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              United States
              Environmental Protection
              Agency
               Office of the
               Inspector General
November 1989
•Office of the Inspector General
              to the Congress
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              April 1,1989
                                                        
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Foreword
                                                   The future of our environmental health is dependent
                                                   upon the strength of environmental laws and our
                                                   success in attaining effective and efficient compliance
                                              with them, whether voluntary or enforced. The effects of
                                              the environmental problems we don't resolve now will be
                                              our legacy to generations to come This is the challenge
                                              facing the Environmental  Protection Agency If we do not
                                              aggressively enforce current laws  and regulations,  how can
                                              we expect that additional or stronger laws will make a
                                              difference, or that our citizens and the leaders of other
                                              countries will  take EPA's  role seriously
                                                The ultimate concern of the Office of Inspector General is
                                              to help the Administrator and Agency managers identify how
                                              the Agency can best apply its resources and authority for
                                              the greatest environmental protection During this
                                               amiannual reporting period we identified a significant  lack
                                               i enforcement of environmental laws and regulations  at
                                              uoth the Federal and State level in several critical  programs
                                              Many of the findings we have made during the last several
                                              years concerning  ineffective enforcement appear to be
                                              recurring, chronic or remain uncorrected
                                                This report highlights particular results from our audits,
                                              investigations, evaluations, and fraud prevention activities
                                              that we believe are significant  This report includes most of
                                              the new reporting requirements of the Inspector General Act
                                              Amendments of 1988, due for  full implementation  in the
                                              semiannual report for the period ending March 31, 1990 We
                                              have also included, for the first time, an Overview section
                                              identifying serious problematic  trends requiring management
                                              attention.
                                                We believe that the Environmental Protection Agency has
                                              both the leadership and the popular support to address the
                                              growing environmental challenges, but will need to get the
                                              most from its limited resources and hold those with
                                              delegated responsibility accountable  Realizing the enormity
                                              of the task, Agency managers are  increasingly relying on the
                                              OIG as  their eyes and ears to identify possible waste and
                                              abuse, and make  recommendations for improving
                                              operational performance The Office of Inspector General is
                                              committed to  the mission of the Agency and will continue
                                              working with Agency managers as both a watchdog and an
                                              advocate for efficient and effective environmental  protection
                                             John C. Martin
                                             Inspector General

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      Contents
Executive Summary
An Overview of EPA's Current Challenges
Overview of Significant Trends In EPA Concerning the OIG
Profile of Activities and Results
Establishment of the OIG in EPA—Its Role and Authority
Organization and Staffing
Purpose and Requirements of the OIG Semiannual Report
Section 1—Significant Problems, Abuses, and Recommendations
Summary of Audit Activities and Results
Agency Management.
Construction Grants
Superfund Program
Special and Prospective Reviews
Section 2—Audit Resolution
Overdue Audit Resolution
Audit Followup of Select Prior Significant Audits
Status of Management Decisions on OIG Audit Reports
Previously Reported Items—Action Not Completed
Action Officials for Audit Reports Outstanding More Than Six Months
Resolution of Significant Audits from Prior Periods
Section 3—Prosecutive Actions
Summary of Investigative Activity
Description of Selected Prosecutive Actions
Civil and Administrative Actions to Recover Funds
Section A—Fraud Prevention and Resource Management Improvements
Review of Proposed Legislation and Regulations
Suspension and Debarment  Activities
Employee and Public Awareness Activities
Personnel Security Program
President's  Council on Integrity and Efficiency
Committee  on Integrity and  Management Improvement
Hotline Activities
Professional and Organizational Development
Section 5—Delinquent Debts
Appendix—List of Audit Reports Issued
Page

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      Executive  Summary
Section 1—
Significant Problems,
Abuses, and
Recommendations
1. Improved Controls Are
Needed to Ensure Adequate
Penalties for Effective
Enforcement
EPA consistently failed to
maintain essential  records
supporting the basis for
enforcement decisions As a
result, there was little assurance
that penalties assessed by EPA
were equitable or sufficient to
deter violations of
environmental laws and
regulations (page 9)

2. Insufficient Penalties
Assessed Against RCRA
Violators
EPA personnel failed to adhere
to Agency policies and
procedures for assessing
penalties under the Resource
Conservation and Recovery Act
(RCRA)  Monetary  penalties
were not sufficient to eliminate
the economic benefits of
noncompliance or achieve
maximum deterrence (page 10)

3. Hawaii Grant Programs Did
Not Achieve Environmental
Goals
Region 9 did not effectively
monitor Hawaii's administration
of over $60 million of program
and construction grants
awarded during  fiscal years
1986 through  1988 (page  10)

4. Stronger Enforcement
Action Required by EPA and
States to Protect  the
Chesapeake Bay
EPA and the States of
Maryland, Pennsylvania, and
Virginia have not effectively
enforced the Clean Water Act
against polluters of the
Chesapeake Bay nor did the
States complete the required
actions to reduce the amount of
toxic pollutants entering the Bay
(page 11)

5. Management
Improvements Needed in the
Leaking Underground Storage
Tank (LUST) Program
EPA did not equitably distribute
LUST Trust funds to  States  that
were working  to solve LUST
problems States in Region 3
did not adequately monitor
progress of cleanups or
implement LUST programs to
protect human health (page 12)
6. Schools with More Serious
Asbestos  Hazards Could Have
Received EPA Funding
EPA needs to improve  its
management of the Asbestos
School Hazard Abatement Act
(ASHAA) loan  and grant program
so that needy local educational
agencies (LEAs) with the most
serious health hazards receive
assistance in financing  and
implementing their asbestos
abatement projects as quickly
as possible (page 12)

7. EPA and States in Regions
2 and 4 Were Not Enforcing
the Clean  Water Act
EPA and States in Regions 2
and 4  were not effectively
enforcing the Clean Water Act
against violations of National
Pollutant Discharge Elimination
System (NPDES) permits by
publicly owned treatment works
(POTW) (page 13)

8. Millions Questioned in
Massachusetts Construction
Grant Program
The Massachusetts Department
of Environmental Protection
(MA-DEP)  used grant assistance
funds  for program activities
outside the scope of  the
delegated  grant agreement with
EPA or contrary to EPA policy
(page  14)

9. Fort Pierce, Florida, Claims
Over $2.6  Million of
Questioned Costs
Fort Pierce, Florida, claimed
over $2 6 million of questioned
costs, including $1,795,789  of
ineligible costs for the
construction of a wastewater
treatment  plant that did not
serve  the planned service area
(page  15)

10.  Grantee Claimed Almost
$2.7 Million of Unnecessary
and Ineligible Costs
The Sonoma Valley County
Sanitation  District, California,
claimed $2,392,534 of ineligible
engineering costs,
administrative expenses, force
account costs, and other project
costs  The  grantee claimed an
additional $267,728 of
unnecessary engineering fees
(page 15)
11. Buffalo Sewer Authority,
New York, Claimed Over $1.6
Million of Ineligible and
Unsupported Costs
The Buffalo Sewer Authority,
New York, claimed $1,398,013
of ineligible construction costs,
design allowance fees,
architectural engineering fees,
and administrative expenses An
additional $285,178 of
unsupported costs were
questioned (page 15)

12. Grantee Claims Over $1.6
Million of Ineligible
Engineering Costs
The Carmel Sanitary District,
Carmel, California, claimed
$1,609,354 of ineligible
engineering design service
costs for an advanced
wastewater treatment plant not
approved for funding by EPA,
and claim negotiation costs
(page 16)

13. Vacaville, California,
Claims $1,358,553 of Ineligible
Costs
The city of Vacaville, California,
claimed $1,358,553 of ineligible
consulting engineering,
administrative, and construction
costs (page 16)

14. Inadequate Administration
and Coordination Impeded
Arkansas Cleanup
Inadequate administration and
coordination by EPA and
Arkansas  at sites in Jacksonville
and Fort Smith slowed cleanup
actions and increased cleanup
costs by $6 million (page 18 )

15. Inappropriate Contracting
and Oversight Resulted  in
Inefficient Cleanups in Ohio
and Indiana
A hazardous waste cleanup
contract awarded before the full
extent of  contamination at an
Ohio site was known was
insufficient, and another
contract was required to
complete the cleanup
Inadequately directed contractor
work violated asbestos cleanup
regulations at the Ohio site and
impeded enforcement efforts at
an Indiana site (page 18)

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16. EPA Had No Audit
Followup System To Assure
That Corrective Actions Were
Taken
EPA did not know if corrective
actions resulting from audit
recommendations were
completed or, if completed,
whether the deficiencies were
corrected (page 19 )

17. Over $2.9 Million Should
Not Have Been Awarded For  a
Milwaukee, Wisconsin Project
The site selected for a  dropshaft
to divert sewage costs over
$2 9 million more than  an
approved alternative site (page
20)

18. Grantee Receives  $1.6
Million Construction Grant
That Should Be Terminated
The Marina County Water
District,  Manna, California, was
improperly awarded a
construction grant to purchase
capacity rights  in the Monterey
regional wastewater treatment
facilities (page 20)
Section 2—
Audit Resolution

At the beginning of the
semiannual period, there were
369 audit reports for which no
management decision had been
made For the second half of
fiscal 1989, the  Office of
Inspector General issued 1,128
new audit reports of which 334
required resolution, and closed
343  At the end of fiscal 1989,
357 audit reports remained in
the Agency followup system for
which no management decision
had been made Of the 357
audit reports, 94 reports
remained in the Agency
followup system for which no
management decision was
made within  six months of
issuance which  included 21
preaward audits previously
excluded from overdue audit
reporting
  Of the 343 audits closed,
$16,8 million of questioned
costs were disallowed  for
recovery, and $56 8 million
which recommended that  funds
be put to better use were
agreed to by EPA management
In addition, cost recoveries in
current and prior periods
included $3 4 million in cash
collections, and at least $103
million in offsets against
billing (page 21)
Section 3—
Prosecutive Actions

During this semiannual reporting
period, our investigative effort
resulted in 21 convictions and
10 indictments  Also, this
semiannual period our
investigative work resulted in
over $1,340,000 in fines and
recoveries
  In a continuing investigation
into asbestos removal in the
New York metropolitan area, a
former EPA Region 2 asbestos
inspector pled guilty to
accepting bribes, 28 contractors
have now been  indicted and
$606,000 in fines assessed A
Connecticut asbestos contractor
and four of his employees pled
guilty to charges emanating
from the  use of  untrained and
uncertified workers in asbestos
removal The EPA Emergency
Response Cleanup Service Zone
2 contractor was charged with
submitting false claims to EPA
totalling almost  $178,000, and
was fired Three EPA
Headquarters employees were
sentenced for their roles in a
scheme to defraud AMTRAK
(page26)


Section 4—
Fraud Prevention
and Resource
Management

Review of Proposed
Legislation and Regulations
During this semiannual period,
we  reviewed 61  legislative and
regulatory items The most
significant were  the Consultant
Registration and Reform Act of
1988, the Consultant Disclosure
and Fraud Prevention Act of
1989, the Solid Waste Export
and Import Act of 1989, and a
revised draft civil penalty policy
under the Resource
Conservation and Recovery Act
(page 30)

Suspension and Debarment
Activities
We completed 93 cases during
this reporting period, resulting in
11 debarments,  2 voluntary
exclusions, 8 settlement
agreements, and 72 cases
closed after investigation There
were 222 active cases at the
close of this  reporting period
(page 31)
Committee on Integrity and
Management Improvement
Projects completed by this
Agency committee, which is
chaired by the Inspector
General, include guidelines to
assist employees in
safeguarding microcomputers,
workstations, and related
equipment, a leaflet which
describes methods for
detecting, curtailing, and
deterring telephone abuse, and
provides guidance on
permissible official business
calls, and an Awareness Bulletin
on Bribes and Gratuities which
outlines what an employee
should do when a bribe or
gratuity is offered (page 34)

Professional and
Organizational Development
The OIG-developed course,
Detection and Prevention of
Fraud, was presented once
through  the EPA Institute and
also in Memphis, Tennessee, to
members of our Southern Audit
staff, auditors from the
Tennessee State Comptroller's
office, and independent public
accountants performing audit
work for the OIG Another
OIG-developed course, Effective
Briefing Techniques, was
presented  once at OIG
Headquarters and once in
Boston to our Eastern and
Mid-Atlantic Audit staffs (page
35)

Human  Resources Council
EPA  Wei/ness Services, a
brochure developed by the OIG
Human Resources Council, was
distributed to all EPA
employees  It describes the
physical exam, counseling, and
fitness services available at
Headquarters and in each
Regional office (page 36)

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    An  Cverview  Of  EPA's Current Challenges
 When the Environmental
 Protection Agfency'(EPA) was
 established m\g?0, the most
 pressing environmental
 problems were the obvious
 ones: soot and smoke from
 cars and smokestacks, and raw
 sewage and chemicals from
 municipal and industrial
 wastewater. Congress has
 enacted a series of laws which
 have brought about significant
 environmental  improvements,
 though many challenging
 problems remain
  This section  highlights some
 of EPA's most significant
 challenges for  restoring and
 protecting the quality of the air
 we breathe,  the land where we
 live, and the water we depend
 on.

 LAND

 The principal sources of land
 waste are:

 • Underground Storage Tanks.
 An  estimated five  to six million
 underground storage tanks in
 use in the United States contain
 petroleum products or
 hazardous chemicals.
 Approximately  two million of
 these tanks may be leaking and
 are a source of land
 contamination that can
 contribute to ground-water
 contamination

 • Industrial Hazardous Wastes.
 The chemical, petroleum,
 metals, and transportation
 industries are major producers
 of hazardous industrial waste,
 such as, dioxm and benzene
 which are known carcinogen.

 • Municipal  Wastes Municipal
 wastes include household and
 commercial wastes, demolition
 materials, and sewage sludge.
 Solvents and other harmful
 household and  commercial
 wastes are generally so
 intermingled with other
 materials that specific control of
 each is virtually impossible.

• Mining Wastes.  A large
volume of all waste generated
 in the United States is from
 mining coal, phosphates,
copper, iron, uranium, and other
 minerals and from  ore
 processing and milling. Runoff
from these wastes increases
the  acidity of streams and
pollutes them with toxic metals.
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The Clean Air Act of 1970
requires EPA to set National
Ambient Air Quality Standards
for those pollutants, termed
"criteria pollutant," which pose
the greatest overall threat to air
quality: ozone, carbon
monoxide, airborne particulates,
sulfur dioxide, lead, and nitrogen
oxides.
  The act also requires EPA to
set National Emission Standards
for Hazardous Pollutants.
Hazardous pollutants are
defined as those that can
contribute to an increase in
mortality or serious illness.
  A major thrust of the next
decade will be to address
growing national and
international problems from acid
deposition and global  warming.

• Acid rain is now recognized
as a serious long-term air
pollution problem for many
industrial nations. The process
of acid rain deposition begins
with emissions of sulfur dioxide
(primarily from coal-burning
power plants) and nitrogen
oxides (primarily from motor
vehicles and coal-burning power
plants). These pollutants interact
with sunlight and water vapor in
the upper atmosphere to form
acidic compounds.
• Global Warming. Certain
types of air pollutants are
producing long-term and
perhaps irreversible changes to
the global atmosphere In  the
troposphere (the lower 10 miles
of atmosphere), high levels of
carbon dioxide are producing an
overall warming of the global
temperatures This greenhouse
effect may  cause irreversible
changes to  the climate and the
atmosphere's protection against
harmful ultraviolet radiation

WATER

The job of cleaning and
protecting the nation's drinking
water, coastal zone waters, and
surface waters is made complex
by the variety of sources of
pollution that affect them.

• Municipal Sources  Municipal
wastewater primarily from
toilets, sinks, showers, and
other uses which runs through
city sewers may be contaminated
by organic materials, nutrients,
sediment, bacteria, and  viruses.
Toxic substances used in the
home also make their way into
sewers

• Industrial Sources. The use of
water in industrial  processes,
such as the manufacturing of
steel or chemicals, produces
billions of gallons of wastewater
daily

• Nonpomt Sources  Nonpomt
sources of water pollution are
multiple, diffuse sources of
pollution as opposed to a single
"point" source such as  a
discharge pipe from a factory.
For example, rainwater washing
over farmlands and carrying top
soil and chemical residues into
nearby streams is a major
nonpomt source of water
pollution.

• Ocean Dumping. Dredged
material, sewage sludge, and
industrial wastes are a major
source of ocean pollution.
Sediments dredged from
industrialized urban harbors are
often highly contaminated with
heavy metals and toxic
synthetic organic chemicals like
PCBs and petroleum
hydrocarbons.

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   Overview  Of Significant  Trends  In EPA Concerning The  OIG
This is a new section of our
report presenting the Office of
Inspector General's perspective
on significant vulnerabilities
facing EPA  These items serve
to highlight  the crosscuttmg
problems the OIG believes must
be addressed for the Agency to
conduct its  programs and
operations in a more effective,
efficient, and economical
manner These trends were
derived from an overview of the
common or recurring conditions
identified by OIG audits,
investigations, and evaluations
reported in  this and prior
Semiannual Reports to
Congress.
Enforcement

Continued efforts must be
expended in ensuring the
effectiveness of the Agency's
enforcement efforts. Audits of
EPA's asbestos, water, air and
solid waste programs have
shown that improved systems
are needed to help identify
violators of environmental laws
and regulations. Once identified,
violators need to be dealt with
and brought into compliance
consistently, fairly, and quickly.
OIG reports demonstrate that
controls need to be in place to
ensure that penalties imposed
against violators are properly
calculated in accordance with
EPA policy and that adequate
justifications are documented to
explain the basis for any
reductions. Additionally, EPA
systems need to track
corrective actions required of
violators until full compliance is
obtained  Where violators do
not adhere to required actions
or achieve scheduled
compliance, further
enforcement action should be
taken expeditiously.
  Current EPA  management
acknowledges these problems
and has initiated necessary
actions to deal  with them.
Overall EPA has initiated penalty
actions resulting in record
penalty collections. The
Administrator has stressed the
need for more aggressive
enforcement efforts and the
Agency has initiated action to
deal with each  of the findings
raised in OIG reports While
only time will show the
adequacy of improvements
being made, the OIG will initiate
further audits during fiscal 1990
to assess the reasonableness of
fines and penalties in criminal
cases and the success of
bringing NPDES violators into
compliance.

Superfund

Significant actions are needed
to improve the  clean up of
Superfund sites. OIG audits
have shown a pattern of
recurring studies, partial
remedies and inadequate
involvement by community
representatives, responsible
parties, and State officials.
Without sufficient oversight by
qualified EPA staff, inadequate
work by various contractorsv'has
complicated the decision
process, impeded
implementation of cost effective
solutions and slowed necessary
cleanup.
  Upon arriving at EPA, the new
Administrator initiated a
comprehensive review of the
Superfund program which
examined virtually every
significant aspect of this $8 5
billion program  The resulting
report made numerous
recommendations necessary to
improve the program. During
the coming year, we plan to
monitor the implementation of
the Agency's recommendations
and assess the adequacy of
program improvements during
various audits of the Superfund
program

Contract and Grant
Administration

Continued EPA efforts are
needed to improve the
administration of various grants
and contracts used to carry out
Agency programs and
accomplish environmental
objectives. EPA depends, to a
great extent, on contractors and
various State and local
governmental entities to
perform much  of the nation's
environmental work.
Unfortunately OIG audits  have
frequently shown that EPA staff
responsible for providing
necessary oversight have not
had the appropriate experience,
training or interest to perform
this work effectively
Additionally, Agency officials
have not always ensured  that
Agency regulations were
followed or that projects were
directed toward accomplishing
their established goals. In some
instances Agency personnel
were having contractors or
subcontractors  perform work
before it was properly ordered
or funded by EPA  In some
cases scientific personnel were
required to perform
administrative tasks, inadequate
or incorrect technical guidance
was provided, and fees were
awarded for marginal or
inadequate contractor
performance.
  Over the last several years,
Agency management has
worked to improve contract and
grant management. Increased
resources have been provided
to the regions and needed
training has been given At the
same time the OIG is continuing
to perform audits and making
further recommendations to
improve this key area

Internal  Controls and
Financial
Management

Agency  reviews of internal
control and financial
management systems have not
always successfully identified
weaknesses in those systems.
For example, in some instances
significant findings resulting
from GAO or OIG audits were
not identified as internal control
weaknesses until after they
were found by the auditors
When they were identified,
such weaknesses were treated
as isolated instances applicable
only to the region or program in
which the audit was conducted.
Additionally, EPA management
stopped tracking the corrective
actions taken on GAO and OIG
findings during the last year and
a half while deciding what
improvements were needed in
their audit followup system
  OIG audits of various aspects
of the Agency's financial
management system repeatedly
identify significant deficiencies.
For example, reports  in the last
three years have reported
weaknesses in financial controls
and inaccuracies dealing with
cash disbursements,  excessive
letter of credit drawdowns,
errors in reported recoveries,
receivables, unliquidated
obligations and disbursements;
as well as inadequate records
and controls over property
management.
  In each of these instances
Agency  management has
concurred with the OIG's
findings and initiated  prompt
actions to correct the problems
During the  next few years we
intend to followup on the
identified problems to assess
the adequacy of corrective
actions and determine whether
further steps are needed to
improve internal controls and
financial management oversight.

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     Profile  Of Activities  And   Results
                                                       Fiscal
                                                       1989
Environmental Protection Agency
Office of Inspector General       April 1, to
 .  .. _      .                  September 30, 1989
 Audit Operations
 OIG MANAGED AUDITS
 Audits Performed by EPA, IPA and
 State
 Questioned Costs
 • Total Ineligible                     $39 5 Million      S 68 9 Million
 • Federal Share Ineligible*             $29 6 Million      S 53 2 Million
 • Total Unsupported*                 $35 5 Million      S 94 8 Million
 • Federal Share Unsupported*          $25 9 Million      $ 69 8 Million
 • Total Unnecessary/Unreasonable*     $ 0 8 Million      $  1 5 Million
 • Federal Share                      $ 0 6 Million      $  1 2 Million
 Unnecessary/Unreasonable*


 Recommended EfficienctesfFunds be Put to Better Use)
 • Total Efficiencies*                  $101  Million      $19 7 Million
 • Federal Share Efficiencies*           $ 5 3 Million      $ 10 7 Million


 Cost Disallowed to be Recovered
 • Federal Share Ineligible              $11 4 Million      $ 29 6 Million
 • Federal Share Unsupported           $ 3 2 Million      $  9 6 Million
 • Federal Share                      $ 1 3 Million      S  1 3 Million
 Unnecessary/Unreasonable
 (costs which EPA management
 agrees are unallowable and is
 committed to recover or offset
 against future payments)


 Cost Disallowed as Cost Efficiency
 • Federal Share Recommended         $35 1 Million      $ 36 8 Million
 Efficiencies
 (funds made available by EPA
 management's commitment to
 implement recommendations in OIG
 performance or preaward audits)


 OTHER AUDITS
 Audits Performed by another Federal Agency or Single Audit Act Audits
 Questioned Costs
 • Total Ineligible
 • Federal Share Ineligible*
 • Total Unsupported*
 • Federal Share Unsupported*
• Total Unnecessary/Unreasonable*
• Federal Share
Unnecessary/Unreasonable*
$ 3 6 Million
$ 3 2 Million

$ 0 1 Million
S 0 1 Million
$ 00 Million
$ 00 Million
4 9 Million
43 Million
1 6 Million
1 4 Million
0 0 Million
0 0 Million
Recommended Efficiencies(Funds be Put to Better Use)
                                   $265 Million
                                   $26 5 Million
 • Total Efficiencies*
 • Federal Share Efficiencies*


 Cost Disallowed to be Recovered
 • Federal Share Ineligible
 • Federal Share Unsupported
 • Federal Share
 Unnecessary/Unreasonable
 (costs  which EPA management
 agrees are unallowable and is
 committed to recover or offset
 against future payments)
                                   $ 04 Million
                                   $ 0 5 Million
                                   $ 00 Million
                $4188 Million
                $4188 Million
                   4 0 Million
                   0 5 Million
                   0 0 Million
                                                              April 1, to
                                                              September 30, 1989
                                                                   Cost Disallowed as Cost Efficiency
                                                                   • Federal Share Recommended        $21 7 Million
                                                                   Efficiencies
                                                                   (funds made available by EPA
                                                                   management's commitment to
                                                                   implement recommendations in OIG
                                                                   performance or preaward audits)


                                                                   AGENCY RECOVERIES
                                                                   Recoveries from Audit Resolutions of   $137 Million
                                                                   Current and Prior Periods
                                                                   (cash collections or offsets to future
                                                                   payments)**


                                                                   REPORTS ISSUED
                                                                   OIG MANAGED AUDITS

                                                                   • EPA Audits Performed                       44
                                                                   by the OIG

                                                                   • EPA Audits Performed by                     94
                                                                   Independent Public Accountants
                                                                   • EPA Audits Performed by  State               24
                                                                   Auditors

                                                                   OTHER AUDITS

                                                                   • EPA Audits Performed by                    205
                                                                   another Federal Agency
                                                                   • Single Audit Act Audits                     761
                                                                   TOTAL REPORTS ISSUED                    1,128
Audit Reports Resolved                       343
(agreement by Agency officials to
take satisfactory corrective action)


