROUP INC CA
     SCS ENGINEERS  INC CA
     TOTAL OF REGION 09 = 20
  D8AT8100004-80086
  E8AX8100003-80275
  M8AT8100009-80130
     PTI ENV SVCS WA
     CH2M HILL INC OR
     BATTELLE PACIFIC NW LAB WA
     TOTAL OF REGION 10 = 3
TOTAL OTHER CONTRACT AUDITS = t
10/01'87
02 02'88
03/22'88
03 22-88
02,17/88
02'24;88
                                                         11 19-87
10,02/87
10/02/87
10 08'87
10-08/87
11 02/87
12 01'87
12'07'87
01'07'88
01'07'88
01'29/88
02 25 88
02 25,88
02/25/88
03,04/88
03 04/88
03 16/88
03 16,88
03 16/88
03 25/88
03'31,88
1020-87
11/25/87
10/26/87
  9. SUPERFUND CONTRACTS
  E9CT7040281-80836
                     HAZTECH GA
                      TOTAL OF REGION 04 = 1
  D9AT7050780-80009
  D9AT8050085-80174
  D9AT8050139-80246
  D9AT8050159-80298
  D9AT80501 54-80299
  D9AT8050170-80343
  D9AT8050231-80465
     PRC ENV MGMT INC IL
     RQAW ASSOCIATES IN
     WW ENG & SCIENCE Ml
     HUBBELL ROTH & CLARK Ml
     LIFE SYSTEMS INC OH
     ENGINEERS INT IL
     DONOHUE & ASSOC Wl
      TOTAL OF REGION 05-7
 TOTAL SUPERFUND CONTRACTS - 8
        TOTAL AUDITS  = 915
                                                         03/29/88
10 03'87
11 05'87
11 20/87
12 0287
12'03/87
12 16/87
01/20/88
        HDQ 771 - - REPORTS ISSUED BY TYPE AUDIT AND REGION
                SEMI-ANNUAL PERIOD ENDING  0331/88
38
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