Investigative Operations
• Fines and Recoveries                 $1,347,114
(including civil)
• Investigations Opened                      126
• Investigations Closed                       135
• Indictments of Persons or Firms               10
• Convictions of Persons or Firms               21
• Administrative Actions Taken Against           12
EPA Employees


Fraud Detection and Prevention Operations
• Debarments, Suspensions, Voluntary           93
Exclusions, and Settlement
Agreements
(actions to deny persons or firms
from participating in EPA programs or
operations because of misconduct or
poor performance)
• Hotline Complaints Received                  36
• Hotline Complaints Processed and             37
Closed
• Proposed Legislative and Regulatory           61
Items  Reviewed
• Personnel Security Investigations              371
Adjudicated
                                                                   Fiscal
                                                                   1989
                                                                                    $ 246 Million
                                                                                    $ 300 Million
                                                                                             78


                                                                                            161


                                                                                             36




                                                                                            377


                                                                                          1,268
                                                                                           1,920
                                                                                                                               676
$1,927,251


      262
      274
       37
       37
       34
                                                                         166
                                                                          82
                                                                          72


                                                                         117


                                                                         600
Questioned Cost' Ineligible, Unsupported and Unnecessary/Unreasonable,  and Recommended Efficiencies (Funds be Put to Better Use)
are subject to change pending further review in the audit resolution process

** Information on recoveries from audit resolution is provided by the EPA Financial Management Division and is unaudited

Inspector General Act Amendments of 1988 (Public Law 100-504) have changed several categories in the IG's  report to Congress and
also require agency management to report directly to the Congress on their responses to audit recommendations. These requirements
are due for inclusion in the semiannual report for the  period ending March  31, 1990

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    Establishment Of  The  OIG  In  EPA—Its Role And Authority
The Inspector General Act of
1978 (Public Law 95-452), as
amended, created Offices of
Inspector General to consolidate
existing investigative and audit
resources in independent
organizations headed by
Inspectors General
  EPA established its Office of
Inspector General (OIG) in
January 1980 As an agency
with a  massive public works
budget, EPA is vulnerable to
various kinds of financial
abuses The OIG's role is to
review EPA's financial
transactions, program
operations, and administrative
activities, investigate allegations
or evidence of possible criminal
and civil violations, and promote
economic, efficient, and
effective Agency operations
The OIG is also  responsible for
reviewing  EPA regulations and
legislation
  The  EPA Inspector General
reports directly to the
Administrator and the Congress
and has the authority to

•  Initiate and carry out
independent and ob|ective
audits  and investigations,

•  Issue subpoenas for evidence
and information,

•  Obtain access to any
materials in the Agency,

•  Report serious or flagrant
problems to Congress,

•  Select and appoint OIG
employees,

•  Fill Senior Executive Service
positions,

•  Administer oaths, and

•  Enter into contracts
  The  Inspector General is
appointed by, and can be
removed only by, thePresident
This independence protects the
OIG from interference by
Agency management and allows
it to function as the Agency's
fiscal and operational watchdog

Organization
and Staffing

The Office of Inspector General
functions through three ma|or
offices, each headed by an
Assistant Inspector General
Office  of Audit, Office of
Investigations, and Office of
Management and Technical
Assessment
  Nationally, there are six
Divisional Inspectors General for
Audit and five  Divisional
Inspectors General for
Investigations who direct staffs
of auditors and investigators and
who report to the appropriate
Assistant Inspector General in
Headquarters

Purpose And
Requirements Of The
Office Of Inspector
General Semiannual
Report

The Inspector General Act of
1978 (Public Law 95-452), as
amended,  requires the Inspector
General to keep the
Administrator and Congress fully
and currently informed of
problems and deficiencies in  the
Agency's operations and to
recommend corrective action
The IG Act further specifies that
semiannual reports will be
provided to the Administrator by
each April 30 and October 31,
and to  Congress 30 days later
The Administrator may transmit
comments to Congress along
with the report, but may not
change any part of the report
  The specific reporting
requirements prescribed in the
 Inspector General Act of 1978,
 as amended, are listed below
 The Inspector General Act
 Amendments of 1988 require
 more detailed statistics on the
 status of audit reports, their
 recommendations and monetary
                results  Also, included are
                additional requirements resulting
                from Senate Report 96-829 on
                the Supplemental Appropriations
                and Rescission Act of 1980
                (Public Law 96-304)
Source
                               Section and Page
Inspector General Act, as amended
Section 4(a)(2), Review of Legislation and
Regulations
Section 5(a)(1), Significant Problems, Abuses,
and Deficiencies
Section 5(a)(2), Recommendations with Respect
to Significant Problems, Abuses,
and Deficiencies

4
1
1

30
8
8
Section 5(a)(3),




Section 5(a)(4),

Section 5(a)(5),


Section 5(a)(6),

Section 5(a)(7),

Section 5(a)(8),


Section 5(a)(9),



Section 5(a)(10),
Section 5(a)(11),


Section 5(a)(12),
Prior Significant
Recommendations on Which
Corrective Action Has Not Been
Completed

Matters Referred to Prosecutive
Authorities
Summary of Instances Where
Information Was Refused
List of Audit Reports

Summary of Significant Reports

Statistical Table - Questioned
Costs

Statistical Table
Recommendations That Funds
Be Put To Better Use

Summary of Previous Reports,
No Management Decisions, an
Explanation of the Reasons Such
Management Decision Has Not
Been Made, and a Statement
Concerning the Desired
Timetable for Achieving a
Management Decision on  Each
Such Report

Description And Explanation of
Revised Management Decisions

Management Decisions With
Which The Inspector General Is
In Disagreement
Senate Report 96-829
Senate Report,    Resolution of Audits
Page 11,
Appendix

1

2
                                                            21
             26
38

 8

23


23
Senate Report,
Page 12,
Delinquent Debts
                                            21
                                                            37
      Staffing Distribution—Fiscal
      1989 Ceiling
      Office                  Headquarters
         Field    Total
Inspector General
Audit
Investigations
Management and
Technical Assessment
b
44
8
23
5
148 192
52 60
23
      Total
                                         200
                                                 280
 'There were no instances where information or assistance requested by the
 Inspector General was refused during this reporting period Accordingly, we
 have nothing to report under section 5(a)(5) of the Inspector General Act of
 1978, as amended
 **Systems to provide the new information anticipated under the IG Act
 Amendments are in the development stage In future semiannual reports
 we expect to provide the summary of previous audit reports with no
 management decision and the Agency's explanation of the reasons such
 management decision has not been made, their statement concerning the
 desired timetable for achieving a management decision and their description
 and explanation of the reasons for any significant revised management
 decision made during the reporting period

 ***At the end of this reporting period, there were no significant
 management decision with which the Inspector General was in
 disagreement

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                               Office of Inspector  General — Who's  Who
    Headquarters
                                                      Inspector General
                                                     John C. Martin
                                                   Deputy Inspector Genera

                                                 Anna Hopkins Virbick
                 Office of Audit
                 Ernest E  Bradley, III
                 Assistant Inspector Genera
                 Kenneth A  Konz
                 Deputy
                         Operations Staff
                         Elissa R Karpf
                         Director
                         Office of Investigations
                         John E. Barden
                         Assistant Inspector General
                         Daniel  S. Sweeney
                         Deputy
Office of Managment
and Technical Assessment
John C Jones
Assistant Inspector General
(Acting)
                         Technical Assistance Staff
                         James O  Rauch
                         Director
                     1
Planning and Resources
Management Staff
Edward Gekosky
Director
                                                                      Technical Assessment and
                                                                      Fraud Prevention Division
                                                                      John C. Jones
                                                                      Director
                                                                      Administrative and
                                                                      Management Services
                                                                      Division
                                                                      Michael J  Binder
                                                                      Director
    Divisional  Inspectors General
Region 8, 9 & 10
Truman R Beeler, Audit
H  Brooks Gnffin
Investigations
                                                                              Region 5
                                                                              Anthony C  Carrollo, Audit
                                                                              Alex Falcon, Investigations
                                                                                Region 1 & 2
                                                                                Paul McKechme Audit
                                                                                Robert M  Byrnes,
                                                                                 nvestigations

                                                                                Region 3
                                                                                Paul R  Gandolfo, Audit
                                                                                Martin Squitien,
                                                                                Investigations

                                                                                Headquarters
                                                                                Kenneth Hockman,
                                                                                 nternal Audit

                                                                                Francis C Kiley
                                                                                Washington Field Office,
                                                                                Investigations
                                  Region 4, 6 & 7
                                  Mary Boyer, Audit
                                  James F Johnson
                                  Investigations

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   Section  1—Significant  Problems,  Abuses,  And Recommendations
As required by sections 5(a)(1)
and (2) of the Inspector
General Act of 1978, as
amended, this section
identifies significant
problems, abuses, and
deficiencies relating to the
Agency's programs and
operations along with
recommendations for the
current period. The findings
described in this section
resulted from audits and
reviews performed by or for
Office of Audit and reviews
conducted by the Office of
Investigations. Because these
represent some of our most
significant findings, they
should not be considered
representative of the overall
adequacy of EPA
management. Audit findings
are open to further review but
are the final position of the
Office of Inspector General.
This section is divided into
five areas: Summary of Audit
Activities and Results, Agency
Management, Construction
Grants, Superfund, and
Special and Prospective
Reviews.
Summary of
Audit Activities
and Results
  Questioned Costs and Recommended Efficiencies by Type of Audit
                                    Construction
                                                   Others
                                                                  Superfund
                                                                                 Internal and Management
                                    Federal Share
                                    Questioned
                      Non-Federal
                      Questioned
Non-Federal
Recommended
Efficiencies
Federal Share
Recommended
Efficiencies
            Audit Effort by Staff Days
                                                     Sources of Audit Reports
                                        Performance

                                        3648
                                         23 3%
                                        44 39%
                                                                                          State Auditors
                                                                                           24  2 1 %
              TOTAL- 15,632 Days
                                                                                  TOTAL REPORTS- 1128

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Agency
Management
The Inspector General Act
requires the OIG to initiate
reviews and other activities to
promote economy and
efficiency and to detect and
prevent fraud, waste, and
mismanagement in EPA
programs and operations
Internal and management audits
and reviews are conducted to
accomplish these objectives
largely by evaluating the
economy, efficiency, and
effectiveness  of operations
  The following are the most
significant internal and
management audit and review
findings and recommendations
Improved Controls
Are Needed to  Ensure
Adequate Penalties
for Effective
Enforcement

Problem

EPA consistently failed to
maintain essential records
supporting the basis for
enforcement decisions. As a
result, there was little
assurance that penalties
assessed by EPA were
equitable or sufficient to deter
violations of environmental
laws and regulations.

Background

EPA is responsible for
implementing and enforcing
various Federal laws designed
to protect the environment,
including monitoring and
inspecting sources of  pollutants,
prosecuting civil and criminal
violations, ordering companies
to comply with regulations or
take other actions, and
assessing monetary penalties
During the past 3 years, the
OIG and GAO reports
recommended  improvements in
EPA's assessment of  penalties
and the States'  implementation
of EPA and State penalty
policies


We Found That

Appropriate penalties were
either not calculated and
assessed at all,  or were
inadequately calculated  EPA
regional offices  did not always
calculate and consider the
economic benefit (the potential
financial gain the violator
received from delayed or
avoided costs of compliance)
and gravity (the reflection of the
actual or potential harm to the
environment and the size of the
violator) in assessing penalties
under the Clean Water Act, the
Clean Air Act, or the Resource
Conservation and Recovery Act
(See pages 10 and 13 for
specific program penalty policies
audited during this semiannual
period ) Improperly assessed
penalties may not effectively
deter violators
  Reductions to calculated
penalties, as much as 90
percent, far exceeded Agency
guidelines and lacked sufficient
support For example, a  sample
of 10 cases in one region
showed that penalties were
assessed in only 6 cases, there
was no calculation of penalties
in the remaining 4 cases The
computed economic benefit of
$637,775 for the 6 cases was
reduced to $88,000,  an 86
percent reduction  Agency
personnel insufficiently
documented the computation,
negotiation, adjustment, and
assessment of penalties
Inadequate  calculation and
documentation to support
penalty reductions greatly
increases the potential for fraud
or abuse Problems similar to
those found in  EPA regions also
occurred in  the States'
administration of penalty
policies
  Information on civil, judicial,
and administrative penalties was
not reflected in  EPA's Strategic
Planning and Management
System (SPMS), a management
tool for setting  goals and
priorities, developing annual
program guidance, and
evaluating performance  in
meeting program objectives
Without information  on the
computation, negotiation,
adjustment, and assessment of
penalties, senior managers
cannot adequately judge the
success of their programs or
identify areas needing
improvement

We Recommended That
The Acting  Assistant
Administrator for Enforcement
and Compliance Monitoring
• Reemphasize that Agency
personnel must fully comply
with program penalty policies,

• Institute a more aggressive
oversight program of regional
penalty activities which  includes
expanded reviews to determine
the adequacy of penalty
computations, penalty reduction,
and documentation to support
final decisions,
•  Increase oversight and
reporting of States'
enforcement actions, and
•  Require that penalty results
of concluded cases be reported
in the SPMS

What Action Was Taken

The audit report (9100485) was
issued on September 27, 1989,
to the Acting Assistant
Administrator for Enforcement
and Compliance Monitoring
(OECM) in coordination with the
Office of General Counsel and
the Assistant Administrators for
Air and Radiation, Water, Solid
Waste and Emergency
Response, Pesticides and Toxic
Substances,  and Policy,
Planning, and Evaluation A
response is due by December
26, 1989 The Acting Assistant
Administrator for Enforcement
and Compliance Monitoring
substantially agreed with our
draft recommendations

-------
Insufficient Penalties
Assessed Against
RCRA Violators

Problem
EPA personnel failed to
adhere to Agency policies and
procedures for assessing
penalties under the Resource
Conservation and Recovery
Act (RCRA). Monetary
penalties were not sufficient
to eliminate the economic
benefits of noncompliance or
achieve maximum deterrence.
We Found That

RCRA gives EPA the authority
to assess civil penalties of up to
$25,000 per day per violation for
failure to take corrective action
within the time  specified in a
compliance order  Agency
policies require  that penalties be
based on the gravity of the
offense and calculated to
eliminate the economic benefits
of noncompliance  EPA did not
adequately compute and assess
penalties against RCRA violators
to reflect either the seriousness
of the violation, the duration of
noncompliance, or the economic
benefits of noncompliance
Also, proposed  penalties against
RCRA violators  in Regions 1, 4,
6, 8,  and 9 were being
excessively mitigated during
negotiations  For the 431 cases
settled by EPA  during  fiscal
years 1985 through 1987, final
penalties of $6,094,686 were
only 37 percent of the
$16,497,130  initially proposed
Reductions to proposed
penalties ranged up to 100
percent as a  result of
negotiations conducted by
regional offices
   Regional management was
not adequately  reviewing
proposed and final penalties for
compliance with Agency
policies,  negotiators were
focusing on quick case
resolution, and  emphasis was
placed on compliance  with
environmental regulations
 instead of both compliance and
deterrence  In addition,
documentation  on proposed
penalties, negotiated
adjustments, and justifications
in executed consent
agreements was insufficient to
support decisions reached
 Percent Of Proposed Penalties Sustained In Negotiation
 •20
                           56
                           Regions
                                                    10    AVG
We Recommended That

The Assistant Administrators for
Enforcement and Compliance
Monitoring, and Solid  Waste
and Emergency Response
• Require that gravity-based
penalties and economic benefit
components of proposed
penalties be clearly identified
and assessed against violating
facilities,
• Reemphasize to  Regions the
importance of adhering to
Agency policies requiring that
penalties assessed eliminate the
economic benefits of
noncompliance, and
• Provide strong oversight to
hold regions accountable for
implementing Agency penalty
policies

What Action Was Taken
The audit report (9100479) was
issued to the Acting Assistant
Administrators for Enforcement
and Compliance Monitoring, and
Solid Waste and Emergency
Response on September 18,
1989 A response to  the report
/s due  by December  17,  1989
Hawaii Grant
Programs Did Not
Achieve
Environmental Goals

Problem
Region 9 did not effectively
monitor Hawaii's
administration of over $60
million of program and
construction grants awarded
during fiscal years 1986
through 1988.

We Found That
Region 9 had not effectively
monitored the grant programs
with the Hawaii Department of
Health (DOH) to protect the
environment, nor had Region 9
fully pursued corrective actions
of previously reported
performance shortcomings by
DOH The cumulative effect of
the deficiencies in DOH's
environmental programs and the
long period that they have
existed raise a serious concern
as to whether DOH has the
capability or desire to
implement and maintain
effective environmental
programs Specifically, we
found
• Ineffective Enforcement
Program  Neither the State nor
EPA demonstrated a serious
commitment to establishing an
effective enforcement program
and pursuing penalties against
facilities with long histories of
discharging water and air
pollutants in violation of
environmental  regulations.

• Inadequate Operation and
Maintenance  Inspection reports
indicated that 37 percent of the
plants received an
"unacceptable" rating, 52
percent were "conditionally
acceptable," and only 11
percent of the  plants were
acceptable Many facilities were
deteriorated, and some  were
not capable of  functioning at
their designed  operating levels
These deficiencies were
attributable to the failure of
counties and DOH to provide
sufficient funds for operation
and maintenance of the
facilities, and properly tram plant
operators The $332 million
Federal investment in the
State's treatment facilities may
not be  adequately protected

• Undemtilization of
Wastewater Treatment  Plants
Many EPA-funded wastewater
treatment facilities, valued in
excess of $128 million,  were
underutilized, some were
operating at less than 50
percent of their design capacity
The underutilized facilities were
primarily attributable to  the
grant recipients' failure to build
other facilities  necessary to
make the EPA-funded projects
fully usable, such as collection
systems and interceptors  to
convey wastewater  EPA and
DOH have not adequately
monitored the  grant recipients'
performance or enforced
conditions of the grant requiring
timely completion of the
complete waste treatment
system

• Compliance  Monitoring
Deficiencies The  Region did  not
assure that the State had  an
effective program for monitoring
compliance with environmental
requirements  Expiring National
Pollutant Discharge Elimination
System (NPDES) permits were
not reviewed on a timely basis,
and two wastewater treatment
facilities  were  allowed to
discharge without a valid
 10

-------
Growth of vegetation in chlorine contact chamber at Hi/o
wastewater treatment facility (OIG photo)
NPDES permit or extension  For
example, the Sand Island
Treatment Plant, the largest
discharger in Hawaii, has been
allowed to discharge about 70
million gallons  per day of
effluent since April 1988
without an NPDES permit Not
all publicly owned treatment
facilities in the State achieved at
least secondary treatment levels
by July 1, 1988, as required by
the Clean Water Act In March
1987, the Region found the
ambient water quality
monitoring program to be
seriously inadequate because of
limited resources and
inadequate laboratory support,
   Inoperable effluent
   pump generator at
  Lahaina wastewater
      treatment plant
     (Region 9 photo)
our current review found that
this program was still
ineffective
• Financial Management
System Deficiencies Time
charges were not ad|usted at
yearend to reflect actual time
worked by some employees,
and time sheets did not always
correctly reflect which grant
program they were actually
working on  The financial status
reports prepared for fiscal years
1986 and 1987 overstated
non-Federal costs and did not
exclude nonrecurrent costs
under the air and water  pollution
control grants  These
deficiencies in DOH's financial
management system were
reported to the Region in five
audit reports issued between
1973 and 1987 As a result of
these weaknesses, the $6 5
million Federal grant costs
reported by DOH for fiscal years
1986 and 1987 were inaccurate


We Recommended That

The Regional Administrator,
Region 9

• Assess DOH's willingness
and capability to operate  an
effective enforcement  program
in accordance with EPA
requirements, and either
increase EPA oversight of DOH
to aggressively implement an
effective enforcement  program
or assume a greater direct
enforcement role,

• Require DOH to implement
and maintain a management
information system for tracking
proposed penalties and final
collections for environmental
violations;

• Require DOH to write
guidelines for conducting O&M
inspections and initiating
enforcement actions Increase
regional oversight of DOH's
O&M inspections  to ensure that
(1) required inspections are
performed and reported
accurately, and (2) appropriate
enforcement action is initiated,

• Require DOH to take a more
aggressive role in  reviewing
grant recipients' user charge
systems to ensure that the user
rates are sufficient to generate
adequate funds for current
O&M needs, repair, and future
equipment replacement,

• Evaluate  DOH's compliance
with its delegated
responsibilities for assuring the
wastewater treatment  projects
are properly constructed and
properly used,

• Require  DOH to (1)
strengthen its environmental
compliance monitoring
procedures for timely renewal
and compliance with NPDES
permits and (2) improve the
ambient water quality
monitoring program,  and
• Work with DOH to correct
financial management
deficiencies and determine
whether revisions are needed
for reporting Federal grant
costs

What Action Was Taken
The Region provided a positive
response to the draft report and
generally concurred with our
recommendations The audit
report (9100446) was issued to
the Regional Administrator,
Region 9, on August 29,  1989
A response to the final audit
report is due by November 27,
1989

Stronger Enforcement
Action Required by
EPA and States to
Protect the
Chesapeake Bay

Problem
EPA and the States of
Maryland, Pennsylvania, and
Virginia have not effectively
enforced the Clean Water Act
against polluters of the
Chesapeake Bay nor did the
States complete the required
actions to reduce the amount
of toxic pollutants entering
the Bay.

Background
The Chesapeake Bay
Agreement, signed  by EPA, the
States bordering the Bay, and
the District of Columbia in 1983
and updated in 1987,  pledges to
reduce nutrient  loadings to the
Bay by 40 percent, manage and
control conventional pollutants,
and reduce toxic pollutants
entering the  Bay The National
Pollutant  Discharge Elimination
System (NPDES) under the
Clean Water Act of 1972
mandates that permits be
issued to all point sources
discharging directly into
navigable waters and  requires
effective compliance monitoring
and a strong enforcement
program by the  States and EPA
  This is the third in a series of
audits focusing on the
Chesapeake  Bay program that
found major problems in the
program's management by the
States and inadequate oversight
and enforcement by EPA
                                                                                                                         11

-------
We Found That

EPA and the States did not
effectively take enforcement
actions against Chesapeake Bay
dischargers  violating their
NPDES permits Even when the
pollution was serious or
longstanding. States were slow
to act against the permit
violators, assessing either
insignificant penalties or no
penalty whatsoever EPA did
not  fulfill its responsibility for
enforcement when the States
failed  to, and did not ensure
that the States expeditiously
and aggressively control toxic
pollutants
  L A Clark is an example of
weak  enforcement action
against a polluter of the Bay
Clark,  a Fredencksburg, Virginia,
wood  preserving facility,
consistently violated its NPDES
permit for 13 years without
being  assessed a penalty  The
facility caused numerous
environmental problems,
including contamination of
surface and ground water,
before finally being placed on
the Superfund National Priorities
List in June 1986,  with an
estimated cleanup cost of $23
million Despite the magnitude
of the facility's environmental
problems, it  retained its NPDES
permit for over 2 years after
being  declared a Superfund site

We Recommended That
The Regional Administrator,
Region 3, take more aggressive
and timely enforcement action
and provide more  effective
oversight to  ensure that the
States comply with Clean Water
Act requirements for controlling
toxic pollutants

What Action Was Taken

The audit report (9100467) was
issued to the Regional
Administrator, Region 3, on
September 11, 1989 A
response to the audit report is
due by December 10, 1989
Management
Improvements
Needed in the Leaking
Underground Storage
Tank (LUST)  Program

Problem

EPA did not equitably
distribute LUST Trust funds
to States that were working
to solve LUST problems.
States in Region 3 did not
adequately monitor progress
of cleanups or implement
LUST programs to protect
human health.

Background

Underground storage tanks
leaking gasoline threaten human
health and the environment by
causing ground water
contamination  Many
components of gasoline have
serious health effects, and
some components such as
benzene and ethylene dibromide
are suspected carcinogens Half
of the nation's drinking water
comes from the ground  EPA
estimated that of two million
underground storage tanks
nationwide, as many as 400,000
may be leaking  In  1986,
Congress established the LUST
trust fund financed by a tax of
0 1 cent on each gallon of
gasoline manufactured The
LUST trust fund is  estimated to
reach $500 million  by  1991  EPA
and the States are authorized to
use the trust fund  for cleanups
of leaking underground storage
tank sites


We Found That

•  EPA's method for distributing
$90 million in  LUST funds
provided unnecessary funding to
States that were unable to
timely use them because of
their inadequate LUST
programs, while other States
with effective programs were
given insufficient funds to
address critical cleanup
problems  The method also
failed to address individual State
need and performance
•  States have not adequately
ensured that responsible parties
were properly and  promptly
cleaning up sites which had
leaking underground storage
tanks  In three States, only 66
of 936 responsible party sites
have been cleaned up The
States did not prioritize
responsible party sites,
schedule and track corrective
actions,  perform timely followup
actions,  and assess the
timeliness or effectiveness of
corrective actions taken

• By  failing to have a viable
program, Pennsylvania lost $1 4
million in Federal LUST Trust
funds Also, Delaware and
Virginia are subjecting residents
to unnecessary exposure to
gasoline contaminants in
household water supplies

We Recommended That
The Assistant Administrator for
Solid Waste and Emergency
Response

• Revise the distribution
method so that (1) the base
amount used in the distribution
formula  is equivalent to the total
amount projected to be in the
trust fund and (2) the amount
awarded to each State is
commensurate with its
individual need and
performance
• Revise EPA's guidelines for
cooperative agreements to
ensure that the States properly
oversee responsible party
cleanups

The Regional Administrator,
Region 3

• Modify cooperative
agreements to require States to
address responsible party
cleanups
• Continue assisting
Pennsylvania in implementing a
State  LUST program and, if
necessary, establish a Federal
program in the State

• Request the Office of
Underground Storage Tanks to
provide guidance on the States'
responsibilities concerning
threats to human health posed
from gasoline-contaminated
water supplies
What Action Was Taken
The audit report (9100487) was
issued to the Acting Assistant
Administrator for Solid Waste
and Emergency Response and
the Regional Administrator,
Region 3, on  September 21,
1989 Before issuance of the
final report, EPA began initiating
corrective actions which
included revising the allocation
formula,  improving State
tracking and oversight of
responsible party cleanup,
continuing to help Pennsylvania
develop and implement a State
LUST program, and analyzing
the health effects caused by
exposure to gasoline
contaminants A final response
on the status of corrective
actions taken is due by
December 20, 1989
Schools with More
Serious Asbestos
Hazards Could Have
Received EPA Funding

Problem
EPA needs to improve its
management of the Asbestos
School Hazard Abatement Act
(ASHAA) loan and grant
program so that needy local
educational agencies  (LEAs)
with the most serious health
hazards receive assistance in
financing and implementing
their asbestos abatement
projects as quickly as
possible.

Background
An estimated 15 million school
children and 1 4 million school
employees attend or work in
buildings containing asbestos, a
known human carcinogen
ASHAA created  an EPA program
to provide interest-free loans
and grants,  assisting financially
needy LEAs with asbestos
abatement projects Loan
repayments by LEAs are made
to the asbestos  trust fund
12

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      CAUTION
       ASBESTOS
     DUST HAZARD
    AVOID BREATHING DUST
       WEAR ASSIGNED
    PROTECTIVE EQUIPMENT
   DO NOT REMAIN IN AREA
     UNLESS YOUR WORK
         REQUIRES IT
     BREATHING ASBESTOS
        DUST MAY SE
         HAZARDOUS
       TOYOUR HEALTH
We Found That
During fiscal years 1987 and
1988, EPA funded applications
on hand which were not
significant enough to receive
funding in the prior year Many
of the projects funded were for
boiler rooms with minor
damage, while other projects
with greater hazards were not
evaluated because the Agency
did not solicit new applications
As a result, classrooms with
major damage and significantly
more exposure hours were
passed over An estimated 2
million more exposure hours
could have been abated  by
funding current applications
instead of older applications
  EPA's 2-year grace period for
all ASHAA loan recipients before
repayment begins  has provided
some LEAs with interest-free
money for up to 2 years after
the completion of abatement
work By establishing more
timely repayment schedules,
EPA could have returned an
additional $1 5 million to the
asbestos trust fund by
December 1989, and an
additional $700,000 each year
thereafter
  Additional funds for needy
LEAs could have been made
available However, the
asbestos trust fund had  not
been made available by an
appropriation act, nor had EPA
requested use of the fund,
which had already  accumulated
about $5 5 million and is
estimated to accumulate to $29
million by 1992
  The State of Pennsylvania
 was not reviewing the adequacy
 of asbestos abatement
 management plans submitted
 by 487 LEAs Each of the 28
 plans we reviewed had
 deficiencies As a result, some
 LEAs may be implementing
 deficient management plans
 under the  mistaken impression
 that their abatement plans
 adequately protected the health
 and  safety of children and
 school employees

 We  Recommended That
 The Assistant Administrator  for
 Pesticides and Toxic
 Substances

 • Solicit applications annually
 for ASHAA funding

 • Work with the Office of
 Management and Budget and
 Congress to ensure that the
 asbestos trust fund is used

 • Request that the Assistant
 Administrator for Air and
 Radiation consider withholding
 portions of asbestos National
 Emission Standards for
 Hazardous Air Pollutants funds if
 Pennsylvania does not comply
 with asbestos laws
 The Assistant Administrator For
 Administration and Resources
 Management

 • Modify future loan
 agreements  to provide more
 timely repayment terms

 What Action Was Taken

 The  final report (9100486) was
 issued on September 20, 1989,
 to the Assistant Administrator
 for Pesticides and Toxic
 Substances and the Assistant
Administrator for Administration
 and Resources Management A
 response to  the audit report is
 due by December 19, 1989
EPA And States In
Regions 2 and 4 Were
Not Enforcing the
Clean Water Act

Problem
EPA and States in Regions 2
and 4 were not effectively
enforcing the Clean Water Act
against violations of National
Pollutant Discharge
Elimination System (NPOES)
permits by publicly owned
treatment works (POTW).

We Found That
Enforcement actions taken  by
EPA and the States in Regions
2 and 4 were inadequate or
ineffective in returning municipal
violators to timely compliance
Notices of violation  and
administrative orders were
issued but not aggressively
enforced against violators
Regions 2 and 4 did not take
timely and appropriate
enforcement actions against
polluters when States failed to
earn/ out their permit
enforcement responsibilities,
resulting in facilities continuing
to discharge inadequately
treated effluent  Also, Region 4
did not escalate timely
enforcement against chronic
violators in Florida, where EPA
has lead enforcement
responsibility
  The States in  Region 2 and 4
did not follow EPA's and/or their
own civil  and administrative
policies or regulations in
assessing penalties for
violations of  NPDES permits
Penalty assessments were  not
severe enough to encourage
compliance or cover the
administrative costs of
enforcement In both regions,
the States' case files lacked
adequate documentation and
justification to support penalty
calculations,  adjustments, and
final assessments  As a result,
213 of the 692  major facilities
(31  percent)  in Regions 2 and 4,
discharging million gallons a day
of inadequately treated effluent,
did not meet the July  1, 1988,
deadline established by
Congress in the Clean Water
Act to achieve water quality
standards
We Recommended That
The Regional Administrator,
Region 2

• Ensure that States
aggressively discharge their
responsibilities by taking timely
and appropriate enforcement
action for NPDES permit
violations
• Initiate direct Federal
enforcement against violators in
significant noncomphance when
State action is  not adequate

• Require penalty assessments
to be greater than the economic
benefit of noncomphance, cover
the administrative costs of
enforcement, and other factors
noted in EPA guidelines Ensure
that penalty calculations and
assessments are adequately
documented
• Continue to  implement the
National Municipal Policy
Enforcement Strategy to assure
that each POTW which did not
meet the July 1, 1988, deadline
is brought under an enforceable
judicial compliance schedule

The Regional Administrator,
Region 4

• Require States to develop
and implement enforcement
management systems
consistent with national
guidelines
• Implement timely and
appropriate enforcement efforts
to bring chronic violators into
compliance with the Clean
Water Act

• Require that reductions in
calculated penalties be justified
and documented in accordance
with the civil penalty policy
• Increase its oversight role  in
the NPDES enforcement
program and initiate Federal
enforcement when States fail to
take appropriate measures that
achieve compliance

What Action Was Taken

The audit reports (9100462 and
9100476) were issued to the
Regional Administrators,
Regions 4 and 2, on September
7 and 13, 1989 Responses
from Regions 4 and 2 to the
audit reports are due by
December 6 and 12, 1989
                                                                                                                         13

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Construction
Grants
EPA's wastewater treatment
works construction grants
program is the largest single
program the Agency
administers Under the
provisions of Public Law 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 fiscal
7989, $1  6 billion was obligated
on 402 new awards and 1,634
increases to existing grants At
year end, a  total of 1,769 active
construction grants represented
$9 6 billion in Federal
obligations
  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 with developing
and implementing a program to
provide grants  to capitalize State
revolving funds for financing
wastewater projects
  During fiscal 1989, $1 2 bill ion
was awarded on 35 new
capitalization grants and 15
continuation grants  As of the
end of this semiannual period,
EPA had obligated $1 4 billion to
42 States and Puerto Rico under
the revolving fund program
Millions Questioned in
Massachusetts
Construction Grant
Program
 Massachusetts DEP
Millions ot Dollars

j^^^l Federal      Non-Federal |	|

Problem

The Massachusetts
Department of Environmental
Protection (MA-DEP) used
grant assistance funds for
program activities outside the
scope of the delegated  grant
agreement with EPA or
contrary to EPA policy.

We Found That

The MA-DEP, in an agreement
with EPA, has been delegated
the responsibility for the
management and administration
of the construction grant
program under the Clean  Water
Act EPA authorizes the use of a
portion of each State's annual
construction grant fund
allotment for administration of
the day-to-day operation of the
construction grants program
  MA-DEP claimed $12,763,960
under this program over a
27-month period  However,
without proper authorization by
EPA, $2 9 million was expended
by MA-DEP for nonconstruction
activities  and is therefore
ineligible  For example, over
$2 6 million was used by
MA-DEP  for an unapproved
State permitting program  and is
ineligible  since this function,
under the National Pollutant
Discharge Elimination System
(NPDES), had not been
delegated to the
Commonwealth of
Massachusetts  For the last 5
years, the Commonwealth had
failed to obtain EPA approval for
the NPDES program because
necessary State legislation had
not been enacted  Without
authorization, MA-DEP also
used approximately $249,000
over a 1-year period to subsidize
deficit spending in water
pollution control This is also
outside the scope of the grant
agreement
  Because MA-DEP had
claimed widespread ineligible
charges, the remaining
expenditures of approximately
$9 8 million were questioned
because EPA could not rely on
MA-DEP's financial
management system  to
adequately identify eligible
costs  Currently, MA-DEP is
unilaterally determining how
funds awarded for construction
grant management will be used
MA-DEP failed to improve its
cash management practices  and
continues  to draw funds in
excess of  its immediate needs
even after 7 years of  promises
The Commonwealth's financial
management system  does not
allow MA-DEP to immediately
disburse letter-of-credit
drawdowns in accordance with
14

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Treasury regulations, resulting in
the Federal Government
incurring unnecessary interest
costs

We Recommended That
The Acting Regional
Administrator, Region 1

•  Require MA-DEP to
reimburse EPA over $2 9 million
expended on ineligible activities,

•  Require MA-DEP to provide
supporting documentation for
$9 8 million claimed,  and

•  Revoke MA-DEP's
letter-of-credit until a cash
management system is
established that meets Treasury
regulations

What Action Was Taken

The audit report (9100510) was
issued to the Acting Regional
Administrator, Region 1, on
September 29, 1989  A
response to the audit report is
due by December 28, 1989
Fort Pierce,  Florida,
Claims Over $2.6
Million of Questioned
Costs
 Questioned Costs

 0  2  4  6  8  10  12  14 16 18 20
Millions of Dollars


Problem
Fort Pierce, Florida, claimed
over $2.6 million of
questioned costs, including
$1,795,789 of ineligible costs
for the construction of a
wastewater treatment plant
that did not serve the planned
service area.

We Found That
EPA awarded four grants,  with a
maximum Federal share of
$8,993,358, to the Fort Pierce
Utilities Authority for the
planning, design, and
construction of a new 9 million
gallon per day secondary
treatment plant, wastewater
transmission additions, and lift
station upgrades We
questioned  the eligibility of
$2,440,485  of the final claim,
including
• $1,795,789 of construction
costs, architectural engineering
fees, project inspection fees,
and administrative expenses
due to the grantee's failure to
provide sewer service to all the
planned areas—including South
Hutchinson  Island, which
represented 16 7 percent of the
design capacity—as required in
the city's facilities plan and EPA
grant,

• $516,806 of construction
costs, architectural engineering
fees, and project inspection
fees that were outside the
scope of the approved project,
and
• $127,890 of project redesign
costs, unapproved indirect cost,
ordinary expenses of local
government, project inspection
fees incurred after the approved
contract completion date, and
equipment  procured in violation
of EPA procurement
requirements
Also, we questioned $167,160
of inadequately  supported
administrative expenses,
architectural engineering fees,
and project  inspection fees

We Recommended That
The Regional Administrator,
Region 4, not participate in the
Federal share of ineligible
questioned  costs ($1,830,363),
determine the eligibility of the
Federal share of unsupported
costs  ($125,370), and recover
the applicable amount from the
grantee

What Action Was Taken

The audit report (9300060) was
issued to the Chief, Municipal
Facilities Branch, Region 4, on
June 14,  1989  An interim
response was received on
September  26, 1989
 Grantee Claimed
 Almost $2.7 Million of
 Unnecessary and
 Ineligible Costs
| Sonoma Valley, CA
 Questioned Costs

 024  6  8  10  12  14 16 1820
Millions of Dollars
^|^| Federal      Non-Federal [_     |

 Problem

 The Sonoma Valley County
 Sanitation District, California,
 claimed $2,392,534 of
 ineligible engineering costs,
 administrative expenses, force
 account costs, and other
 project costs. The grantee
 claimed an additional
 $267,728 of unnecessary
 engineering fees.

 We Found That

 EPA awarded two grants
 totaling $14,912,595 to the
 Sonoma Valley County
 Sanitation District, California, for
 design of water reclamation and
 pollution control facilities and
 construction  of upgrades and
 expansions to existing
 wastewater treatment facilities
 We questioned $2,392,534 of
 the grantee's $15,994,066 final
 claim as ineligible for Federal
 participation, including

 • $1,817,286 for  unallowable
 engineering costs applicable to
 redesign of the grantee's
 effluent disposal system, work
 performed before the
 engineering subagreement was
 approved, costs incurred after
 the authorized completion date,
 and costs allocable to  the
 ineligible portion of the
 construction project,

 • $428,400 of grantee
 administrative and force account
 costs that were not allocable to
 the approved project, for
 ineligible site acquisition costs,
 incurred  after the  authorized
 completion date, and outside
 the scope of the approved
 project, and
• $146,848 for ineligible costs
for rights of way, easements,
excessive landscaping, and
construction work outside the
approved project scope
We also questioned $267,728 of
unnecessary design costs
applicable to a Step 3
construction grant which was
never funded

We Recommended That
The Regional  Administrator,
Region 9,  not participate in the
Federal share of questioned
costs ($1,794,400), determine
the eligibility of the Federal
share of unnecessary design
costs ($200,796), and recover
the applicable amount from the
grantee

What Action Was Taken

The audit report (9300041) was
issued to the  Regional
Administrator, Region 9, on April
11, 1989 A response due on
July  10,  1989, had not been
received as of October 27,
1989
Buffalo Sewer
Authority, New York,
Claimed Over $1.6
Million of Ineligible
and Unsupported
Costs
                                                                                               Buffalo Sewer Authority, NY
 Questioned Costs

 0    10    20     JO    40   50
   	!	I	O	J	
Millions of Dollars
^^^^| Federal     Non-Federal \	]

Problem

The Buffalo Sewer Authority,
New York, claimed $1,398,013
of ineligible construction
costs, design allowance fees,
architectural engineering fees,
and administrative expenses.
An additional $285,178 of
unsupported costs were
questioned.

-------
We Found That

EPA awarded four grants
totaling $33,843,944 to the
Buffalo Sewer Authority for the
construction of the Scajaquada
Tunnel Interceptor, connections
to the city's  existing sewer
system, access  manholes and
modification of existing
combined sewer overflow
structures, and rehabilitation of
a pump station  We questioned
$1,398,013 of the grantee's final
claim as  ineligible, including
•  $963,575  of construction
costs, architectural engineering
fees, and design allowance fees
claimed in excess of approved
amounts or grant budget,

•  $298,230  of architectural
engineering  fees, administrative
expenses, and construction
costs claimed in  excess of costs
actually incurred  or allocable to
ineligible portions of
construction costs; and

•  $136,208  of force account
and administrative costs claimed
that were incurred before the
EPA grant award, legal services
associated with  grant application
costs, or expenses normally
related to the cost of local
government
Also, we questioned $285,178
of unsupported construction,
design allowance, architectural
engineering, and force account
costs, and administrative
expenses claimed in excess of
the grant budget pending EPA
approval of final grant
amendments

We Recommended That
The Acting Regional
Administrator, Region  2,  not
participate in the Federal share
of the ineligible  costs
($1,048,510), determine the
eligibility of the  Federal share
($213,884) of unsupported
costs, and recover the
applicable amount from the
grantee
What Action Was Taken

Three audit reports (9100347,
9100348, and 9100354) were
issued to the Acting Regional
Administrator, Reg/on 2,  the
first two on July 6, 1989, and
the third on July 7, 1989 A
response to  the audit report
was due within  90 days
(October 4 and October 5,
7989J As of October 27, 1989,
we had not received responses
to the reports
Grantee Claims Over
$1.6 Million of
Ineligible Engineering
Costs
Problem

The Carmel Sanitary District,
Carmel, California, claimed
$1,609,354 of ineligible
engineering design service
costs for an advanced
wastewater treatment plant
not approved for funding by
EPA, and claim negotiation
costs.

We Found That

EPA awarded three grants
totaling $10,936,274 to the
Carmel Sanitary District for an
areawide disposal facilities plan,
design of a reclamation project,
and construction of a secondary
treatment plant, ocean  outfall
diffuser modifications; and
collection system pump station
improvements We questioned
$1,609,354 of the grantee's final
claim as ineligible for Federal
grant participation, including

•  $1,441,965 of engineering
design costs for an advanced
wastewater treatment project,
not approved for funding by
EPA, since water quality would
not be significantly improved,
•  $147,019 of other
engineering fees for unallowable
contract contingency costs,
failure to credit the project for
revenues received from the sale
of construction plans and
specifications, and costs outside
of the approved project scope,
and

•  $30,614  of consulting
contract costs not approved by
the delegated State agency and
claim negotiation costs allocable
to another  contract
Also, we identified $10,244 of
eligible construction costs that
were not claimed by the
grantee that could be offset
against questioned costs

We Recommended That
The  Regional Administrator,
Region 9, disallow the
$1,609,354 of costs questioned
and recover the $1,115,972 of
the Federal share previously
paid to the grantee

What Action Was Taken

The audit report (9300099) was
issued to the Regional
Administrator, Region 9, on
September 28, 1989 A
response is due by December
27, 1989
Vacaville, California,
Claims $1,358,553 of
Ineligible Costs
Millions of Dollars
|H Federal      Non-Federal]     |

 Problem

 The city of Vacaville,
 California, claimed $1,358,553
 of ineligible consulting
 engineering, administrative,
 and construction costs.

 We Found That

 EPA awarded two grants
 totaling $8,185,463 to assist the
 city of Vacaville, California, plan.
design, and construct a
wastewater treatment plant,
effluent outfall, and storage
reservoir We questioned
$1,358,553 of the grantee's final
claim as ineligible for Federal
grant participation, including

• $1,210,951 of  consulting
engineering costs incurred
before the subagreement was
approved by the  State Water
Resources Control Board, not
substantiated with adequate
supporting documentation, and
indirect costs billed in excess of
the allowable actual rate,

• $84,929 of administrative
costs not adequately supported
by time sheets and other
documents for specific tasks
performed by grantee
employees, and
• $62,673 of construction costs
outside the scope of the
approved project and force
account costs allocable to the
ineligible portion  of the
construction project

We Recommended That
The  Regional Administrator,
Region 9, determine that EPA
not participate in the ineligible
questioned cost  and recover the
Federal share ($1,018,860)
previously paid the grantee

What Action Was Taken

The audit report (9300093) was
issued to the Regional
Administrator, Reg/on 9,  on
September 13, 1989  A
response is due by December
12,  1989.
16

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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
DIG needs to provide audit
coverage,  SARA gave the
Inspector General a number of
specific responsibilities
Mandatory 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 report
regarding the required
Superfund annual audit work,
containing such
recommendations as the
Inspector General deems
appropriate The second annual
report,  covering fiscal 1988, was
issued  on  September 22, 1989
  In addition, the EPA
Administrator is required to
submit a detailed annual report
to the Congress on January 1 of
each year on the progress
achieved in implementing
CERCLA during the preceding
fiscal year  The OIG is required
to review this report for
reasonableness and accuracy,
and the Agency is required to
attach the result of the OIG
reviews to the Agency's annual
report  The Agency's  annual
Superfund report for fiscal 1987
was transmitted to Congress on
May 11,  1989
  Our review of the Agency's
Superfund report to Congress
found that some important
information included in the
report was  either inaccurate or
incomplete Information on
program accomplishment
figures for preremedial, removal,
and remedial programs was
frequently inaccurate  because
Headquarters information
systems used to prepare the
report were not reliable Much
of the Headquarters information
did not agree with
corresponding information from
regional systems, and significant
portions of the regional claims
were not supported by valid
source documents  Also, the
Agency's report showed only
delays which occurred since
January 1, 1987, in the status of
remedial investigation/feasibility
studies and remedial actions,
although the law required that
all delays from previously
published schedules for
completion of these activities be
shown
  In two areas of the report, we
believe the information
presented was not as complete
as it could have been Section
301(h)(l)(G) of CERCLA requires
EPA to provide "An estimate  of
the amount of resources    to
complete implementation of all
duties    " under CERCLA
However,  EPA only provided
budgetary figures for fiscal 1987
through 1989 Information
presented on feasibility studies
did not include descriptions of
cleanup alternatives, costs,
benefits, and risks  to public
health and the environment
which are vital to understanding
how EPA makes decisions on
Superfund sites
  The report for fiscal 1988, and
the Inspector General review of
it, are still in preparation
                                                                                                                         17

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Inadequate
Administration and
Coordination Impeded
Arkansas Cleanup

Problem
Inadequate administration
and coordination by EPA and
Arkansas at sites in
Jacksonville and Fort Smith
slowed cleanup actions and
increased cleanup costs by $6
million.

Background
From  1948 to 1986,  the Vertac
site in Jacksonville, Arkansas,
was used to produce herbicides,
including "Agent Orange," with
dioxm as a by-product  The
responsible party created a
$107 million trust fund in 1986
to pay for cleanup of the site,
and maintained the dioxin
drums until abandonment in
January 1987
  From  1958 to 1970,  the
Gramlich site, a city  block in a
residential area of Fort Smith,
Arkansas, was sprayed with
PCB-contaminated oil as a dust
and pest control measure on
yards, alleys, and streets and
under several homes In 1982,
Region 6 became aware of  the
site and attempted to take
cleanup action The immediate
cleanup action was denied by
EPA Headquarters, which
recommended a planned
removal action None was
performed
Dioxin-filled drums are removed
from the Vertac site in
Jacksonville, Arkansas (photo
by David W Gray, EPA)
We Found That

At the Vertac site, the leaking
drums were not timely
incinerated although both EPA
and the State of Arkansas
agreed that incineration was the
only feasible permanent
remedy  EPA and the State
failed to agree on who was
responsible for the incineration
The State took  over 2 years to
procure an incineration contract
while EPA packed and stored
the hazardous waste drums for
incineration The 2 year
incineration delay was due to
responsible party litigation and
the State's inexperience with
developing incineration,
although EPA had a program for
developing new technologies  If
the drums had  been incinerated
soon after the first year of
removal, EPA could have saved
$4 7 million in maintenance
costs
  At the Gramlich site,  Region 6
requested Headquarters'
approval and $258,000 to
conduct an immediate removal
of 800 cubic yards of
PCB-contaminated soil  EPA
Headquarters denied the
request and recommended a
planned  removal  The State
conducted a $50,000 cleanup in
October 1982,  the Region
assumed this action cleaned up
the site  The Region did not
confirm this assumption or
perform post-removal sampling
until 1988 EPA's post-removal
sampling determined that only
200 of the 800 cubic yards of
PCB-contaminated soil had been
removed by the State and that
the contamination had spread to
an additional 2,000 cubic yards
at the site As a result, EPA had
to spend $1 6 million to remove
all 2,600 cubic yards of
PCB-contaminated soil to which
homes near the site had been
exposed for an additional 3 to 6
years
  Also, the Region did not
complete enforcement action
against the responsible party at
the  Gramlich site because it did
not  ask the responsible party to
perform cleanup activities
before beginning the removal,
notify, in writing, the
responsible party of its potential
liability for the cost  of the
removal, issue an administrative
order once the responsible party
refused  to perform the removal,
and pursue cost recovery
against the responsible party

We Recommended That
The Regional Administrator,
Region 6

• Implement procedures for the
proper coordination  and
oversight of joint cleanup efforts
with States,

• Implement procedures to
ensure the full use of, and
compliance with, EPA's
enforcement policy, and

• Pursue cost recovery for the
Gramlich removal against the
responsible party

What Action Was Taken
The audit report (9100513) was
issued to the Regional
Administrator, Region  6, on
September 29,  1989 A
response is due by  December
28,  1989
                                                              Inappropriate
                                                              Contracting and
                                                              Oversight Resulted in
                                                              Inefficient Cleanups in
                                                              Ohio and Indiana

                                                              Problem
                                                              A hazardous waste cleanup
                                                              contract awarded before the
                                                              full extent of contamination
                                                              at an Ohio site was known
                                                              was insufficient, and another
                                                              contract was required  to
                                                              complete the cleanup.
                                                              Inadequately directed
                                                              contractor work violated
asbestos cleanup regulations
at the Ohio site and impeded
enforcement efforts at an
Indiana site.

We Found That

•  EPA awarded a $2 million
site-specific contract to clean up
the Dayton Tire and  Rubber site,
located in  Dayton, Ohio,
although Agency contracting
officials  did not know the
quantities  of wastes requiring
removal Because the contract
limited the amount of hazardous
waste to be removed, an
additional $1 3 million delivery
order under another  contract
was needed to complete the
removal Also,  the large quantity
of asbestos needing removal
forced the On-Scene
Coordinator (OSCi to make
impractical decisions such as
what and where to remove in
order to stay within contract
limitations
  Asbestos removal  procedures
used by a  subcontractor at
Dayton Tire and Rubber did not
comply with applicable
regulations established by the
Occupational Safety  and Health
Administration  (OSHA) Also,
the OSC had not been
adequately trained to manage
asbestos cleanups and ensure
the subcontractor followed
OSHA worker protection rules
Both the Agency's Technical
Assistance Team and an OSHA
inspector found numerous
violations of OSHA safety
procedures by the cleanup
contractor, including  failure to
isolate asbestos-contaminated
work areas, lack of an adequate
decontamination area for
workers, and improper use of
respirators by 90 percent of the
contractor's employees

• A contractor did not perform
an efficient and timely search
for potentially responsible
parties (PRPs) to pay cleanup
costs of PCB-contaminated oil
18

-------
at the Cam-Or site in Westville,
Indiana At a cost of about
$100,000, the contractor took a
year to photocopy boxes of
Cam-Or's records that were
determined unnecessary in
identifying PRPs  EPA officials
failed to adequately monitor the
contractor's work and act on
information in the contractor's
monthly status reports
indicating problems with the
PRP search  Consequently, a
second PRP search was
required and EPA did not send
information requests to PRPs
until 20 months after the
removal began, further delaying
EPA's efforts to obtain
reimbursement of over $2
million in cleanup costs

We Recommended That

The Regional Administrator,
Region 5

• Complete corrective actions
initiated during the audit, and

• Provide a 40-hour asbestos
training course for all On-Scene
Coordinators

What Action Was Taken

The audit report (9100493) was
issued to the Regional
Administrator, Region 5, on
September 29, 1989 A
response is due from  the
Regional Administrator
onDecember 28,  1989 During
the audit, and in response to
our draft audit report.  Region 5
agreed to
• Follow Agency guidance on
the use of site-spec/fic
contracts and maintain an
appropriate degree of contract
flexibility,

• Prepare detailed
extent-of-contamination studies
before preparing contract
statements of work and
awarding contracts,
• Forward information on
unsatisfactory PRP searches to
EPA's National Enforcement
Investigations Center,  which
audits PRP search contractors,
and

• Brief all On-Scene
Coordinators on asbestos
removal procedures and begin
sending  them to full asbestos
training courses
Special And
Prospective
Reviews
This section in our semiannual
report describes significant and
potential findings, deficiencies,
and recommendations which
have been identified through
evaluations, analyses, protects,
and audits These projects are
intended to help 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,
independent picture of
operations Special reviews are
not statistical  research studies
or detailed audits Rather, they
are information gathering
studies that identify issue areas
for management attention
EPA Had No Audit
Followup System To
Assure That
Corrective Actions
Were Taken

Problem

EPA did not know if
corrective actions resulting
from audit recommendations
were completed or, if
completed, whether the
deficiencies were corrected.

We Found That

EPA did not know whether or
not corrective actions resulting
from audit recommendations
were implemented
Implementation of corrective
actions was previously tracked
in the Audit Followup Corrective
Action Tracking System
However, Agency officials
indicated that system was
inadequate, primarily due to a
lack of internal controls over
entering, monitoring, and
reporting progress of each
corrective action taken  In early
1988, the Agency ceased
reporting through that system
and concentrated on developing
and implementing an improved
reporting system. At the time
we issued our report, the new
system was still not operational
Consequently,  there was no
Agency audit followup system
  The Agency was in violation
of the Office of Management
and Budget Circular A-50 and its
own Order 2750,  which require
the Agency to  initiate and
maintain an Agency-wide audit
followup system  Additionally,
the lack of an audit followup
system to track the
implementation of corrective
actions was a material
weakness which should  have
been reported  in the Agency's
annual assurance letter required
by the Federal  Managers'
Financial Integrity Act
We Recommended That

• The new audit followup
system include all uncompleted
corrective actions from prior
OIG audits

• Manual interim reporting  be
required if the new system  is
not operational by the beginning
of fiscal  1990

• The absence of an Agency
audit followup system be
reported as a material weakness
in this year's annual assurance
letter


What Action Was Taken

The Special Review on the
Effectiveness of Agency Audit
Followup (9400041) was issued
to the Assistant Administrator
for Administration and
Resources Management on
September 26, 1989 A
response to  the report is due by
December 26,  1989
                                                                                                                        19

-------
Construction Grant
Early Warning System

This relatively new program is
designed to identify potential
problem construction projects
early in their life cycle so that
EPA management can take
appropriate corrective action
  The long-range goal of the
construct/on  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 takes 2
to 10 years
  Because audits are generally
performed after the project is
complete, problems which
affect the efficient design,
construct/on, management, or
operation of  a treatment plant
are not disclosed until
thousands or millions of dollars
have been spent  The QIC 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
Over $2.9 Million
Should Not Have
Been Awarded For a
Milwaukee, Wisconsin
Project

Problem

The site selected for a
dropshaft to divert sewage
costs over $2.9 million more
than an approved alternative
site.

We Found That
On January 31,  1989, a
$37,680,948 continuation
construction grant was awarded
to the Milwaukee Metropolitan
Sewerage District (MMSD),
Milwaukee, Wisconsin, for the
construction of a dropshaft and
other facilities to divert sewage
as part of a crosstown
interceptor project  During the
project design phase,
Milwaukee County was
concerned that the proposed
construction site was too close
to the Milwaukee County Eye
Institute where  operations using
delicate instruments are
performed
  Eight alternative project sites
were studied, and one was
chosen as the most
environmentally safe and
cost-effective alternative
However, after 4 years of
negotiations,  MMSD was
unable to obtain site easements
from Milwaukee County for the
recommended alternative site
Another site,  which was not
one of the eight previously
examined, costing an additional
$2,974,160 for design and
construction,  architectural
engineering fees, and
administrative expenses, was
then selected We determined
that the site selection was not
cost justified  and questioned
both the $2 3 million for
additional construction and
$647,160 for  applicable services
as unallowable for Federal
funding
  In addition, the Wisconsin
Department of Natural
Resources  inappropriately
certified the project for grant
award before the U S  Army
Corps of Engineers review and
Milwaukee County's approval of
the plans and specifications
Also, the project did not comply
with the grant award project
schedule

We Recommended That
The Regional Administrator,
Region 5 to (1) adjust the grant
award to reflect the
unreasonable costs questioned
($2,230,620 Federal share), and
(2) consider imposition of
sanctions against the grantee
for noncomphance with the
grant award project schedule

What Action Was Taken

The construction grant early
warning review report (9400038)
was issued to the Regional
Administrator, Region 5, on
September 11, 1989 A
response to the report is due by
December 11,  1989
Grantee Receives $1.6
Million Construction
Grant That Should Be
Terminated

Problem
The Marina County Water
District, Marina, California,
was improperly awarded a
construction grant to
purchase capacity rights in
the Monterey regional
wastewater treatment
facilities.

Background
Originally, the Marina County
Water District's wastewater
treatment requirements were
included in an EPA-funded
regional facilities plan for the
greater Monterey area At the
water district's request, Marina
County was formally removed
from the regional project on
August 17, 1979 Subsequently,
the water district reversed  its
original position and  requested
assistance in gaining use of the
Monterey regional facility outfall
to resolve discharge  violations
into Monterey Bay
We Found That

On June 30, 1989,  EPA
awarded a $1,694,000
construction grant to the Marina
County Water District to buy
capacity rights to the Monterey
regional wastewater treatment
plant  The grant was improper
and should not have been
awarded since EPA regulations
do not allow "buy-in" costs  if
the acquired treatment works
was built with Federal and State
financial assistance, and if the
buy-in circumvented other
Federal  requirements In this
particular case, the regional
facility was constructed with
Federal and State funds and
EPA's award of  a construction
grant to the water district
violated  a special grant condition
precluding grant funding for
Marina's buy-in costs
  The grant award  to the district
for buy-in costs  did not  meet
EPA eligibility requirements and
should be terminated  Also,
award of the grant  funds for the
buy-in can be considered a
windfall  to Marina for its failure
to complete timely processing
of its construction grant
application for the conveyance
facilities

We Recommended That

The Regional Administrator,
Region 9, notify the district that
the grant is ineligible for funding
because it was issued in
violation of grant regulations and
terminate the grant

What Action Was  Taken

The construction grant early
warning review report (9400043)
was issued on September 26,
1989  A  response is due by
November 1, 1989

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As required by the Inspector
General Act, as amended, 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
Resolution

EPA management and the
Office of Inspector General
report that, at the beginning of
the second half of fiscal 1989,
there were 369 audit reports for
which no management decision
had been made as reported on
the chart on the following page.
This number of audit reports,
when added to the 334 audit
reports requiring follow-up
action that were issued by the
Office of Inspector General
during the period, totals 700
audit reports needing resolution
The Agency made management
decisions on 343 of these
audits At the end of fiscal
1989, 357 audit reports
remained for which no
management decision had been
made. Of this number 94 audit
reports remained for which no
management decision was
made within six months of
issuance This number included
21 preaward audits, previously
excluded from overdue audit
reporting
  Of the 343 audits closed,
$16.8 million of questioned
costs were disallowed and are
to be recovered, and $56 8
million of recommendations that
funds be put to better use were
agreed to by EPA management
In addition, cost recoveries in
current and prior periods
included $3 4 million in  cash
collections and at least  $103
million in offsets against billings
  During the past year, EPA
formed a Task Force to develop
quality training materials and an
approach for all managers to
help them improve their audit
management skills and  the
performance of their programs
This effort is called
"Strengthening the Audit
Management Ability of  EPA
Managers." EPA's audit
follow-up coordinators were
recently introduced to these
new training materials They are
now arranging training for their
organizations to get this
information to managers,
supervisors and others involved
with the audit management
program
  EPA, in its effort to meet the
reporting requirements of the
Inspector General Act
Amendments of 1988, is also
currently implementing a
software package that will allow
audit follow-up coordinators to
track audit follow-up activity at
the local level  and to  report
information to the Headquarter
Audit Follow-up Official
Hands-on training sessions were
conducted in  mid-October to
instruct EPA's audit follow-up
coordinators to understand and
properly use the software
  These efforts by EPA are
aimed at ensuring timely and
quality  audit resolution
                                EPA Office Of Inspector General Status Report On Perpetual Inventory Of Audits In Resolution Process For
                                The Semiannual Period Ending: September 30, 1989
                                                                                      Dollar Values (in thousands)
                                                                              Report Issuance
                                                                         Audit Resolution
                                                                         Costs Sustained
                                                            Number
                                        Questioned
                                            Costs
                     Recommended   To Be
                        Efficiencies   Recovered
                    As
                    Efficiencies
                                A  For which no management
                                decision has been made by the
                                commencement of the
                                reporting period*
                                                               369
                                          $163,778
                          $796,782
                                B Which were issued during       1,128
                                the reporting period

                                C Which were issued during        797
                                the reporting period that
                                required no resolution
                                            59,401
                            31,804


                                95
                                Subtotals (A+B-C)
                                                               700
                                                                           223,179
                                                           828,491
                                D For which a management
                                decision was made during the
                                reporting period
                                                               343
                                            76,314
                           275,654    $16,771
                       $56,822
                                E For which no management
                                decision has been made by the
                                end of the reporting period
                               357
                                           146,865
                           552,836
                                Reports for which no
                                management decision was
                                made within six months of
                                issuance
                                                                94
                                                                            89,674
                                                           524,611
                                "Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this
                                report and our previous semiannual report results from corrections made to data in our audit tracking system
                                                                                                                            21

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Audit Followup

The Inspector General Act
Amendments of 1988 have
focused increased attention on
Agency responses to the
findings of the Inspectors
General Agency management is
now required to report
semiannually, in a separate
report to Congress, the
corrective actions taken in
response to the IG's  audits The
Office of Inspector General will
also  review the Agency's
followup actions Below are
summaries of several of these
reviews
IRS Getting Penalty
Information; Some
Problems Remain

  A September 1987 audit
showed that EPA
Headquarters and Regional
offices did not routinely
provide penalty information
to the IRS. Consequently,
violators of EPA regulations
may have gained a tax
advantage by claiming
penalties paid to EPA  as a
deductible business expense
when they were not
deductible.

  Our followup (report 9400045)
found that penalty information  is
now routinely provided  to the
IRS every quarter However,
EPA has not yet issued clear
guidance to EPA officials to
ensure that consent decrees
state that penalties are  not tax
deductible We also found that
background  information on
alternative payments in  lieu of
cash were not being routinely
forwarded to IRS
                              Letter-of-Credit
                              Deficiencies In Region
                              9 Continue

                                A 1987 audit in  Region 9
                              found that some letter of
                              credit (LOG) recipients were
                              drawing down cash in excess
                              of the amounts authorized
                              under their grants and were
                              not submitting timely and
                              accurate accounting records.

                                Our followup (report 9400047)
                              found that, while Region 9 had
                              initiated corrective  actions to
                              implement our prior
                              recommendations,  LOG
                              deficiencies continue to exist A
                              review of four of seven grants
                              that had been expired for 10 to
                              22 months found that the
                              Region's grant closeout
                              procedures were not effective
                              in assuring timely reconciliation
                              and closeout of expired grants
                              Region 9's LOG system was  not
                              always reconciled to related
                              accounting records
 Problems Remain in
 Asbestos Control
We issued a report in March
1988 recommending
improvements in the handling
of the asbestos portion of the
program called National
Emission Standards for
Hazardous Air Pollutants
(NESHAP).

   Our followup (report 9400044)
found that EPA has taken great
strides toward resolving the
problems highlighted in our prior
audit  However, the Agency had
not issued the final asbestos
health and safety guidelines
These are expected in the
spring of 1990 Also, inspectors
in 9 of 15 delegated States
reviewed did not routinely  enter
asbestos containment areas
Not all of the delegated
agencies have inspection
strategies that coincide with the
national strategy, or have a
strategy for identifying
contractors that fail to notify
EPA of asbestos projects,  or
have taken  significant action
against asbestos NESHAP
violators
                               Recoveries Resulting
                               from OIG Audits Still
                               Not Adequately
                               Reported

                               A 1986 special review by the
                               OIG showed that recoveries
                               resulting from OIG audits
                               were not being accurately
                               reported to the Office of
                               Management and Budget
                               (OMB).

                                 Our followup (report 9400048)
                               found that information reported
                               to the OMB, the Administrator,
                               and the Congress  on  recoveries
                               resulting from OIG audits is still
                               not accurate  For example, we
                               identified $32 6 million in
                               discrepancies in fiscal 1987 and
                               1988 from miscalculating the
                               amounts for the sustained
costs, not reporting some
monetary findings, and
mistakenly including non-OIG
audits in the Audit Tracking
Report system  A failure to
stress continued compliance
with its 5-year-old reporting
instructions (administrative order
2750, Management of EPA
Audit Reports and Follow-up
Actions), lack of training, and
inadequate oversight have
allowed reporting errors to
persist Thus, EPA is not in
compliance with requirements
of OMB Circular A-50, Audit
Followup
 22

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 Status Of
 Management
 Decisions On IG Audit
 Reports

 This section presents statistical
 information as required by the
 Inspector General Act
 Amendments of 1988 on the
 status of EPA management
 decisions on audit  reports
 issued by the DIG  involving
 monetary recommendations In
 order to provide uniformity in
 reporting between  the various
 agencies, the President's
 Council on  Integrity and
 Efficiency issued guidance on
 reporting the costs under
 required statistical  tables of
 sections 5(a) 8  and 9 of the act

   As presented, information
 contained in Tables I and II
 cannot be used to  assess
 results of audits performed or
 controlled by this office  Many
of the reports counted were
performed by other Federal
auditors or independent public
accountants under the Single
Audit Act EPA DIG staff does
not manage or control such
assignments  In addition,
amounts shown as costs
questioned or recommended to
be put to better use contain
amounts which were at the
time of the audit unsupported
by adequate documentation or
records  Since auditees
frequently provide additional
documentation to support their
allowability subsequent to the
audit, we expect that a high
proportion of unsupported costs
will not be sustained
  EPA OIG controlled audits
resolved during the year,
resulted in $77 3 million being
sustained out of $84 3 million
considered unallowable in
reports  under OIG control This
results in a 91 6 percent
sustained rate
           TABLE II

           Inspector General Issued Reports With
           Recommendations That Funds Be Put To Better Use
                                   Number
                                        Dollar Value
                                      (in thousands)
           A  For which no            104
           management decision has
           been made by the
           commencement of the
           reporting period


           B  Which were issued       49
           during the reporting period


           Subtotals (A+B)            153


           C  For which a              105
           management decision
           was made during the
           reporting period


           (i)  Dollar value of           29
           recommendations that
           were agreed to by
            management


           -based on proposed         N A
           management action
                                           $491,622






                                             31,708



                                            523,331


                                            275,654





                                             56,822





                                               N A
 TABLE I

 Inspector General Issued Reports With Questioned Costs

                                       Dollar Values (in thousands)

                                          Questioned  Unsupported
                               Number      Costs       Costs
                                   -based on proposed         N A
                                   legislative action


                                   (n) Dollar value of costs       45*
                                   not disallowed


                                   (in) Dollar value of            41
                                   non-awards or
                                   unsuccessful bidders
                                                                                                                   N A
                                                       184,567
                                                       34,265*
 A For which no management         143
 decision has been made by the
 commencement of the reporting
 period


 B New Reports issued during         136
 period


 Subtotals (A +  B)                   279

 C For which a management          107
 decision was made during the
 reporting period


 (i) Dollar value of disallowed costs      90


 (n) Dollar value of costs not            77*
 disallowed


 D For which no management         172
 decision has been made by the end
 of the reporting period
          $163,159    [$111,148]
            59,401



           222,559


            76,314




            16,771


            59,544



           146,245
 [25,976]



[137,124]

 [58,758]
 [78,366]
D For which no
management decision has
been made by the end of
the reporting period


Reports for which no
management decision
was made within six
months  of issuance
                                                                                                               247,676
                                                                              219,452
      Semiannual Period Ending September 30, 1989


*0n 35 audits management did not agree to any of the
$160.712 recommendations that funds be put to better
use Ten of the audits included in Cd) above were only
partially agreed to by management  Therefore, these
reports and recommendations that funds be put to better
use that were not agreed to by management are included
in this category
**This amount represents the dollar value of recommendations
that funds be put to better use
Reports for which no management
decision was made within six
months of issuance
            89.05E
 [53,240]
            Semiannual Period Ending September 30, 1989


*On 17 audits management did not sustain any of the $8,378 questioned
costs  Sixty audits included in C(i) are also included in C(n) because they
were only partially sustained  Only the costs questioned that were not
sustained are included in this category
                                                                                                                                 23

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Previously Reported
Items—Corrective
Actions Not Taken

The Inspector General Act, as
amended,  requires that each
semiannual report identify
unresolved audits discussed in
previous reports Two hundred
and twenty-four reports were
discussed  in  all previous
reports, 211  have been
resolved The 13 audit reports
listed below  had not been
resolved as of September 30,
1989
Audit
Number   Grantee/Contractor
Issue Date   Status*
8100927   Program Review R-4
           Removal Sites

8100958   Maui County, HI

8100468   Miami-Dade, FL
8100761    Moses Lake, WA
  09/26/88   In Headquarters OIG/Program
            Office for Final Resolution

  09/29/88   No Response

  07/02/88   OIG In  Agreement With 10/25/88
            Proposed Final Determination
            Letter— Awaiting Final
            Determination Letter to
            Close Out


  08/31/88   In ARB Referral  Process
                               9100209   RCRA Contract Monitoring   03/31/89   No Response*


                               9300035   Sacramento Regional        03/31/89   No Response
                                         County Sanitation District,
                                         CA
                               9100119   Nassau County, NY

                               9100134   Ft Myers, FL

                               9300027   Pima County, AZ

                               9400025   Homeland, CA
                                    12/21/88   No Response

                                    12/29/88   No Response

                                    03/09/89   No Response

                                    02/07/89   In Headquarters OIG/Program
                                              Office for Final  Resolution
                               9100045   PEI Associates
                                    11/01/88   Response Submitted
                                              Dated 9/28/89 In Review
                                              Process
                               9100071   PEI Associates
                                    11/21/88   Response Submitted
                                              Dated 9/28/89 In Review
                                              Process
                               9100077   PEI Associates
                                    12/02/88   Response Submitted
                                              Dated 9/28/89 In Review
                                              Process
                               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
 24

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Action Officials for Audit Reports Outstanding More Than Six
Months as of September 30, 1989*
 Action Official
 EPA Administration

 Assistant Administrator, Office of     1
 Administration and Resources
 Management

 EPA Contracts
 Director, Procurement and Contracts   6
 Management Division

 EPA Grants Programs

 Director, Grants Administration        3
 Division
Regional
Regional
Regional
Regional
Regional
Administrator,
Administrator,
Administrator,
Administrator,
Administrator,
Region
Region
Region
Region
Region
2
4
5
9
10
2
25
29
6
1
1
13
7
4

1
9 2 - 1***
15 5 2 -
1 _ _ !***
1
                                                              Resolution of Significant Audits from Prior Periods
                                                                                            Report Issuance    Report Resolution
Report Number/
Report Date
P2CW*7-01-0129
8100319
REPORT DATE
6/20/88
P2CW*7-02-0032
9100118
REPORT DATE
12/21/88
P2CW6-02-0056
9100146
REPORT DATE
1/10/89
P50G*7-02-0083
9100221
REPORT DATE
3/23/89
N3HMJ9-05-0171
9500359
REPORT DATE
2/8/89
E2CW*6-09-0021
7100358
REPORT DATE
6/16/87
S2CW*7-09-0014
9300026
REPORT DATE
3/6/89
Grantee/
Contractor
Norwalk, CT



Amherst, NY



Ramsey, NJ



NYSDEC-Love
Canal, NY


Gary, IN



Aliso Water Mgmt
Agency, CA


McFarland, City of
CA


FS Questioned Federal Share
to be Recovered
INEL
UNSP
UNUR

INEL
UNSP
UNUR

INEL
UNSP
UNUR

INEL
UNSP
UNUR

INEL
UNSP
UNUR

INEL
UNSP
UNUR

INEL
UNSP
UNUR

$709,919 INEL
1,868,093 UNSP
0 UNUR

789,255 INEL
1,428,056 UNSP
0 UNUR

388,333 INEL
407,853 UNSP
0 UNUR

3,335,323 INEL
1,805,180 UNSP
0 UNUR

0 INEL
440,946 UNSP
0 UNUR

517,940 INEL
9,506,017 UNSP
0 UNUR

10,689 INEL
0 UNSP
548,084 UNUR

$610,107
490,478
0

750,094
642,902
0

144,959
340,467
0

3,335,323
605,180
0

0
440,946
0

488,935
0
0

10,689
0
548,084

Total
                                 73  28  27
S2CW*7-09-0029 Los Angeles, CA   INEL
 8100875                      UNSP
REPORT DATE                  UNUR
9/15/88
                                                                                                  3,139,453 INEL   2,096,584
                                                                                                         0 UNSP         0
                                                                                                    843,586 UNUR    715,196
*This report is presented in the same format as previous
semiannual reports It has not been changed because the Agency's
system to provide the new  information anticipated under the IG Act
Amendments is still in the development stage  In future semiannual
reports we expect to provide the agency's explanation of the
reasons such management  decision has not been made and their
statement concerning the desired timetable for achieving a
management decision The  73 past due audits do not include
preawards audits included in the chart on page 23  Preawards will
be included in future reporting in  accordance with the IG Act
Amendments
**lncomplete audit responses open 90 days or more past report
date will be handled as a nonresponse in accordance with EPA
Directive 2750 titled "Management of EPA Audit Reports and
Follow-up Actions" All of the reports under this category would be
considered as nonresponse
***ln Headquarters OIG/program office for final resolution
                                                              NOTE
                                                              INEL =  INELIGIBLE COST
                                                              UNSP = UNSUPPORTED COST
                                                              UNUR = UNNECESSARY/UNREASONABLE COST
                                                              RECOM = RECOMMENDED EFFICIENCIES
                                                              SUST = RECOMMENDED EFFICIENCIES SUSTAINED
                                                                                                                        25

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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
Pending Investigations as of
April 1, 1989             239

New Investigations Opened
This Period              126
Investigations Closed
This Period
135
Pending Investigations as of
September 30, 1989      230
                             Prosecutive and
                             Administrative
                             Actions

                             In this period, investigative
                             efforts resulted in 10
                             indictments and 21 convictions
                             Fines and recoveries, including
                             those associated with civil
                             actions, amounted to
                             $1,347,114 Twelve
                             administrative actions* were
                             taken as a result of
                             investigations
                             Resignations/Terminations   2

                             Suspensions               2

                             Reprimands               4

                             Other                    4
                             *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
                                         Profile of Pending Active
                                         Investigations by EPA Program Area
                                                                   MultiProg/Oth<
                                                                    16
                                                               Administration
                                                                 15 65%
                                          Superfund
                                          42 183%
                                                                                                  Enf & Compliance
                                                                                                   1  4%
                                                                            Solid Waste
                                                                             58 252%
      Procurement
      Fraud 22 96%
                                                                                                   Toxics
                                                                                                   1  3%
                  Total - 230
                                                                                    Total 230
26

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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 initiated before
April I 1989
Former EPA Asbestos
Inspector Pleads
Guilty to Conspiracy
Charge

Howard Stacker, a former EPA
Region 2 asbestos inspector,
pled guilty on June 26, 1989, to
conspiracy to accept bribes of
more than $170,000 from
asbestos removal contractors
during the years 1983 through
1987 Stecker was bribed to
overlook violations of EPA rules
and regulations regarding
asbestos removal proiects
conducted by the contractors,
and to avoid job sites at which
asbestos removal projects were
being earned out  EPA
regulations require that specific
practices be used during
demolition and  renovation of
structures  containing asbestos
to minimize the potential
exposure of workers and the
general public.
  A joint investigation of
Stecker and asbestos removal
contractors in the New York
metropolitan area by the EPA
Office of Inspector General and
the Office  of Labor
Racketeering of the U S
Department of Labor has
resulted in the indictment of 28
contractors, representing 19
companies To date, $606,000
in fines have been assessed
  In a related case, Gene
Belsole, owner  and operator of
Cleanco Industrial Services of
New York, Inc , pled guilty on
August 23, 1989,  to charges of
bribing  Stecker  Belsole is
expected to be  sentenced soon
                              Connecticut Quintet
                              Pleads Guilty in
                              Asbestos Case

                              James McGuire, president of
                              the United Painting Co , Bethel,
                              Connecticut, and four of his
                              employees, Christopher
                              Weldon, Jennifer Gabaordi,
                              Christopher Gabaordi, and
                              Steven  Kovacs, pled guilty to
                              charges arising from United's
                              use of workers who were
                                                            United Painting was hired to remove asbestos from the Julia
                                                            A Clark School in Stamford, CT  (DIG photo)
                                                            neither trained nor certified by
                                                            an EPA-approved training
                                                            program to remove asbestos
                                                            from public school buildings in
                                                            Bethel and Stamford,
                                                            Connecticut  McGuire pled
                                                            guilty to making false
                                                            statements to a Government
                                                            agency, the employees were
                                                            charged with violating the Toxic
                                                            Substances Control Act
                                                              This investigation was
                                                            conducted jointly by the EPA
                                                            Office of Inspector General and
                                                            the United States Postal
                                                            Inspection Service
Steel Company and
fts President Plead
Guilty to Fraud

The Rusco Steel Company and
its president, Robert S  Russell,
of Warwick, Rhode  Island, were
convicted of making false
statements on a minority
business certification application
filed with the Commonwealth of
Massachusetts Russell and
Rusco were each fined $10,000
Russell was also placed on 3
years probation and ordered to
perform 100 hours of
community service to the
minority community
  A joint investigation
conducted by the Offices of
Inspector General of the EPA,
U S General Services
Administration (GSA), and U S
Department of Transportation
(DOT) revealed that  Rusco was
named as a minority business
enterprise on numerous projects
funded by EPA, GSA, and DOT
                               Operator of North
                               Carolina Wastewater
                               Treatment Plants
                               Sentenced
John G Mason, former contract
operator of five wastewater
treatment plants in Wake
County, North Carolina, was
sentenced on June 13. 1989, to
2 years in prison (18 months of
which were suspended), a
$5,000 fine, 5 years of
supervised probation, and 384
hours of community service
work, for violations of  the Clean
Water Act  In addition, Mason
was barred from future
employment as a wastewater
treatment plant operator
  Mason pled guilty in January
1989 to two counts of
submitting false statements to
the North Carolina Department
of Natural Resources and
Community Development, while
he was the  contract operator of
the plants from November 1986
to October 1987 These false
statements  were violations of
the Clean Water Act because
that law provides that no
pollutants be discharged into
navigable waters of the United
States except under the terms
and conditions stated  in a
National Pollutant Discharge
Elimination System permit
                                                                                                                     27

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Car Importers Indicted
for False Certification

Lyle E  Lathe,  owner of L&L
International, Inc, Wilmington,
North Carolina, and John C Von
Essen,  owner  of Auto Craft
Canada and Exotic Motors,
Ontario, Canada, were indicted
August 15, 1989, for 11 counts
of mail fraud, forgery, currency
violations, and violations of EPA
and DOT regulations, stemming
from the import and sale of
foreign sports cars  Lathe was
in charge of the day-to-day
operations of L&L International,
which imported European luxury
vehicles and resold them  in the
United  States  His company
would also make the
modifications necessary to
convert the imported
automobiles to meet U S
emission standards
  A joint investigation  by  the
EPA DIG, U S Customs
Service, and DOT found that
between April 1986 and
October 1986 the defendants
were involved in a scheme to
circumvent EPA regulations and
Federal laws by falsely certifying
that the required emission work
had been completed on the
imported automobiles
Hazardous Waste
Cleanup Firm Indicted

Chem-tle Environmental
Sciences, Inc , San Antonio,
Texas, was indicted on July 31,
1989, by a grand jury in the
Middle District of North
Carolina Chem-tle, the EPA
Emergency Response Cleanup
Service Zone 2 contractor, was
charged in the two-count
indictment with submitting false
claims to EPA totaling
$177,62926
  The OIG investigation
revealed that Chem-tle billed
EPA for 3 months' operation of
a quality assurance program and
pollution liability insurance
coverage, which the firm
provided on the EPA  contract
  This indictment led to the
removal of Chem-tle as the
Zone 2 Emergency Response
Cleanup Services contractor
The value of this contract could
have totaled $14 million over a
3 year period
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 addition,
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
Three EPA
Headquarters
Employees Sentenced
in AMTRAK Fraud
Scheme

Three EPA Headquarters
employees were sentenced in
Washington, D C , on October
7, 1988, for their roles in an
attempt to defraud AMTRAK by
submitting false lost luggage
claims  The total dollar amount
of the fraud was $5,000,
representing 10 individual false
claims.
  One employee received a
sentence of 2  years probation
and 100 hours of community
service, plus restitution of
$4,750 The employee also
received a 30 day suspension
from EPA  Two other
employees got 1-year probation,
50 hours of community service,
and $100 restitution One
received a 7-day suspension
from EPA, and the other
received a letter of reprimand


Former EPA Employee
Convicted in Dallas

Ronald Gene Fisher, a former
Region 6 attorney, was
convicted for securing execution
of a document by deception
Another Region 6 attorney had
alleged that Fisher had forged
her name and  used her Texas
Bar Association number on a
lawsuit filed m Dallas County
Fisher was sentenced to 4
years in prison, suspended for
10 years, was fined $5,000, and
will be disbarred in Oklahoma,
the only State where he is
licensed to practice law
Civil And
Administrative
Actions To  Recover
EPA Funds
Investigations and audits of the
Office of Inspector General
provide the basis for civil and
administrative actions to recover
funds fraudulently obtained from
EPA Through the Inspector
General Division of the  Office of
General Counsel, the OIG uses
a variety of tools to  obtain
restitution  These include
cooperative efforts with the
Department of Justice in filing
civil suits under the  False
Claims Act, and other
author/ties, working with
grantees using their own civil
litigation authorities, invoking
the rest/tut/on provisions of the
Victim and Witness  Protection
Act during  criminal sentencing,
using the Agency's authority to
administratively offset future
payments and to collect debts,
and negotiating voluntary
settlements providing for
restitution  in the context of
suspension and debarment
actions
  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 EPA published  its  final
rule implementing the act in
April 1988, codified  at 40 C F R
Part 27  With these  regulations
in place, we are now evaluating
cases to bring to EPA's
administrative law judges for
adjudication and recovery
  Civil and administrative
actions to recover funds usually
extend over several semiannual
reporting periods Progress is
being made on several  such
matters •
 28

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EPA Wins $225,000
from Super-fund
Defrauders
Enmanco Corporation and three
of its officers, James Barnum,
Gary Domanski, and Daniel Toy,
consented in September 1989
to a judgment against them for
$225,000 in a Superfund fraud
case brought under the False
Claims Act
  The settlement of this case is
the latest phase of criminal,
civil, and administrative actions
against Enmanco  and the three
officers The case began in
1984 when an investigation by
the DIG, initiated  as a result of
an OIG audit, demonstrated that
Enmanco and the three officers
had submitted false payroll
costs, manifests,  and invoices
during the 1982-83 cleanup of
the Liquid Disposal Inc ,
hazardous waste  site in Utica,
Michigan  During  the
investigation, waste haulers
admitted driving empty and
partially-loaded trucks that
Enmanco had manifested as
full, and two firms admitted
paying  Enmanco kickbacks of
$25,041 and $11,355 for
receiving Enmanco's business
The defendants pled guilty  to
one count of conspiring to
defraud the Government with
respect to claims  and paid
criminal fines, served jail time,
and made restitution  of $32,181
under the Victim and Witness
Protection Act  In addition,  EPA
debarred Enmanco and the
three officers Government-wide
for 3 years
$440,000 Recovered  in
Georgia Bid Rigging
Claim
The Government recovered
$440,000 in April 1989 from two
of the defendants in a civil False
Claims Act suit brought against
three electrical construction
companies and their principals
who had rigged bids on the
EPA-funded Snapfmger Creek
wastewater treatment plant
project in DeKalb County,
Georgia, near Atlanta Paxson
Electric Co  and Wesley C
Paxson, Sr, its president,
agreed to pay the Government
$430,000 and $10,000,
respectively
EPA Wins $2.7 Million
Judgment Against
Chattanooga Bid
Riggers
A Federal court in Tennessee
granted EPA's claim for $2 7
million  against Fischbach &
Moore, Inc , and Paul Murphy in
May 1989 The Court found
Fischbach & Moore and Murphy
liable for rigging the bid for the
electrical work on the
EPA-funded Moccasin Bend
wastewater treatment plant in
Chattanooga, Tennessee. This
False Claims Act case followed
antitrust convictions of
Fischbach & Moore and
Commonwealth Electric  EPA
has already settled with other
defendants in the case, Paul
Schor, Sven Lofgren, and Phillip
Mahoney, for more than
$200,000
Philadelphia Shares
Antitrust Recoveries
with EPA
The city of Philadelphia has paid
$120,000 to EPA from the
proceeds of its lawsuit against
five electrical contractors who
rigged the bids on an
EPA-fmanced wastewater
treatment project  The city had
received $260,000 from
settlements with the
contractors  The U S Attorney's
Office estimates that the bid
rigging conspiracy inflated the
cost of the project by about
$200,000 EPA financed 75
percent of the rigged contract
The City's lawsuit was  based on
Federal antitrust convictions of
Leonard A Nucero, Sr, the
Nucero Corporation, and
Wilhard, Inc , and the related
perjury conviction of Ronald P
Kaczmarek, of the Reiter
Construction Company  The
Office of Inspector General
participated  in the investigation
that led to those convictions
We commend the city's
cooperative spirit and its
aggressiveness in pursuing its
civil remedies
                                                                                                                      29

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 o6CtlOn   4—Fraud  Prevention and Resource Management  Improvements
This section describes several
activities of the Office of
Inspector General to promote
economy and efficiency and
to prevent  and detect fraud,
waste, and abuse in the
administration of EPA
programs and operations.
This section includes
information required by
statute, recommended by
Senate report, or deemed
appropriate by the Inspector
General.
Review Of
Legislation And
Regulations
Section 4(a)(2) of the Inspector
General Act of 1978, as
amended, directs the Office of
Inspector General to review
existing and proposed legislation
and regulations relating to
programs and operations to
determine their effect on
economy and efficiency and the
prevention and detection of
fraud and abuse  This
semiannual reporting period, we
reviewed 20 legislative and 41
regulatory items. The most
significant items  reviewed are
summarized below.
Consultant
Registration and
Reform Act of 1988

We supported the primary
objective of the act, to
strengthen controls over
advisory and assistance service
contracts However, we
disagreed with the statement
that the Inspectors General
have not consistently complied
with the requirement to submit
to Congress certain evaluations
relating to contracts for
consulting services Our Internal
Audit Division performs the
annual review required by 31
U S.C 1114 (b), and has issued
its report every year since 1984
as required
  In addition, we suggested
that a more restricted definition
of advisory and assistance
service contracts be included in
the bill Our audit service
contracts could be considered
advisory and assistance service
contracts, and we do not
believe that the use of such
contracts prompted the
development of the bill
Therefore, the legislation should
clearly distinguish between an
agency's use of consultants and
the OIG's use of external
auditors.
  The bill also requires
employees who award or
modify a contract for advisory or
assistance services to transmit
action documents to the OIG
We suggested clarification of
this requirement since the
OIG's responsibility concerning
these documents was not
prescribed  Finally, we
recommended that the bill be
revised to permit the head of
the agency  or his/her designee
to prepare the written
evaluation of the  contractor's
performance and to specify that
only the OIG can evaluate the
performance of any contractor
performing  work for the OIG
                                                             Consultant Disclosure
                                                             and Fraud Prevention
                                                             Act of 1989

                                                             We opposed H R 3145, which
                                                             would require consultants to
                                                             applicants for assistance from
                                                             Federal  agencies to submit
information about their role to
the appropriate Inspector
General or other officer. We
view the collection of such data
as a programmatic function and
do not believe that the
Inspectors General should be
involved in the process
Requiring routine administrative
handling and scrutiny of this
data by Inspectors General
would tend to defeat those
provisions  of the Inspector
General Act of 1978, as
amended, which separate the
Inspectors General from  the
programmatic functions of their
agencies. We believe that a
better approach would be for
agencies to collect information
on consultant activities as a part
of each application for Federal
assistance The Inspectors
General could then access the
information as needed.


1989 RCRA Civil
Penalty Policy

We said that a revised draft of
the 1989 RCRA Civil Penalty
Policy would dilute the Agency's
ability to use its statutory
authority to assess penalties of
up to $25,000 per day, per
violation The policy did not (1)
provide assurance that regional
enforcement personnel would
verify the accuracy and
legitimacy of evidence
submitted by violators or (2)
prevent lump sum  penalty
settlements without adequate
justifications. In effect, the
revised policy reflects the
Agency's expectation that
proposed penalties will continue
to be significantly reduced
during settlement negotiations.
We believe this will send a clear
message to the regulated
community that proposed
penalties are a scare tactic not
to be taken seriously, which is
inconsistent with the
Administrator's  recent
pronouncements on the  "get
tough" enforcement policies of
the Agency.


Solid Waste Export
and  Import Act of
1989

In our opinion, the provisions  of
the EPA draft bill "Solid Waste
Export and Import Act of 1989,"
30

-------
do not adequately provide for
EPA to be notified of an intent
to export/import hazardous
waste Further, the draft bill
does not specify EPA's authority
or ability to make enforcement
determinations when companies
have actually exported
hazardous waste and violated
the annual reporting
requirement The draft bill does
require that the Administrator,
when assessing a penalty, take
into account the seriousness of
the violation and any good faith
efforts to comply with
applicable requirements
However, we believe there
should also be a requirement for
the Administrator to consider
whether a violator is a repeat
offender when assessing
penalties

External Quality
Control Reviews
The draft PCIE policy statement
on external quality control
reviews, in our opinion, was
unclear about whether a
formalized review team must be
created to determine if an audit
organization is following
adequate audit policies and
applicable auditing standards
Our internal quality control
system includes written audit
policies and procedures in the
form of an Office of Inspector
General Manual, and
management assessment
reviews (MARs) as well as  OIG
Bulletins and Staff
Memorandums  In addition, our
audit managers perform reviews
as required by the Federal
Managers Financial Integrity Act
(FMFIA) We believe that these
mechanisms are sufficient to
provide an adequate internal
control system where
compliance is reviewed and
evaluated by senior audit
managers. Thus, we believe
that no demonstrated need
exists for establishing an
external quality control review
team, and that such a team
would duplicate the functions
performed through other OIG
procedures
Suspension And
Debarrnent
Activities
EPA's policy is to do business
only with contractors and
grantees who are honest and
responsible  EPA enforces this
policy by suspending or
debarring contractors or
grantees from further EPA
involvement Causes for
debarment include conviction of,
or civil judgment for,

•  commission of a fraud or a
criminal offense in connection
with obtaining, attempting to
obtain, or performing a public
contract or subcontract,

•  violation of Federal or  State
antitrust statutes relating to the
submission of offers,

•  commission of
embezzlement, theft,  forgery,
bribery,  falsification or
destruction of records, making a
false statement, or receiving
stolen property, or
•  commission of any other
offense indicating a lack  of
business integrity or business
honesty that seriously and
directly affects the present
responsibility of a government
contractor or subcontractor

A contractor may also be
debarred for violating  the terms
of a government contract or
subcontract, such as willful
failure to perform in accordance
with the terms of one or more
contracts, or a history of failure
to perform, or of unsatisfactory
performance on one or more
contracts  A contractor may also
be debarred for any other cause
of so serious or compelling a
nature that it affects the  present
responsibility of the contractor
Thus, a contractor need not
have committed fraud or be
convicted of an offense to
warrant being debarred
Debarments are to be for a
period commensurate with the
seriousness of the cause, but
are generally not to exceed 3
years
  The effectiveness of the
suspension and debarment
(S&D) program has been
enhanced by regulations that
provide all Federal agencies a
uniform system for debarring
contractors from receiving work
funded by Federal grants, loans,
or cooperative agreements  The
system, required by Executive
Order 12549,  provides
that a nonprocurement
debarment or suspension by
one agency is effective in all
and requires the General
Services Administration (GSA) to
publish monthly a "List of
Parties Excluded from Federal
Procurement or
Nonprocurement Programs "
Formerly, a nonprocurement
debarment was effective only in
the programs administered by
the debarring agency, and each
agency maintained its own  list
   The EPA Grants
Administration Division operates
the S&D  program at EPA  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
   The OIG's Suspension and
Debarment Unit has been
working with  the Grants
Administration Division to
further educate and inform
State and local environmental
interest groups of the
devastating effects that a
suspension or debarment has
on dishonest or nonresponsible
contractors
Summary of
Suspension and
Debarment Activities

The following is a summary of
S&D actions taken during this
reporting period
            April 1, to
            Sept. 30,      Fiscal
              1989        1989
CASES OPENED
DURING
PERIOD         35         117
CASES COMPLETED
Debarments
Voluntary
exclusions
Settlements
Closed after
investigation
Total
11

2
8

72
93
42

5
25

94
166
                Active cases as
          of September 30, 1989
Under investigation            15
Under program or counsel
  review                   203
Proposed for debarment         2
Suspended or suspended and
proposed for debarment         2

Total                     222

The following are several
examples

• EPA debarred B E S
Environmental Specialists (BES)
and its founder, Richard
Baranowski, on June 12, 1989,
for 21 months  BES  was the
emergency removal  contractor
on the  Brown's  Battery site in
Berks County, Pennsylvania
Based on evidence developed in
an EPA OIG investigation the
hearing officer found that
Baranowski had done free
construction work on the
on-scene coordinator's house
and had taken him on an
expense-paid Canadian vacation
BES' refusal to turn  over
records to the Office of
Inspector General for an audit
was another ground  for
debarment  Prior to the
decision, BES had been
suspended  for 11 months
                                                                                                                         31

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• Denver Asbestos Control
Technology,  Inc , (DACT), Rocky
Mountain Applications,
Environmental Contracting
Services and their officers, Joel
Lederman and James Hellman,
have been debarred from
participation  in Federal
assistance, loan, and benefit
programs for 3 years  The
debarment followed Lederman's
plea of guilty to submitting false
statements certifying  the health
conditions of DACT employees,
and aiding and abetting  in
connection with asbestos
violations  Hellman pled guilty  to
bribery and making false
statements concerning loan or
credit applications in connection
with the asbestos program

• Joseph  P  Grana, former vice
president of  Amelco Industries,
was debarred from further
participation  in Federal
assistance, loan, and benefit
programs for 3 years
commencing September 12,
1989  After conspiring to rig
bids for electrical work to be
done at Powerlme Oil
Company's refinery in Santa Fe
Springs, California, the
Department  of the Army
debarred  Amelco from all
federal procurement activities
for 8 months EPA also
proposed to  debar Amelco
under its  regulations As a
result, Amelco signed a
compliance agreement with
EPA, dismissed Mr Grana, and
established a new corporate
policy mandating compliance
with antitrust regulations

• Irwin Pearlman of Pittsburgh,
Pennsylvania, was debarred for
3 years on July 27, 1989
following his conviction  for
criminal violations of the Clean
Air Act and aiding and abetting
These violations for the
stripping and removal of friable
asbestos occurred at a privately
owned facility which was under
renovation Although there was
no involvement of EPA funds,
the nature of Mr Pearlman's
business was such that he
could become  a potential bidder
on EPA-funded contracts

• Clarence S  Benton, former
vice president of
Williams-McWilliams Company,
Inc  , has signed a compliance
agreement with EPA for a
6-month debarment from
participation in all Federal
assistance, loan, and benefit
programs  The corporation was
twice convicted of Sherman Act
violations for conspiring to
suppress and  eliminate
competition for contracts with
the U S Army Corps of
Engineers for  dredging services
in the Gulf of  Mexico
Williams-McWilliams Company
has also been debarred by the
Department of the Army from
direct Federal procurement
activities through January  28,
1990

• Eason  & Smith Enterprises,
Inc  (E&S) of Oklahoma City,
Oklahoma, signed a compliance
agreement with EPA excluding
them from participation in  EPA
assistance programs  E&S was
convicted of unlawfully storing
hazardous wastes in violation of
Resource Conservation and
Recovery Act  requirements  The
Defense  Logistics Agency also
debarred E&S for 2 years

• EPA executed a compliance
agreement with Brewton
Materials, Inc , Dothan,
Alabama, debarring them from
participation in EPA assistance
programs for a 60-day period
Brewton  Materials, Inc , was
convicted in February 1988 of
violating the Sherman Act by
conspiring to fix the price  of
concrete block in Alabama and
Florida

• After initially proposing a
debarment, EPA executed a
compliance agreement with
Luedtke Engineering Company
(LEG) of Frankfurt, Michigan
LEG was convicted of bid
rigging on a Federal dredging
contract with  the Department of
the Army (DOA) in  Cleveland,
Ohio  After DOA also entered
into a settlement agreement
with LEG, EPA discontinued
debarment proceedings
Employee  And
Public Awareness
A continuing priority of the
Office of Inspector General is to
enhance public awareness of 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 Office of Inspector General
We have also found that while
many Agency employees  and
managers are concerned about
the possibility of fraud and
abuse in EPA and sincerely
want to learn how to detect or
prevent it, several others appear
naive to its existence or even
reject the possibility of it
happening  Although they may
not be in violation of law,
employees who maintain
anything but a strictly
arm's-length relation with any
contractor, and any contractor
that performs with anything less
than good faith, represent a risk
to the integrity of the
competitive  procurement
process and what EPA gets for
its money We believe that EPA
employees are in the best
position to detect, prevent, and
report fraud, waste, and abuse
if they can recognize it
  We have used a variety of
media to provide information
and encourage specific
segments of the concerned
population to recognize and
report conditions or actions that
threaten EPA's resources or
mission OIG-developed
publications, videotapes,
presentations, and training help
prepare EPA project or program
managers and employees to
identify and  report suspected
indicators of fraud that
otherwise may have gone
unnoticed
Presentations

John C  Martin, Inspector
General, spoke on "Quality
Work and  White Collar Crime"
at the annual conference of the
American  Consulting Engineers
Council in  Scottsdale, Arizona, in
May
  Mr Martin also spoke at the
National Professional
Conference of the Association
of Government Accountants in
Los Angeles in June His topic
was "Blueprint for Fraud
Auditing  New Requirements
and Implementation "
  John E.  Barden, Assistant
Inspector  General for
Investigations, made a
presentation on fraud prevention
to the Contract Lab  Program
Superfund Automated Analytical
Data Management Caucus The
Caucus met in June in Las
Vegas The contract lab program
is one of the  OIG's areas of
emphasis  during fiscal 1990
  Representatives from OIG
and the Grants Administration
Division  gave a presentation on
suspension and debarment to
the Northeast Hazardous Waste
Project Conference in
September 1989 at
Williamsburg, Virginia The
Project, a  multi-State effort
designed to address the
problem of illegal activity in the
area of hazardous waste, is
composed of representatives
from the attorneys' general
offices, the regulatory agencies,
and the criminal investigative
units from the 14 Northeast
States, as  well as
representatives from the U S
EPA National Enforcement
Investigations Center
  Michael  J  Binder, Director of
OIG's Administrative
Management and Services
Division, made a presentation
on management of time at the
annual professional
development conference, held
in June, of the Philadelphia
chapter,  Association of
Government Accountants
32

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Semiannual Reports

Over 1,500 copies of each
semiannual report to Congress
are distributed to members of
Congress on EPA-related
committees, top EPA managers,
news media (including wire
services), State agencies
administering EPA programs,
State attorneys general, citizens
(by request), EPA libraries, and
selected environmental groups

Articles and Publications

Two brochures, "What to do
Before and After the Auditors
Arrive" and "What an
Investigation Means  to You,"
have been updated and are
being distributed to EPA
employees and the general
public  Also, we have continued
to develop and publish articles
for EPA managers and
employees by working with the
EPA Office of Public  Affairs  In
addition, numerous articles have
been published by newspapers
nationwide concerning the
results of our most significant
audits and investigations
 Personnel Security
 Program
The personnel security program
is one of the Agency's first-line
defenses against fraud, using
background and National
Agency Check and Inquiries
investigations to review the
integrity of EPA employees and
contractors
  During this semiannual
reporting period, the Personnel
Security Staff reviewed 371
investigations  The following
conditions were identified and
administrative actions taken

• One employee received  a
14-day suspension for omitting
previous convictions and prior
firings in applying  for
employment with  EPA on an
SF-171

• One employee received  a
written  reprimand  for
intentionally falsifying the
SF-171  used to gam
employment with  EPA by failing
to disclose a prior criminal
conviction.

• One employee received  an
oral reprimand for falsifying the
SF-171  used to gain
employment with  EPA by not
disclosing a prior criminal
conviction

• Twelve employees were
required to submit corrected
SF-171s for failure to list
previous misdemeanors and
minor convictions
• One employee resigned  in
lieu of an administrative removal
for  unsatisfactory performance
and failure to list previous firings
on the SF-171 used to gain
employment with  EPA

We continue working closely
with Agency program officials
on the implementation of the
0PM  regulations regarding
position sensitivity designations
and granting of clearances
  We are also entering
information into an operational
computer system which
provides management reports
on the status of ongoing
investigations It also provides
reports on those investigations
which need updating
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
 strengthen the effectiveness of
 the entire Inspector General
 community Headed by the
 Deputy Director, Office of
 Management and Budget, PCIE
 members include the Inspectors
 General and other key Federal
 officials
  John C Martin is the chair of
 the Administration, Inspections,
 and Special Reviews
 Committee, one of the PCIE's
 standing committees  The
 standing committees  are the
 means the PCIE uses to get its
 work accomplished The
 functions of Mr Martin's
 committee are to
 • Serve as the focus  to
 promote good administrative
 practices within the IG
 community,
 • 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 quality
 standards for Office of Inspector
 General investigations,
 • 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

  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,  and executive
 development The
 Communications Subcommittee
 advances  PCIE goals by
 publishing compendiums of
 PCIE publications, providing
 speakers to discuss fraud,
 waste, abuse,  and
 mismanagement topics, and
 promoting a national awareness
 campaign by use of publications
 to foster governmental
 economy and efficiency
  EPA OIG personnel participate
 as members of the Computer,
 Training and Communications
 Subcommittees and chair the
 Support Activities Training work
 group
  Three Inspectors General.
John Martin of EPA, James
 Richards of Interior,  and Richard
 Kusserow of Health and Human
 Services, serve on the National
Advisory Commission on Law
 Enforcement  This commission,
chaired by Charles Bowsher,
 Comptroller General of the
 United States,  is concerned
with issues affecting the
administration and coordination
of law enforcement efforts
throughout the country
  Staff of  the EPA Office of
Inspector General participated  in
or led a number of Committee
special reviews and projects
during this semiannnual
reporting period Some of the
activities are summarized
below

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IG's Confer with OMB
Executive at FBI Academy

In April 1989, the PCIE met for
a 2-day conference at the FBI
Academy in Quantico, VA
Coordinated by John Martin, the
conference provided an
opportunity for the  members to
meet Frank Hodsoll, Executive
Associate Director of the Office
of Management and Budget
Mr Hodsoll briefed the
members on issues of particular
interest to the PCIE and opened
the discussion for input from all
of those present The IGs
discussed current and future
PCIE projects which might
dovetail with Administration
initiatives

Survey on  Performance
Review Boards Completed

In June 1989, the Committee
completed a survey on the
establishment of a  roster of  OIG
executives  to serve on
performance review boards for
Senior Executive Service
employees  within the PCIE
community Based  on the
positive responses, the
committee  established a  PCIE
performance review board
roster and published it in  the
Federal Register

IG Database Found Not
Warranted

The committee also completed
a survey on the  potential
usefulness  of establishing a
data base of IG  findings and
investigations of general interest
to the IG community  Although
there was support for the
concept, there were concerns
regarding the significant amount
of work to maintain such a
system, and difficulty in
agreeing on a common
classification system given
differences  in agency programs
The data base will not be
established
Semiannual Reports Seminar
Held on Capitol Hill
In August 1989, the PCIE
Support Activities Work Group
sponsored a combined
management forum and work
group seminar; the subject was
OIG semiannual reports The
all-day session was held at the
Rayburn House Office Building
and was attended  by over 150
representatives of  the IG
community
  The seminar  began with
keynote addresses by
Inspectors General John Martin
and James  Richards of the
Department of  the Interior, who
discussed their philosophy on
semiannual reports and the
reports' value to agencies,
OIGs, Congress, and the  public
Next,  four  staffers from the
Committee on Governmental
Affairs, Committee on
Government Operations, and
House Committee on
Appropriations discussed how
Congress uses the reports and
how the reports can be
improved Three executives
from the Department of Health
and Human Services then
discussed the new semiannual
reporting requirements The rest
of the day was devoted to a
hands-on workshop on how to
prepare a semiannual  report
Employees responsible for
preparing the reports in five
OIGs discussed aspects ranging
from developing a  schedule to
arranging for printing and
composing  a mailing list
  The forum was  led by
Michael J  Binder of EPA, chair
of the Support  Activities
Working Group
Steve Ryan,  counsel to the
Senate Government Operations
Committee, was a speaker at
the seminar on semiannual
reports (OIG photo)
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
comprised of senior EPA
program and regional officials
and is chaired by the Inspector
General  The following
examples describe projects
completed during this reporting
period

Computer Advisory On
Physical Security  for
Microcomputers

Physical security once meant
keeping a  computer and its
information from physical harm
by surrounding the computer
facility with locks, fences, and
guards. Today's computer
environment is often a typical
office setting with  several
microcomputers, word
processors, and portable
terminals  Consequently,
physical  security has changed to
accommodate these realities
Because the Agency has made
substantial investments  in
microcomputers, workstations,
and related equipment, CIMI
developed a  computer advisory
to provide guidelines which
would assist employees in
safeguarding these valuable
assets
Federal Telecommunications
Systems Leaflet

Although Government audits of
telephone use have long
disclosed significant,
widespread abuse, narrow
interpretations of what
constitutes an official call have
undermined efforts to eliminate
abuse. GSA amended the
Federal Information Resources
Management Regulations
(FIRMR) to permit employees to
make reasonable use of
Government telephone
systems, including placing calls
which were previously
prohibited, while simultaneously
guarding against telephone
abuse  To make EPA
employees, contractors, and
managers aware of real as well
as potential abuse, and to clarify
EPA policy regarding authorized
and unauthorized use of
Government telephones, CIMI
developed a leaflet describing
methods for detecting,
curtailing, and deterring
telephone abuse and providing
examples of permissible official
business calls
Awareness Bulletin on Bribes
and Gratuities

Bribery—that is, offering,
providing, or accepting anything
of value to induce or reward
performance or nonperformance
of official acts—is a serious
crime In addition, accepting
certain gifts, gratuities, or
entertainment violates EPA
regulations, even if there is no
statutory violation To make
employees aware of their
responsibilities regarding bribes
and gratuities, CIMI developed
an awareness bulletin outlining
what employees  should do
when a  bribe or gratuity is
offered  In addition, the bulletin
lists exceptions when the
acceptance of a gratuity is
permissible
34

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Hotline Activities
The OIG Hotline Center
received 36 new complaints and
completed and closed 37 cases
during the reporting period Of
the 37 cases closed,  11 cases
resulted in environmental,
prosecutive, or administrative
corrective action, while 26 did
not require  action Cases that
did not have immediate validity
due to insufficient information
may be used to identify trends
or patterns  of potentially
vulnerable areas for future
review The hotline also
received 871 telephone calls
where callers were referred to
the appropriate program office,
State agency, or other Federal
agency for assistance
  The following are examples of
corrective action taken as a
result of information provided to
the OIG Hotline Center

•  A complaint alleged that
medical waste was being
improperly burned and that the
particles emitted were
endangering nearby homes and
foliage  A review of the
complaint disclosed that a local
hospital had been ordered by
the State to extend its
incinerator stack  The hospital
complied but failed to extend
the stack to a height sufficient
to prevent a downwash of
emissions into the surrounding
community As a result of this
complaint, the State has
required the hospital to develop
a plan to reduce emissions from
its incinerator and to increase
the height of the incinerator
stack to prevent pollution of the
neighborhood The State has
also drafted new regulations
which would allow further
regulation of hospital waste
incinerators through control of
toxic emissions  A working
group has been formed by the
State to develop rules
controlling toxic emissions, and
EPA is assisting the group in an
advisory capacity
• A complaint alleged waste of
Government funds A review of
the complaint disclosed that
new file cabinets were
repainted and new desk tops
were provided for Superfund
work stations to coordinate the
color scheme,  at a cost of
$27,225 Additional expense of
$350 was  incurred for overtime
of personnel to supervise the
repainting  of the cabinets The
complaint  also disclosed that
unserviceable excess furniture
was shipped between Regions
and then stored in a commercial
warehouse for 4 months
pending GSA approval for
disposal since  it had no market
value  The cost for transporting
and storing the unusable items
was $10,738 The office that
transported the furniture
continued  to carry the items on
the property records because
property transfer documents
were not prepared As a result
of this complaint, the Agency
took steps to improve the
controls over the procurement
and management of property,
furniture, and equipment and to
minimize unnecessary
expenses
Professional  And
Organizational
Development
During fiscal 1989, the EPA OIG
continued to expand on
initiatives started during fiscal
1988 while beginning new ones
to improve our organizational
skills,  relationships, efficiency,
and effectiveness Areas of the
greatest activity include the
development and  presentation
of several technical and
management courses by our
staff, leadership in professional
associations, proiects of our
Human Resources Council,
publication and distribution of
our own training catalog, and
organizationwide training on
self-awareness and
organizational culture For the
semiannual period ending
September 30, 1989 we
approved 416 training
enrollments for a total of 1,287
days of training and participation
in professional development
seminars and conferences

OIG Developed Courses

• Detection and Prevention of
Fraud

This course was developed to
prepare independent public
accountants doing work for the
EPA OIG to detect and refer
possible instances of fraud to
the OIG for criminal
investigation We  prepared staff
members in each  divisional
office to present this course in
their own geographical
locations  During this
semiannual period, we
presented the course once
through the EPA Institute and
also in Memphis, Tennessee, to
members of our Southern Audit
staff, auditors from the
Tennessee State Comptroller's
office, and independent public
accountants performing audit
work for the OIG  We will
continue presenting this course
through the EPA Institute and to
independent public accountants
in fiscal 1990
•  Effective Briefing Techniques

This course is designed to
prepare auditors, investigators,
and managers to give effective
and persuasive  presentations,
deal with confrontational
situations, and improve
OIG/chent relations  This course
includes sections on effective
oral communication, visual
imagery, confrontational
management, and a video
workshop This  course stresses
the importance  of (1) teamwork
between OIG employees and
Agency management and (2)
creating a strong and credible
image of OIG staff members
and work products We
presented this course once in
Headquarters and once in
Boston to our Eastern and
Mid-Atlantic Audit staffs

• Auditing Superfund Activities
Orientation

During this semiannual reporting
period, we completed plans and
materials and presented  a  "dry
run" of a course on auditing the
Superfund The  development of
this course, coordinated  by the
OIG training specialist, is a
combined  effort of  ail three
primary components of the OIG
and is scheduled for a pilot
presentation in early 1990

OIG Training Activities

Three contract courses were
presented during this period

• Management of Time  The
purpose of this training is to
eliminate self-defeating
behaviors relating to time
management

• Introduction to ADP Auditing
A foundation  in ADP concepts,
including such areas as
operating systems, data base
management  concepts, system
development  life cycle,
microcomputers,
communications, and computer
security

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• Operational Auditing Based
on GAO Techniques This
course simulates actual
experience in conducting an
operational audit, developing
findings, and preparing a draft
report

  Also, an orientation for all new
OIG employees was held in
Washington, D C  in April
  A training information
management system developed
by the Office of Inspector
General, Department of Health
and Human Services, has been
modified and is in use by the
EPA OIG to track the
completion of continuing
professional education courses
required by the General
Accounting Office in its "yellow
book" of standards  The
standards  require anyone
performing or managing
Government audits to receive at
least 80 hours of continuing
professional training every 2
years, including at least 24
hours directly related to
Government auditing Also, at
least 20 of the total 80  hours
must be taken during 1 of  the 2
years


Human Resources Council
The OIG Human Resources
Council (HRC), composed of 16
OIG  employees representing all
grade levels and geographical
locations,  advises and assists
the Inspector General in
developing effective policies,
strategies, and programs for
employee development and
work force management  The
Council is chaired by the Acting
Assistant  Inspector General for
Management and Technical
Assessment
  A meeting of the  HRC was
held September 11-13,  1989, in
Boston, Massachusetts  Council
members  reviewed  the HRC's
significant accomplishments
during fiscal 1989
• developing a booklet which
describes the physical exam,
counseling, and fitness services
available at Headquarters and
each EPA region  The booklet
was originally conceived as an
informational document for OIG
employees  However,
recognizing the widespread
interest in  this information, we
distributed the booklet to all
EPA employees in Headquarters
and the 10 regions

• holding an orientation session
for new OIG employees at
Headquarters

• examining the Agency's leave
donation program, determining
that OIG employees are covered
under the Headquarters
employee pool, and deciding not
to initiate a separate OIG
program
• developing and instituting a
pilot program in our Boston
office for rewarding deserving
employees in innovative ways

  In previous semiannual reports,
we discussed the OIG's
initiation of a 5/4-9 compressed
work schedule The OIG was
the first Headquarters
organization to begin such a
program, and we are pleased to
report that nearly all EPA
Headquarters offices have
followed our lead and initiated
compressed work schedules
Surveys in the OIG  and
throughout Headquarters show
a dramatic increase in morale
with no negative impact on
productivity or work quality The
OIG's compressed schedule has
been extended through July
1990
  When we began our
compressed schedule in
February 1988, we generated
significant interest in the IG
community since we were the
first OIG to offer this benefit
We briefed many OIGs on our
program and provided copies  of
our policy on request  We
recently learned that at least
two other OiGs—at the
Departments of Education and
Agriculture—are now offering a
compressed work schedule  At
an October 1989 PCIE seminar,
top managers from both OIGs
expressed keen satisfaction
with the schedule and the
demonstrable increase in morale
in their offices
36

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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

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 Department of Justice or
the General Accounting  Office
for approval of the final
resolution of the debts
However, the Claims Officer
need not immediately refer
debts over $20,000 until all
Agency collection actions have
been taken.
  As of September 30, 1989,
the Claims  Officer reported 19
accounts receivable valued at
$1,890,185  For this reporting
period, the Claims Officer
• terminated four debts totaling
$109,907 because of the
debtors' inability to pay,

• compromised two $253,101
debts for $126,404,
• returned one debt for
$30,789 to the Financial
Management Division for
regional office action, and

• collected one $13,822 debt

   The DIG did not verify the
Claims  Officer's figures.

Agency Collection Efforts

The Financial Management
Division provided the following
summary of EPA's collection
efforts for March 1 through
September 30, 1989  Although
the figures reflect the Agency's
accounting records as of
September 30, 1989, they were
obtained before the closing
process. Therefore,  these may
not be the Agency's final
figures  The OIG did not verify
the amounts presented below
                                                                Collections

                                                                Amounts Written Off


                                                                Interest Assessed

                                                                Interest Collected


                                                                Accounts Receivable

                                                                Non-Federal
                                                                  90 days or less
                                                                  Over 90 days
                                                $131,789,276
                                                    195,287
                                                 $8,378,538
                                                 92,657,214
                                                                Subtotal
                                                                 Interagency Agreements
                                                                  Total
                                                 101,035,753**

                                                    790,043***
                                                 101,825,796
                                                                *The Financial Management
                                                                Division did not provide amounts for
                                                                interest assessed and interest
                                                                collected due to complications
                                                                resulting from the implementation
                                                                of the Integrated Financial
                                                                Management System

                                                                **Agency records show that 33
                                                                percent of this amount is
                                                                receivables which are being
                                                                appealed  Collection actions are
                                                                suspended until the appeals process
                                                                is complete

                                                                ***This 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 31 percent of the
                                                                lOtal in this category is over 90 days
                                                                old
                                                                                                                            37

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       Appendix — Audit  Reports  Issued
   THE INSPECTOR GENERAL ACT REQUIRES A LISTING, SUBDIVIDED ACCORDING TO SUBJECT MATTER, OF EACH AUDIT REPORT ISSUED BY
THE OFFICE DURING THE REPORTING PERIOD AND FOR EACH AUDIT REPORT, WHERE APPLICABLE, THE DOLLAR VALUE OF QUESTIONED
COSTS AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE.
Audit Control Auditee
Number
1. INTERNAL & MANAGEMENT AUDfTS
E1S9F9-01-0144-9100338 SITE REVIEW: WATERBORO ME
TOTAL OF REGION 01 = 1
E1HW*8-02-0 133-9 100476 NPDES PERMITS - REGION 2
E1XM*8-02-0059-9 100505 CARIBBEAN FIELD OFFICE PR
TOTAL OF REGION 02 = 2
E1H9*8-03-0208-9 100467 POINT SOURCE POLLUTION ENTERING
THE CHESAPEAKE BAY
E1 £1*8-03-0161 -91 00486 ASBESTOS LOANS & GRANTS - REGION 3
E1 08*8-03-0160-9100487 LEAKING UNDERGROUND STORAGE TANK
PROGRAM - REGION 3
TOTAL OF REGION 03 = 3
E1HWD8-04-0207-9 100462 NPDES PERMITS - REGION 4
TOTAL OF REGION 04 = 1
E1H1F8-05-0528-91 00474 GREAT LAKES GRANTS PROGRAM
E1G8E9-05-0087-91 00485 PENALTY CAPPING REPORT
E1SHD9-05-001 9-91 00493 REMOVAL ACTIONS MANAGEMENT -
REGION 5
E1SHG9-05-0374-9400034 SITE REVIEW: KELLY KOET OH
E1SHG9-05-0373-9400035 SITE REVIEW. BROOKS FOUNDRY Ml
E1KAG9-05-011 1-9400044 ASBESTOS NESHAPS' FOLLOWUP
E1GMG9-05-0469-9400045 PENALTY INFO TO IRS FOLLOWUP
E1SHG9-05-0403-9400046 SITE REVIEW: ENGINUITY IN
E6FGG9-05-0272-9400033 SPECIAL REVIEW: OAK GROVE MN
TOTAL OF REGION 05 = 9
E1SHD9-06-0017-9100513 REMOVAL ACTIONS MANAGEMENT -
REGION 6
TOTAL OF REGION 06 = 1
E1F5*8-09-0184-9100446 ADMINISTRATION OF HAWAII'S
GRANT PROGRAMS
E1G6*8-09-01 88-91 00479 RCRA FINES CONSOLIDATED CA
E1SHG9-09-01 11-9400042 SITE REVIEW: MIDDLEFIELD/
ELLIS CA
E1AMG9-09-6000-9400047 LETTER OF CREDIT: FOLLOWUP
REGION 9 CA
TOTAL OF REGION 09 = 4
E1SFV-1 1-0037-9100236 AGENCY'S SUPERFUND ANNUAL REPORT
E1EPG9-1 1-0026-9400027 FIFRA REVOLVING FUNDS
P1SFF8-1 1-0048-91 00488 TRUST FUND AUDIT FISCAL 1988
E6AMG9-1 1-0025-9400029 COM - FPC VA
TOTAL OF HDQ - IAD AUDITS = 4
E 1 HWG9- 1 3-002 1 -9400037 ANTARCTICA
E1AMG9-13-0023-9400041 AGENCY'S AUDIT FOLLOW-UP SYSTEM
E1AMG9-13-0022-9400048 ACCOUNTS RECEIVABLE ESTABLISHED
FOR AUDIT REPORTS' SUSTAINED COST
TO BE RECOVERED
TOTAL OF HDQ - SR AUDITS = 3
TOTAL INTERNAL & MANAGEMENT AUDITS = 28
2. CONSTRUCTION GRANT AUDITS
E2CW*8-0 1-0 195-9 100445 WAREHAM MA
E2EW*8-01 -0370-91 00510 DEP 205G MA
P2CW*7-01-0177-9100301 DURHAM NH
P2CW*7-01-0010-9100339 STRATFORD CT
P2CW*8-0 1-0027-9 100356 NEW HAVEN CT
P2CW6-01-0278-9100367 EAST PROVIDENCE Rl
Final Report Ineligible
Issued Costs

6/29/89

9/13/89
9/28/89

9/11/89

9/20/89
9/21/89


9/ 7/89

9/12/89
9/27/89
9/29/89

6/21/89
6/22/89
9/28/89
9/29/89
9/29/89
6/21/89

9/29/89


8/29/89

9/18/89
9/22/89

9/29/89


4/ 6/89
4/13/89
9/22/89
4/19/89

9/11/89
9/21/89
9/29/89





8/28/89
9/29/89
6/ 1/89
6/29/89
7/10/89
7/13/89

0
0
0
0
0
0

0
0

0
0
0
0
0
0

0
0
0
0
0
0
0
0

0
0

0
0

0

0
0
0
0
0
0
0
0
0


0
0

535,124
2,978,630
1,620
25,235
655,622
3,521
Unsupported Unnecessary/ Efficiencies
Costs Unreasonable (Funds Be Put
Costs To Better Use)

0
0
0
0
0
0

0
0

0
0
0
0
0
0

0
0
0
0
0
0
0
0

0
0

0
0

0

0
0
0
0
0
0
0
0
0


0
0

240,062
9,785,330
0
0
53,486
31,325

0
0
0
0
0
0

0
0

0
0
0
0
0
0

0
0
0
0
0
0
0
0

0
0

0
0

0

0
0
0
0
0
0
0
0
0


0
0

0
0
11,250
0
0
0

0
0
0
0
0
0

901,310
0

0
0
0
0
0
0

0
0
0
0
0
0
0
0

0
0

0
0

0

0
0
0
0
0
0
0
0
0


0
901,310

0
0
0
0
0
0
 38

-------
Questioned Costs a**nn
Audit Control Auditee
Number
P2CW*7-0 1 -0 1 24-9 1 00383
P2CW*6-0 1 -0277-9 1 00384
P2CW*6-01 -0270-91 00386
P2CW*6-0 1 -0236-9 1 00390
P2CW*8-0 1-0121-91 00392
P2C W'8-0 1 -0 1 70-9 1 004 1 6
P2CW*8-01-0031-9100417
P2CW6-0 1 -0275-9 1 00463
P2CW7-0 1 -006 1 -9 1 00464
P2CW*8-0 1 -0033-9 1 00465
P2CW8-0 1 -0 1 93-9 1 00466
S2C W*8-0 1 -0038-9 1 00293
S2CW*8-0 1 -004 1 -9 1 004 1 8
S2CW8-0 1-0161-91 00420
S2CW*8-0 1 -0403-9 1 00444

E2CWL9-02-0063-9 1 00508
P2C W7-02-0 1 67-9 1 00260
P2CW*6-02-01 92-91 00294
P2CW*6-02-0200-9 1 00298
P2CW*6-02-02 1 4-9 1 00299
P2CW*8-02-0 1 80-9 1 00347
P2CW*7-02-01 43-9 1 00348
P2CW*8-02-0 1 48-9 1 00354
P2CW*7-02-0 1 95-9 1 00355
P2CW*7-02-0 1 25-9 1 00366
P2CW6-02-0 1 98-9 1 00368
P2CW7-02-0 1 98-9 1 00369
P2CW*8-02-0 191-91 00385
P2CW*6-02-0 1 59-9 1 00423
P2CW*8-02-0 1 92-9 1 00442
P2CW7-02-01 40-91 00477
P2CWV-02-01 50-91 00509
P2CW*7-02-0205-9 10051 1
P2CW*8-02-0 1 20-9 1 0051 2

E2CW8-03-0 1 28-9 1 00239
E2CW8-03-0270-9 1 003 1 6
E2CW*7-03-0349-9200007
E2AWP9-03-031 2-9400040
P2CW*7-03-0209-9 1 00258
P2CW*8-03-0024-9 1 00273
P2CW6-03-0338-91 00282
P2CW*8-03-0056-91 00283
P2CW*8-03-0054-9 1 00290
P2CW*6-03-0340-91 00295
P2CW*8-03-0039-91 00325
P2CWV-03-0101-9100335
P2CW*8-03-0031 -91 00377
P2CW*8-03-0 112-91 00378
P2CW7-03-0262-91 00381
P2CW*7-03-0295-9 1 00468
P2CW*7-03-0249-9 1 00478
P2CW7-03-0347-9 1 00490
P2CW*7-03-030 1-91 00494

E2CWN9-04-02 1 6-9300080
P2CWN5-04-00 1 4-9300039
P2CWN7-04-01 21 -9300048
P2CWN7-04-0304-9300051
P2CWN8-04-0221 -9300052
P2CWN7-04-0 1 87-9300053
P2CWN8-04-0209-9300054
P2CWN8-04-0441 -9300055
P2CWN8-04-0430-9300057
P2CWN7-04-0325-9300060
P2CWN8-04-0085-9300064
P2CWN7-04-03 1 3-9300068
P2CWN8-04-0400-9300069
P2CWN7-04-0285-9300075
P2CWN7-04-0303-9300076
VERNON CT
RUMFORD ME
SOUTHINGTON CT
PORTLAND WATER DISTRICT ME ME
LINCOLN SANITARY DISTRICT ME
MERRIMACK NH
HALLOWELL WATER DISTRICT ME
MANCHESTER NH
WILLISTON VT
OLD ORCHARD BEACH ME
TROY NH
PALMER MA
TEWKSBURY MA
ROCKLAND MA
NARRAGANSETT BAY WQMDC Rl
TOTAL OF REGION 01 = 21
NYSDEC 205 G NY
NORTH TONAWANDA NY
LINDEN ROSELLS SEWER DIST. NJ
NASSAU COUNTY NY
NASSAU COUNTY NY
BUFFALO SA NY
BUFFALO SA NY
BUFFALO SA NY
MANCHESTER/SHORTSVILLE NY
GLEN COVE NY
STONY BROOK REG SEW AUTH NJ
ROCKAWAY VALLEY REG SA NJ
WALWORTH NY
AMSTERDAM NY NY
JAMESTOWN NY
BERKELEY HEIGHTS NJ
WATERFORD NY NY
OWEGO NY NY
GLOVERSVILLE/JOHNSTOWN NY
TOTAL OF REGION 02 = 19
BALTIMORE MAYOR & CTY COUN MD
SELINSGROVE MUNI AUTHORITY PA
FRANKLIN TWP MUNI AUTH PA
WOOD TOWNSHIP PA
YORK CITY SEWER AUTH PA
MC MECHEN CITY OF WV
MARYLAND ENVIRO SERVICE MD
DISTRICT OF COLUMBIA DC
KISKI VALLEY WTR POLLUTION PA
CONSUMER & REG AFFAIRS DC
FRANKLIN CITY OF VA
HEALTH & MENTAL HYGIENE MD
FREDERICK CTY DEPT PUB WKS MD
CRAB ORCHARD-MAC ARTHUR PSD WV
CRAB ORCHARD/MACARTHUR PSD WV
SISSONVILLE PSD WV
SPRINGETTSBURY TWP PA
KENT COUNTY LEW COURT DE
DISTRICT OF COLUMBIA DC
TOTAL OF REGION 03 = 19
FT MYERS FL
CONCORD BD OF LIGHT & WTR NC
SHEFFIELD AL
LAGRANGE KY
CLANTON WGSB AL
MS BUREAU OF BLDGS MS
CANTON MS
TAMPA FL
MS GULF COAST REG WA MS
FT PIERCE UTILITIES AUTH FL
WINSTON-SALEM CITY/COUNCIL NC
JACKSONVILLE FL
TAMPA FL
HILLSBOROUGH CO FL
HILLSBOROUGH CO FL
Final Report
Issued
7/26/89
7/27/89
7/27/89
7/31/89
7/31/89
8/10/89
8/10/89
9/ 7/89
9/ 8/89
9/ 8/89
9/ 8/89
5/24/89
8/15/89
8/15/89
8/28/89

9/29/89
5/ 2/89
5/24/89
5/31/89
5/31/89
7/ 6/89
7/ 6/89
7/ 7/89
7/ 7/89
7/11/89
7/13/89
7/14/89
7/27/89
8/16/89
8/28/89
9/14/89
9/29/89
9/29/89
9/29/89

4/10/89
6/ 7/89
9/20/89
9/20/89
4/27/89
5/ 8/89
5/12/89
5/12/89
5/24/89
5/26/89
6/13/89
6/27/89
7/20/89
7/21/89
7/25/89
9/11/89
9/15/89
9/25/89
9/27/89

8/16/89
4/ 7/89
5/ 9/89
5/18/89
5/18/89
5/18/89
5/24/89
5/24/89
6/ 5/89
6/14/89
7/ 7/89
7/14/89
7/17/89
8/ 4/89
8/ 4/89
Ineligible Unsupported Unnecessary/ Er
Costs Costs Unreasonable (Func
Costs To Be
924
5,814
75,086
0
47,829
81
15,719
3,669
0
25,588
3,974
107,124
317,444
123,882
17,512
4,944,398
37,764
499,797
194,951
2,293,614
2,965,324
591,560
362,388
94,562
32,923
176,197
32,328
83,333
84,128
99,911
144,183
193,830
135,147
36,066
94,041
8,152,047
54,533
183,782
39,377
0
387,293
65,203
54,160
635,741
3,011
100,667
32,059
188,150
266,990
31,854
82,081
82,641
100,226
107,185
476,009
2,890,962
49,484
56,600
12,496
2,782
9,064
6,861
240,615
24,244
0
1,830,363
707,902
51,541
8,261
19,504
2,740
91,015
6,088
123
0
0
16,500
0
10,011
0
0
0
0
122,505
0
1,312
10,357,757
1,253,619
517,981
47,169
82,598
19,492
41,545
119,903
52,436
0
7,674
36,273
53,515
113,170
0
87,188
69,930
260,147
38,155
773,518
3,574,313
134,855
61,610
0
0
101,925
336,542
334,478
142,671
325,280
49,198
2,250
2,653,946
658,772
244,576
48,155
511,122
343,713
609,969
1,594,454
8,153,516
0
16,475
0
71,125
0
0
0
318,102
0
125,370
59,818
816,326
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,250
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
205,904
0
0
0
0
0
0
0
intended
Mciencies
Is Be Put
itter Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
39

-------
Audit Control Auditee
Number
P2CWN8-04-0364-9300079
P2CWN8-04-0041 -9300081
S2CWN6-04-001 1-9300056
S2CWN7-04-0083-9300092

E2AWP9-05-0280-940003 1
E2AWP9-05-0400-9400038
P2CWN6-05-0393-9300044
P2GWN5-05-0328-9300059
P2GWN6-05-0374-9300062
P2GWN7-05-0029-9300066
P2CWN6-05-0388-9300070
P2CWN6-05-01 98-9300072
P2GWN7-05-0049-9300078
P2CWN7-05-0479-9300094
P2CWN7-05-0069-9300 1 00

E2CWN8-06-01 90-9300049
E2EWN9-06-0098-9300 1 0 1
E2AWP9-06-01 03-9400028
P2CWN6-06-0 1 84-9300038
P2CWN7-06-0050-9300047
P2CWN8-06-0074-9300058
P2CWN7-06-01 56-9300088

P2C WN7-07-0 1 39-9300040
P2CWN6-07-0 1 67-9300042
P2CWN8-07-01 81 -9300065
P2CWN7-07-01 03-9300067
P2CWN7-07-01 15-9300084
P2CWN8-07-003 1 -9300085
P2CWN7-07-0086-9300090

E2AWPO-09-0230-9400043
S2CW7-09-0038-9300037
S2CW*6-09-0 1 20-930004 1
S2BW*8-09-01 47-9300043
S2CW*6-09-0 1 3 1 -9300045
S2BW7-09-0247-9300050
S2CW*6-09-0 1 04-930006 1
S2CW*7-09-0074-9300073
S2CW*7-09-0087-9300074
S2CWV-09-01 51 -9300077
S2CW*7-09-0021 -9300086
S2CW*7-09-0 1 0 1 -930009 1
S2CW*8-09-01 1 1-9300093
S2BW*7-09-01 90-9300095
S2CWV-09-01 66-9300096
S2CWN9-09-0043-9300099

D2BWL9-10-0133-9100241
D2BWL9- 1 0-0 1 35-9 1 00250

TOTAL CONSTRUCTION
JACKSON MS
TAMPA FL
CLEVELAND TN
COVINGTON TN
TOTAL OF REGION 04 = 19
DETROIT EWS Ml
MMSD EWS Wl
HIGHLAND SD IN
MOOREHEAD MN
MSD CHICAGO IL
BATTLE CREEK Ml
URBANA-CHAMPAIGN SD IL
OWOSSO Ml
LAKEWOOD OH
MEDINA CO OH
CARBONDALE IL
TOTAL OF REGION 05 = 11
ALBURQUERQUE NM
STATE REVOLVING FUND TX
PRAIRIE GROVE AR
FARMINGTON NM
OKLAHOMA CITY OK
BOSSIER CITY LA
HOUSTON TX
TOTAL OF REGION 06 = 7
UNION MO
ST.PETERS MO
KANSAS CITY MO
FLAT RIVER MO
RICHMOND MO
LIBERAL KS
CAMERON MO
TOTAL OF REGION 07 = 7
EARLY WARNING-MARINA CWD CA
PACIFICA, CITY OF CA
SONOMA VALLEY CSD CA
BROWN & CALDWELL CA
RIO VISTA, CITY OF CA
BROWN AND CALDWELL CA
LAS VIRGENES MUN. W D CA
SAN BERNARDINO CSA #70 CA
SANTA CRUZ SD CA
WATSONVILLE, CITY OF CA
SACRAMENTO REG CSD CA
BLUE LAKE, CITY OF CA
VACAVILLE, CITY OF CA
LINDORF ASSOC INC CA
MORRO BAY/CAYUCOS WTF CA
CARMEL SAN DIST. CA
TOTAL OF REGION 09 = 16
BECK R W AND ASSOCIATES WA
BECK R W AND ASSOCIATES WA
TOTAL OF REGION 10 = 2
GRANT AUDITS = 121
Final Report
Issued
8/15/89
8/17/89
5/24/89
9/13/89

6/13/89
9/11/89
5/ 1/89
6/12/89
6/26/89
7/ 7/89
7/18/89
7/20/89
8/ 7/89
9/13/89
9/29/89

5/11/89
9/29/89
4/13/89
4/ 7/89
5/ 9/89
6/ 5/89
9/ 5/89

4/ 7/89
4/25/89
7/ 7/89
7/11/89
8/22/89
8/22/89
9/ 7/89

9/26/89
4/ 5/89
4/11/89
4/25/89
5/ 4/89
5/15/89
6/15/89
7/31/89
8/ 3/89
8/ 7/89
8/24/89
9/11/89
9/13/89
9/14/89
9/18/89
9/28/89

4/10/89
4/14/89


Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
36,464
21,089
30,165
114,524
3,224,699
0
0
58,281
124,001
0
0
28,544
0
0
786,983
99,808
1,097,617
125,115
0
0
174,309
0
69,248
2,226,978
2,595,650
41,541
32,151
215,707
6,900
7,540
113,415
62,223
479,477
0
162,579
1,794,400
0
107,257
0
156,978
126,472
884,445
31,414
2,324
4,312
1,018,915
0
181,114
1,207,016
5,677,226
0
0
0
29,062,076
0
0
0
234,049
1,641,265
0
0
0
0
0
0
213,236
90,987
105,220
23,034
0
432,477
0
0
0
0
0
1,430
0
1,430
0
0
41,250
0
0
0
0
41,250
0
0
0
0
0
0
0
0
0
0
153,904
0
0
0
10,223
0
164,127
0
0
0
24,366,135
0
0
0
43,276
249,180
0
0
0
0
0
0
0
0
0
16,223
41,805
58.028
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
200,796
0
41,329
0
41,288
0
0
0
0
0
0
0
0
0
283,413
0
0
0
601,871
0
0
0
0
0
1,131,050
2,230,620
0
0
0
0
0
0
0
0
0
3,361,670
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
931,700
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
931,700
0
0
0
4,293,370
3. OTHER GRANT AUDITS

C3HMK9-01-0118-9500534
C3H M K9-01 -0122-9500559
C3HMK9-01 -0135-9500560
C3HMK9-01 -0130-9500606
C3H M K9-01 -0140-9500634
C3H M K9-01 -0157-9500690
C3H M K9-01 -0149-9500692
C3HMK9-01-0164-9500784
C3HMK9-01-0177-9500785
C3HMK9-01-0185-9500856
C3HMK9-01 -0196-9500896
C3HMK9-01-0195-9500897
C3H M K9-01 -0193-9500898
C3HMK9-01-0199-9500911
C3H M K9-01 -0194-9500932
C3HMK9-01-0221-9501065
C3HMK9-01-0223-9501082
SANDWICH             MA
CONWAY VILL FIRE DISTRICT
NH
JAFFREY              NH
NEWPORT              NH
WAKEFIELD,           NH
CONCORD             MA
RUTLAND             VT
SACO               ME
EXETER               NH
WESTBOROUGH           MA
NORTH ATTLEBOROUGH      MA
BRIDGEWATER           MA
CHELMSFORD           MA
SCARBOROUGH SANITARY DIST. ME
WARREN              MA
CITY OF CHICOPEE        MA
TOWN OF SUNAPEE        NH
4/10/89
4/24/89
4/24/89
5/ 8/89
5/12/89
6/ 1/89
6/ 2/89
6/23/89
6/23/89
7/20/89
8/ 1/89
8/ 1/89
8/ 1/89
8/ 3/89
8/ 7/89
8/28/89
8/30/89
40

-------
Questioned Costs
Audit Control Auditee
Number
C3HMK9-01-0222-9501083
N3HMK9-01 -01 16-9500533
N3HMK9-01 -01 1 7-9500536
N3H M K9-0 1 -0 1 42-9500632
N3HMK9-01-0141-9500633
N3 H M K9-0 1 -0 1 38-9500673
N3 H M K9-0 1 -0 1 58-9500687
N3 H M K9-0 1 -0 1 59-9500688
N3HMK9-01-0159-9500689
N3HMK9-01-0156-9500691
N3HMK9-01-0176-9500783
N3H M K9-0 1 -0 1 66-9500786
N3H M K9-0 1 -0 1 87-9500859
N3H M K9-0 1 -0 1 86-9500860
N3H M K9-0 1 -0 1 98-95009 1 0
N3H M K9-0 1 -0 1 97-9500933
N3H M K9-0 1 -0202-9500972
N3H M K9-0 1 -020 1 -950 1 060
N3HMH9-01-0218-9501061
N3HMH9-01 -021 7-9501 064
N3HMH9-01 -0220-9501 081
N3HMH9-01 -021 9-9501 088
N3HMH9-01 -0224-9501 091

C3H M K9-02-0240-9500527
C3H M K9-02-0265-9500572
C3H M K9-02-0273-950063 1
C3H M K9-02-0275-9500642
C3H M K9-02-0277-9500643
C3 H M K9-02-0274-9500647
C3H M K9-02-0284-9500677
C3H M K9-02-0285-9500678
C3H M K9-02-0286-9500679
C3HMK9-02-0287-9500680
C3HMK9-02-0288-9500683
C3HMK9-02-0292-9500744
C3HMK9-02-031 5-9500792
C3HMK9-02-0316-9500793
C3HMK9-02-031 7-9500794
C3H M K9-02-0320-9500797
C3H M J9-02-0337-9500809
C3HMK9-02-0350-9500815
C3HMK9-02-0353-9500827
C3HMK9-02-0356-9500840
C3HMK9-02-0369-9500939
C3HMK9-02-0372-9500949
C3HMK9-02-0375-9501 007
C3HMK9-02-0383-9501 050
C3HMK9-02-0389-9501 168
C3HMK9-02-0399-9501207
N3HUK9-02-0238-9500525
N3HMK9-02-0239-9500526
N3HMK9-02-0262-9500558
N3H M K9-02-0263-9500563
N3H M K9-02-0264-9500564
N3HMK9-02-0269-9500575
N3HUK9-02-0270-9500576
N3HMK9-02-0276-9500640
N3HMK9-02-0278-950064 1
N3HMK9-02-0282-9500648
N3HMK9-02-0283-9500663
N3HMK9-02-0295-9500745
N3H M K9-02-0296-9500746
N3HMK9-02-031 8-9500795
N3HMK9-02-03 1 9-9500796
N3H M K9-02-0335-9500807
N3H M K9-02-0336-9500808
N3HMK9-02-0338-950081 0
N3HMK9-02-0339-950081 1
N3HMK9-02-0361 -9500871
N3HMK9-02-0364-9500888
N3HMK9-02-0374-9500967
N3H M K9-02-0376-950 1 005
N3HMK9-02-0382-9501049
N3HMK9-02-0384-950 1 055
N3HMK9-02-0388-9501 167
N3HMK9-02-0390-9501 176
N3HMK9-02-0391 -9501 206

TOWN OF ENFIELD NH
KEENE NH
NEW BEDFORD MA
RANG ELY ME
SO. NEWHAMPSHIRE PLNG. COM NH
BERKSHIRE CNTY REG. PLNG. MA
MANCHESTER NH
STATE NEW HAMPSHIRE NH
STATE NEW HAMPSHIRE NH
MILFORD MA
CAMBRIDGE MA
NEW HAVEN CT
PIONEER VALLEY PLANNING COM MA
MAPC MA
NORWALK CT
BRIDGEPORT CT
CITY OF WATERBURY CT
EASTERN MAINE DEVELOPMENT DSME
CITY OF CRANSTON Rl
STATE OF RHODE ISLAND Rl
STATE OF MAINE ME
STATE OF MAINE ME
NASHUA REG PLANNING COMM. NH
TOTAL OF REGION 01 = 40
GRAND ISLAND, NY
CAPE MAY COUNTY MUA, NJ
MIDDLESEX COUNTY UA NJ
LANDIS SA, NJ
LEROY, NY
WASHINGTON COUNTY, NY
WOODSTOCK NY
WOODSTOCK NY
WOODSTOCK NY
GLOVERSVILLE-JOHNSTOWN JT NY
BUENA MUA NJ
CHESTER NY
ROUSES PT NY
ROUSES PT NY
BERGEN COUNTY UA NJ
MIDDLETOEN NY
INTERSTATE SANITATION COMM NY
BUFFALO SA NY
FALLSBURG NY
CHESTER NY
GREAT NECK NY
ROCKAWAY VALLEY REG SA NJ
RUSHVILLE NY
GREAT NECK WPCD NY
GOWANDA NY
NORWICH NY
RESEARCH FOUNDATION OF SUNY.NY
GOUVERNEUR, NY
ELLENVILLE, NY
MONTOUR FALLS, NY
FREDONIA, NY
NORTH GREENBUSH, NY
CLARKSON UNIV., NY
HAMBURG, NY
NASSAU COUNTY, NY
AKRON, NY
WARREN COUNTY, NY
KINGSTON NY
SAUGERTIES NY
WALDEN NY
ROCKLAND COUNTY NY
NIAGARA FALLS NY
JAMESTOWN NY
ESSEX COUNTY NJ
ESSEX COUNTY NJ
NEW YORK STATE NY
ANDOVER NY
SCHAGHTICOKE NY
FREDONIA NY
FULTON NY
MONROE COUNTY NY
ATLANTIC COUNTY NJ
SARATOGA COUNTY NY
CATTARAUGUS NY
TOTAL OF REGION 02 = 54
Final Report
Issued
8/30/89
4/10/89
4/10/89
5/12/89
5/12/89
5/23/89
6/ 1/89
6/ 1/89
6/ 1/89
6/ 1/89
6/23/89
6/23/89
7/21/89
7/21/89
8/ 3/89
8/ 7/89
8/10/89
8/24/89
8/24/89
8/28/89
8/30/89
8/31/89
8/31/89

4/ 6/89
4/27/89
5/11/89
5/15/89
5/15/89
5/16/89
5/25/89
5/25/89
5/25/89
5/25/89
5/26/89
6/12/89
6/27/89
6/27/89
6/27/89
6/27/89
7/ 6/89
7/10/89
7/13/89
7/17/89
8/ 8/89
8/ 9/89
8/15/89
8/22/89
9/18/89
9/25/89
4/ 6/89
4/ 6/89
4/24/89
4/25/89
4/25/89
4/28/89
4/28/89
5/12/89
5/12/89
5/16/89
5/22/89
6/12/89
6/12/89
6/27/89
6/27/89
7/ 6/89
7/ 6/89
7/ 7/89
7/ 7/89
7/24/89
7/31/89
8/10/89
8/14/89
8/22/89
8/23/89
9/18/89
9/19/89
9/25/89

tt^r>f\n
Ineligible Unsupported Unnecessary/ Ef
Costs Costs Unreasonable (Fun<
Costs To Be
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10,742
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
19,976
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
30,718
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
nmended
ficiencies
Is Be Put
itter Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
41

-------
Questioned Costs
Audit Control Auditee
Number
C3 H M K9-03-0 1 79-950053 1
C3HMK9-03-01 87-9500544
C3 H M K9-03-0 1 96-9500557
C3HMK9-03-01 95-9500562
C3HMK9-03-0204-9500595
C3HMK9-03-021 7-9500684
C3HMK9-03-0218-9500685
C3HMK9-03-0230-9500718
C3HMK9-03-0232-9500723
C3H M K9-03-0245-9500770
C3HMK9-03-0246-9500771
C3H M K9-03-027 1 -9500822
C3H M K9-03-0275-9500837
C3HMK9-03-0277-9500841
C3H M K9-03-0278-9500842
C3HMK9-03-0279-9500843
C3H M K9-03-0280-9500846
C3H M K9-03-028 1 -9500847
C3H M K9-03-0287-9500865
C3H M K9-03-0293-9500876
C3H M K9-03-0294-9500877
C3H M K9-03-0295-9500884
C3H M K9-03-03 1 3-9500909
C3HMK9-03-0318-9501012
C3H U K9-03-032 1 -950 1 056
C3HMK9-03-0342-9501 100
C3HMK9-03-0346-9501201
C3HMK9-03-0348-9501216
C3H M K9-03-0378-950 1 284
N3H M K9-03-0 1 80-9500532
N3H M K9-03-01 86-9500543
N3H M K9-03-01 89-9500552
N3H M K9-03-0203-9500585
N3HMK9-03-0206-950061 1
N3HMK9-03-0210-9500621
N3HUK9-03-0233-9500747
N3HMK9-03-0247-9500778
N3H M K9-03-0249-9500779
N3HMJ9-03-0251 -9500803
N3HMK9-03-0250-9500820
N3HMJ9-03-0267-9500821
N3HMK9-03-0273-9500828
N3HMK9-03-0274-9500829
N3HMK9-03-031 1-9500922
N3HMJ9-03-0322-9501020
N3HMK9-03-0326-9501033
N3HMK9-03-0329-9501057
N3HMK9-03-0345-9501 150
N3HMK9-03-0358-9501 157
N3HM J9-03-0347-950 1 202
N3H M K9-03-0359-950 1 208
P3 DO '8-03-0093-91 004 14

C3HWK9-04-0 1 69-9500567
C3H WK9-04-0 1 93-9500589
C3HWK9-04-01 92-9500590
C3HWK9-04-0206-9500597
C3HWK9-04-0203-9500602
C3HWK9-04-0200-9500603
C3HWK9-04-01 94-950061 0
C3HWK9-04-0205-950061 3
C3HWK9-04-0204-9500616
C3HWK9-04-0 1 9 1 -95006 1 7
C3HWK9-04-0218-9500655
C3HWK9-04-021 7-9500656
C3HWK9-04-0223-9500669
C3HWK9-04-0221 -9500672
C3HWK9-04-02 1 9-9500676
C3HWK9-04-0245-9500695
C3HWK9-04-0238-9500701
C3HWK9-04-0239-950071 2
C3HWK9-04-0243-950071 5
C3HWJ9-04-0237-9500716
C3HWK9-04-0247-9500725
C3H M K9-04-0256-95008 1 2
C3HWK9-04-0257-950081 8
C3HWK9-04-0258-950081 9
SHENANGO TWP MUN AUTHORITY PA
TAZEWELL COUNTY VA
EAST EARL SEWER AUTHORITY PA
MOSCOW SEWER AUTH. CYE/12-87PA
BUCHANAN COUNTY VA
UPPER AUGUSTA TWP CY 12/86 PA
UPPER AUGUSTA TWP CY 12/87 PA
LEOLA SEWER AUTHORITY PA
UPPER MACUNGIE TWP AUTH PA
CARROLL COUNTY/FYE 6/85 MD
CARROLL COUNTY/FYE 6/86 MD
DELMAR TOWNS OF MD
WSSC MD
SOMERSET COUNTY - FYE 6/86 MD
SOMERSET COUNTY - FYE 6/87 MD
SOMERSET COUNTY FYE 6/88 MD
CARROLL COUNTY-FYE 6/87 MD
QUAKERTOWN BOROUGH OF PA
HARRISBURG WATER & SEWER PA
PINE-HARRISVILLE SEWER AUTH PA
PINE-HARRISVILLE SEWER AUTH PA
BERLIN TOWN OF MD
ANNE ARUNDEL COUNTY MD
SUSSEX COUNTY DE
NAT ASSOC OF ATTORNEY GEN
ALTOONA CITY OF PA
UPPER MONTGOMERY JOINT AUTH PA
WEST CHESTER BOROUGH PA
BALTIMORE COUNTY MD
TAZEWELL COUNTY VA
ROANOKE CITY OF FYE 6/88 VA
NAT'L COUNCIL ON AGING DC
MARYLAND STATE OF-FYE 6/87 MD
HENRICO COUNTY OF FYE 6/88 VA
ARLINGTON COUNTY VA
HOWARD UNIVERSITY DC
FREDERICK CITY MD
VA-COMMONWEALTH UNIVERSITY VA
VIRGINIA UNIVERSITY VA
BALTIMORE CITY OF MD
VA DEPT OF CONSERVATION VA
NEW CASTLE COUNTY DE
HAGERSTOWN CITY OF MD
ALLENTOWN CITY OF PA
PENNSYLVANIA COMMONWEALTH PA
MONTGOMERY COUNTY OF VA
DC DEPT OF PUBLIC WORKS DC
DC DEPT OF PUBLIC WORKS DC
KENT COUNTY LEVY COURT DE
VA POLYTECHNIC INSTITUTE VA
GEORGE WASHINGTON UNIVSTY DC
WSSC MD
TOTAL OF REGION 03 = 52
DEKALB CO., GA
OLD FORT, NC
BUNCOMBE CO. MSD, NC
DARLINGTON, SC
ROBBINS, NC
SEA PINES PUBLIC SVC DIS., SC
GREENSBORO, NC
STAR, NC
NEWTON CO. WATER & SEWER, GA
WASHINGTON, NC
TAMPA, FL
HANSON, KY
YANCEYVILLE, NC
CLEVELAND UTILITIES WATER, TN
CARROLLTON, GA
SUMTER SC
MONTICELLO KY
ST. ANDREWS PUBLIC SVC DIST.SC
MIDWAY KY
JEFFERSON COUNTY AL
HICKORY NC
JACKSONVILLE FL
DALTON UTILITIES GA
LAKELAND FL
Final Report
Issued
4/10/89
4/13/89
4/24/89
4/24/89
5/ 4/89
5/26/89
5/26/89
6/ 7/89
6/ 8/89
6/20/89
6/20/89
7/12/89
7/14/89
7/18/89
7/18/89
7/18/89
7/18/89
7/19/89
7/24/89
7/25/89
7/25/89
7/26/89
8/ 3/89
8/16/89
8/23/89
9/ 6/89
9/21/89
9/27/89
9/28/89
4/10/89
4/13/89
4/18/89
5/ 3/89
5/ 8/89
5/11/89
6/12/89
6/22/89
6/22/89
6/29/89
7/1 1/89
7/11/89
7/13/89
7/13/89
8/ 4/89
8/16/89
8/18/89
8/23/89
9/13/89
9/15/89
9/21/89
9/25/89
8/ 8/89

4/25/89
5/ 4/89
5/ 4/89
5/ 5/89
5/ 8/89
5/ 8/89
5/ 8/89
5/ 8/89
5/ 8/89
5/10/89
5/18/89
5/18/89
5/23/89
5/23/89
5/23/89
6/ 5/89
6/ 6/89
6/ 6/89
6/ 6/89
6/ 6/89
6/ 8/89
7/ 7/89
7/11/89
7/11/89
Ra*»/\rv
Ineligible Unsupported Unnecessary/ Efl
Costs Costs Unreasonable (Func
Costs To Be
0
0
0
0
0
0
0
0
177,669
0
0
0
0
0
0
0
0
0
0
0
0
0
162,544
0
0
0
0
0
0
0
0
0
0
0
0
0
342
0
0
134,228
0
0
0
0
0
0
432,858
24,677
0
0
0
0
932,318
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,088
0
0
0
0
0
0
0
0
0
3,567
3,433
0
0
0
0
8,088
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
imended
Ficiencies
Is Be Put
tter Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
42

-------
  Audit Control
  Number
Audit ee
                  Final Report
                  Issued
          Ineligible
          Costs
                                                                                        Questioned Costs
    Unsupported
    Costs
   Unnecessary/
   Unreasonable
   Costs
    Recommended
        Efficiencies
     (Funds Be Put
    To Better Use)
 C3HWK9-04-Q281-9500943
 C3HMK9-04-0302-9500963
 C3HWK9-04-0296-9500964
 C3HWK9-04-0300-9500965
 C3HWK9-04-0301 -9500966
 C3HWK9-04-0275-9500978
 C3HWK9-04-0276-9500983
 C3HWK9-04-0274-9500992
 C3HWK9-04-0286-9500997
 C3HWK9-04-0285-9500998
 C3HWK9-04-0284-9500999
 C3HWK9-04-0350-9501070
 C3HWK9-04-0349-9501071
 C3HWK9-04-0355-9501077
 C3HWK9-04-0363-9501078
 C3HMK9-04-0362-9501079
 C3H WK9-04-0361 -9501080
 C3HWK9-04-0354-9501084
 C3HWK9-04-0353-9501085
 C3 HWK9-04-0352-9501086
 C3 HWK9-04-0356-9501087
 C3HWK9-04-0348-9501090
 C3HWK9-04-0376-9501122
 C3HWK9-04-0380-9501129
 C3HWK9-04-0371 -9501133
 C3HWK9-04-0381-9501138
 C3HWK9-04-0382-9501139
 C3HWK9-04-0384-9501146
 C3HWK9-04-0374-9501147
 C3HMJ9-04-0308-9501148
 C3HWK9-04-0368-9501149
 C3HWK9-04-0365-9501151
 C3HWK9-04-0289-9501154
 C3HWK9-04-0392-9501155
 C3HWK9-04-0394-9501158
 C3HWK9-04-0406-9501217
 C3HMK9-04-0322-9501219
 C3HMK9-04-0320-9501220
 C3HWK9-04-0313-9501221
 C3HWK9-04-0411-9501222
 C3HWK9-04-0417-9501223
 C3HWK9-04-0311-9501224
 C3HWK9-04-0337-9501244
 C3HWK9-04-0402-9501248
 C3HMK9-04-0335-9501251
 C3H WK9-04-0412-9501252
 C3HM K9-04-0326-9501253
 C3HWK9-04-0328-9501255
 C3H M K9-04-0395-9501256
 C3H WK9-04-0312-9501257
 C3HWK9-04-0330-9501259
 C3HWK9-04-0333-9501260
 C3HWK9-04-0425-9501273
 C3HWK9-04-0426-9501274
 H3AML9-04-0212-9100274
 H3AAL9-04-0214-9100281
 N3HMJ9-04-0185-9500565
 N3HWK9-04-0187-9500566
 N3H AK9-04-0208-9500591
 N3HWK9-04-0211-9500598
 N3HWK9-04-0199-9500604
 N3HWK9-04-0209-9500605
 N3HWK9-04-0201 -9500612
 N3HWK9-04-0202-9500614
 N3H WK9-04-0210-9500615
 N3HAK9-04-0207-9500618
 N3HWK9-04-0226-9500664
 N3HUK3-04-0228-9500666
 N3HAK9-04-0222-9500667
 N3HWK9-04-0220-9500668
 N3HWK9-04-0224-9500670
 N3H WK9-04-0225-9500671
 N3HWK9-04-0229-9500674
 N3HWK9-04-0230-9500675
N3HWK9-04-0242-9500696
N3HMK9-04-0235-9500700
N3HUK9-04-0240-9500702
N3HWJ9-04-0246-9500703
N3HUK9-04-0241-9500713
   FLOWOOD
   TALLAHASSEE
   GRIFFIN
   CLERMONT
   DAYTON
   SARALAND
  MS
   FL
GA
  FL
 TN
  AL
   LOUISVILLE JEFFERSON CO MSD KY
   ATLANTA              GA
   BOLIVAR             TN
   JACKSON              TN
   LEWISBURG             TN
   FORT LAUDERDALE        FL
   TALLAHASSEE           FL
   HARRISON CO. W M D       MS
   BRUNSWICK            GA
   COBB COUNTY           GA
   KEY WEST             FL
   SPARTANBURG SANITARY SEWER SSC
   KISSIMMEE            FL
   ANDALUSIA            AL
   BEAUFORT COUNTY         SC
   BERKELEY COUNTY        SC
   MIDDLESBOROUGH         KY
   PORT ORANGE           FL
   ROBBINS              NC
   NICEVILLE             FL
   EDEN                NC
   FLEMING NEON           KY
   SAFiASOTA             FL
   AL DEPT OF ENV. MGMT     AL
   KEY WEST              FL
   BRADFORD             TN
   CLEVELAND             TN
   MURPHY              NC
   CAVELAND SANITATION AUTH   KY
   GADSDEN              AL
   LIXINGTON FAYETTE CO     KY
   PENSACOLA             FL
   O2ARK UTILITIES BOARD    AL
   ATLANTIC BEACH         FL
   MARTIN               TN
   CULLMAN              AL
   EASLEY UTILITY SYSTEM    SC
   HANSON               KY
   JEFFERSON COUNTY FISCAL COURKY
CLANTON
COLUMBIA
FT MILL
DEKALB
PALATKA
CLEVELAND
SYLVANIA
CARROLLTON
ASHEBORO
RESEARCH TRIANGLE
RESEARCH TRIANGLE
AL
SC
SC
GA
GA
TN
GA
GA
NC
INST., NC
INST., NC
NORTH CAROLINA STATE OF, NC
SANFORD,
FL
MECKLENBURG COUNTY, NC
STANTONSBURG,
FLORENCE,
HARTSVILLE,
CLYDE,
AIKEN,
GOLDSBORO,
NC
SC
SC
NC
SC
NC
  MECKLENBURG COUNTY,      NC
  DURHAM,              NC
  SUMTER AREA TECHNICAL COLLE.SC
  BUNCOMBE COUNTY,        NC
  DOUGLAS,             GA
  CLIFTON,             TN
  ENFIELD,              NC
  CHARLOTTE,            NC
  HIGH POINT,           NC
  LAGRANGE              GA
  DADE COUNTY           FL
  CLEMSON UNIVERSITY       SC
  GEORGIA FORESTRY COMMISSION GA
  SOUTH CAROLINA UNIVERSITY OFSC
 8/ 8/89
 8/10/89
 8/10/89
 8/10/89
 8/10/89
 8/11/89
 8/11/89
 8/11/89
 8/11/89
 8/11/89
 8/11/89
 8/29/89
 8/29/89
 8/30/89
 8/30/89
 8/30/89
 8/30/89
 8/31/89
 8/31/89
 8/31/89
 8/31/89
 8/31/89
 9/ 7/89
 9/ 8/89
 9/ 8/89
 9/11/89
 9/11/89
 9/12/89
 9/12/89
 9/13/89
 9/13/89
 9/13/89
 9/15/89
 9/15/89
 9/15/89
 9/27/89
 9/27/89
 9/27/89
 9/27/89
 9/27/89
 9/27/89
 9/27/89
 9/27/89
 9/27/89
 9/28/89
 9/28/89
 9/28/89
 9/28/89
 9/28/89
 9/28/89
 9/28/89
 9/28/89
 9/28/89
 9/28/89
 5/ 9/89
 5/12/89
 4/25/89
 4/25/89
 5/ 4/89
 5/ 5/89
 5/ 8/89
 5/ 8/89
 5/ 8/89
 5/ 8/89
 5/ 8/89
 5/10/89
 5/22/89
 5/22/89
 5/22/89
 5/23/89
 5/23/89
 5/23/89
 5/23/89
 5/23/89
 6/ 5/89
6/ 5/89
6/ 6/89
6/ 6/89
6/ 6/89
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
0
0
0
0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
0
0
 0
0
0
0
0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
0
0
0
0
0
0
0
0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
0
 0
0
0
                                                                                                                              43

-------
Audit Control Auditee
Number
N3HWK9-04-0244-950071 4
N3HWK9-04-0260-95008 1 6
N3HUK9-04-0259-950081 7
N3HWK9-04-0280-9500923
N3HWK9-04-0279-9500924
N3HUJ9-04-0277-9500928
N3HUJ9-04-0288-9500929
N3HWK9-04-0291 -9500930
N3HMK9-04-0278-9500931
N3HAK9-04-0283-9500942
N3HUK9-04-0287-9500985
N3HWK9-04-0290-9500986
N3HWK9-04-0282-9500996
N3HUK9-04-0295-9501016
N3HAK9-04-035 1 -950 1 072
N3HWK9-04-0357-9501 073
N3HWK9-04-0379-9501 1 20
N3HWK9-04-0372-9501 121
N3HWK9-04-0385-9501 124
N3HWK9-04-0377-9501 126
N3HUK9-04-0373-9501 130
N3HWK9-04-0378-9501 131
N3HMK9-04-0364-9501 132
N3HAJ9-04-0369-9501134
N3HWK9-04-0383-9501 1 40
N3HUK9-04-0366-9501 141
N3HWK9-04-0370-9501 1 42
N3HUK9-04-0367-9501 143
N3HWK9-04-0375-9501 144
N3HWK9-04-0393-9501 1 56
N3HMK9-04-0317-9501214
N3HWK9-04-0405-9501 21 5
N3HWK9-04-04 1 6-950 1218
N3 H U J9-04-03 1 0-950 1 228
N3HWK9-04-0318-9501229
N3HWK9-04-0404-9501 230
N3HWK9-04-03 1 9-950 1 23 1
N3HUK9-04-041 4-9501 232
N3HWK9-04-04 1 3-950 1 233
N3HUK9-04-041 5-9501 234
N3HUJ9-04-0338-9501 235
N3HWJ9-04-03 1 4-950 1 236
N3HWK9-04-0334-9501 237
N3HWK9-04-0332-9501240
N3HUK9-04-0359-9501242
N3HWK9-04-0327-9501245
N3HUK9-04-0336-9501246
N3HAK9-04-0325-9501 247
N3H M J9-04-0423-950 1 249
N3HWK9-04-0343-950 1 250
N3HMJ9-04-0307-9501254
N3H M J9O4-033 1 -950 1 258
N3H WK9-04-03 1 6-950 1 26 1
N3HWK9-04-0323-9501 262
N3HMJ9-04-0315-9501263
N3HWJ9-04-0309-9501 264
N3H U J9-04-0424-950 1 265
N3HSJ9-04-0397-9501 266
N3H U K9-04-0403-950 1 267
N3HWK9-04-0398-950 1 268
N3HWK9-04-0399-9501 269
N3HAK9-04-0401 -9501 270
N3H M J9-04-0400-950 1 27 1
N3H UK9-04-0396-9501 272
N3HWJ9-04-0306-9501 275

C3H M J9-05-0259-950052 1
C3H MK9-05-0246-9500530
C3H M J9-05-0250-9500539
C3H M K9-05-0276-9500573
C3H M K9-05-0233-9500580
C3HMK9-05-0281-9500596
C3H M J9-05-0296-9500600
C3HMK9-05-0293-9500601
C3H M J9-05-0295-95006 1 9
C3HMK9-05-0294-9500620
C3H M K9-05-0338-9500645
C3HMK9-05-0337-9500646
SALISBURY NC
MANATEE COUNTY FL
MEDICAL UNIVERSITY SC
WINSTON SALEM NC
ST CLOUD FL
MISSISSIPPI STATE UNIVERSITYMS
AUBURN UNIVERSITY AL
ST PETERSBURG FL
TRIANGLE J COUNCIL OF GOVTSNC
SHELBY COUNTY TN
SHELTON STATE COLLEGE AL
DOTHAN AL
ROCKY MOUNT NC
GEORGIA UNIVERSITY OF GA
SHELBY COUNTY TN
VALDOSTA GA
SANFORD FL
OKALOOSA FL
ETOWAH TN
ROCKWOOD TN
GEORGIA STATE UNIVERSITY GA
MEMPHIS TN
HUNTSVILLE AL
DEPARTMENT OF EDUCATION GA
EDEN NC
KENTUCKY UNIVERSITY KY
QUITMAN GA
DUKE UNIVERSITY NC
MEMPHIS TN
KNOXVILLE TN
PINELLAS COUNTY FL
ORANGE COUNTY FL
FORT MYERS FL
AUBURN UNIVERSITY AL
BRADENTON FL
GREENVILLE NC
ORLANDO FL
KENTUCKY UNIVERSITY EASTERN KY
AIKEN COUNTY SC
RESEARCH TRIANGLE INSTITUTE NC
SOUTH CAROLINA UNIVERSITY OFSC
DALLAS COUNTY COMMMISSION
LEE COUNTY FL
MUFREESBORO TN
WESTERN KENTUCKY UNIVERSITY KY
BERKLEY CHARLESTON DORCHESTESC
NORTHERN KENTUCKY UNIVERSITYKY
MECKLENBURG COUNTY NC
FLORIDA, STATE OF FL
HINESVILLE GA
ALABAMA DEPT OF EDUCATION AL
AL DEPT OF AGRICULTURE & INDAL
THOMASVILLE GA
ROCHELLE GA
GA DEPT OF NATURAL RESOURCESGA
GEORGIA FORRESTRY COMMISSIONGA
WESTERN CAROLINA UNIVERSITY NC
MONTGOMERY COUNTY TN
EMORY UNIVERSITY GA
AUGUSTA GA
JACKSON MS
BROWARD COUNTY FL
TENNESSEE, STATE OF TN
TUSKEGEE UNIVERSITY AL
ALABAMA DEPT OF CORRECTIONS AL
TOTAL OF REGION 04 = 168
WESTPORT FY 87 IN
FRAZEE FY 87 MN
CHANDLER FY 87 IN
MINNEOTA FY 88 MN
CAMPBELLSPORT Wl
ILLINOIS EPA FY 87/88 IL
EVERGREEN LSD FY 88 OH
WAPAKONETA CSD FY 88 OH
MCCOMB LSD FY 88 OH
SLEEPY HOLLOW FY 88 IL
FOUNTAIN FY 88 MN
WINSTED FY 88 MN
Final Report Ineligible Unsupported Unnecessary/ Efficiencies
Issued Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
6/ 6/89
7/11/89
7/11/89
8/ 4/89
8/ 4/89
8/ 7/89
8/ 7/89
8/ 7/89
8/ 7/89
8/ 8/89
8/11/89
8/11/89
8/11/89
8/16/89
8/30/89
8/30/89
9/ 7/89
9/ 7/89
9/ 7/89
9/ 7/89
9/ 8/89
9/ 8/89
9/ 8/89
9/ 8/89
9/11/89
9/11/89
9/11/89
9/11/89
9/12/89
9/15/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89
9/28/89

4/ 3/89
4/ 7/89
4/11/89
4/27/89
5/ 3/89
5/ 5/89
5/ 5/89
5/ 5/89
5/10/89
5/11/89
5/16/89
5/16/89
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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0
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0
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0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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0
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0
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0
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0
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0
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0
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0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

-------
Audit Control Auditee
Number
C3H M K9-05-0334-9500649
C3H M K9-05-0335-9500650
C3 HM K9-05-0342-9500653
C3HMJ9-05-0339-9500654
C3HM J9-05-034 1 -9500662
C3HMJ9-05-0340-9500665
C3HMK9-05-0351-9500681
C3HMJ9-05-0349-9500682
C3HMJ9-05-0350-9500686
C3HMJ9-05-0353-9500736
C3HMK9-05-0358-9500738
C3HMJ9-05-0354-9500739
C3HMK9-05-0359-9500740
C3HMK9-05-0365-9500741
C3HMJ9-05-0355-9500748
C3HMJ9-05-0367-9500749
C3HMJ9-05-0366-9500755
C3HMK9-05-0368-9500757
C3HMK9-05-0352-9500760
C3HMK9-05-0360-9500761
C3H M K9-05-0377-9500767
C3H M K9-05-037 1 -9500768
C3H M K9-05-0372-9500772
C3HMK9-05-0385-9500802
C3HMK9-05-0389-9500874
C3HMK9-05-0363-9500875
C3H M K9-05-039 1 -9500879
C3 H M K9-05-0388-950088 1
C3H M K9-05-0393-9500883
C3HMK9-05-0398-9500901
C3HMK9-05-0369-950091 6
C3HMK9-05-0401-9500917
C3HMK9-05-0436-9500920
C3HMJ9-05-0417-9500921
C3H M K9-05-04 1 6-9500934
C3H M K9-05-0420-9500947
C3H M K9-05-0429-9500954
C3HMK9-05-04 1 9-9500955
C3HMK9-05-0432-9500979
C3HMK9-05-0430-9500981
C3HMK9-05-0428-9500982
C3HMJ9-05-0449-9501008
C3H M J9-05-0448-950 1 009
C3H M K9-05-0453-950 1017
C3H M K9-05-0459-950 1 099
C3HMK9-05-0461-9501 169
C3HMJ9-05-0470-9501 175
C3HMJ9-05-0466-9501 197
C3HMK9-05-0474-9501209
N3H M K9-05-0243-9500540
N3HMK9-05-0258-9500541
N3H M K8-05-0396-9500554
N3HMJ8-05-031 2-9500574
N3HMK9-05-0232-9500581
N3HMJ9-05-0279-9500582
N3H M K9-05-0328-9500583
N3HMK9-05-0318-9500622
N3H MJ9-05-03 1 6-9500623
N3H M J9-05-0267-9500624
N3HMK9-05-0222-9500625
N3HMK9-05-01 72-9500652
N3HMK9-05-0330-9500737
N3HMK9-05-0344-9500769
N3H M K9-05-0346-9500798
N3HMJ9-05-0345-9500850
N3H M K9-05-0327-9500882
N3HMJ9-05-041 4-9500935
N3HMK9-05-0057-9500948
N3H M J7-05-058 1 -9500977
N3HMJ9-05-0433-9501018
N3H M K9-05-0396-950 1019
N3H MJ9-05-0029-950 1 058
N3H M J9-05-0225-950 1 059
N3HMK8-05-051 8-9501 066
N3H M J9-05-0447-950 1 067
N3H M J9-05-0 1 65-950 1 068
N3HMJ9-05-0209-9501 069
N3H MJ9-05-02 1 6-950 1 074
N3H M J9-05-0224-950 1 075
MONROE CD DC FY 88 Ml
SCHAUMBURG FY 88 IL
ISLE FY 88 MN
WOOSTER FY 88 OH
HOPE FY 86/87 IN
WHITELAND FY 86/87 IN
LANSING FY 88 Ml
MITCHELL FY 87 IN
DYER FY 88 IN
WINAMAC FY 86/87 IN
PLAINVIEW-ELGIN SD FY 88 MN
HOBART FY 88 IN
MILACA FY 88 MN
MENAHGA FY 88 MN
ROCHESTER FY 88 IN
PETERSBURG FY 88 IN
KENTLAND FY 87/88 IN
BAY VILLAGE FY 88 OH
DELTA TWP LANSING FY 88 Ml
S ST PAUL FY 88 MN
COLD SPRING FY 88 MN
CLEVELAND FY 88 MN
BLUE EARTH FY 88 MN
BLACKDUCK FY 88 MN
PIPESTONE FY 87/88 MN
JOLIET FY 87 IL
GRAND RAPIDS FY 88 Ml
MAZEPPA FY 88 MN
FRAZEE FY 88 MN
PARK RAPIDS FY 88 MN
SPRINGFIELD FY 88 IL
REDWOOD FALLS FY 88 MN
NIPC FY 88 IL
CLINTON CO FY 88 IN
WASECA FY 88 MN
HUTCHINSON FY 88 MN
BONNIE BRAE-FM SD FY 88 IL
DU PAGE CO WSS FY 88 IL
LE SUEUR FY 88 MN
CARVER CITY FY 88 MN
MADISON FY 88 MN
NAPPANEE FY 88 IN
INDIANA DEM FY 88 IN
GLENWOOD FY 88 MN
ARLINGTON FY 88 MN
NEORSD FY 88 OH
CANTON FY 87 OH
MICHIGAN CITY FY 88 IN
WAMAC FY 89 IL
ERIE CO FY 87 OH
INDIANAPOLIS FY 87 IN
INDIANAPOLIS FY 86 IN
YOUNGSTOWN FY 86 OH
SHIAWASSEE CO FY 87 Ml
COOK CO FY 87 IL
WISCONSIN MED COLL FY 87 Wl
LOYOLA U FY 87/88 IL
INDIANA U FY 88 IN
CUYAHOGA CO FY 87 OH
CLEVELAND FY 87 OH
TOLEDO FY 87 OH
ILLINOIS STATE U FY 87/88 IL
WAUSAU FY 88 Wl
OSHKOSH FY 88 Wl
LICKING CO FY 87 OH
COLUMBUS FY 88 OH
VIGO CO FY 88 IN
WAYNE CO FY 86 Ml
LEBANON FY 85 OH
MICHIGAN DOH FY 84/85 Ml
MISSAUKEE CO FY 87 Ml
BOONEVILLE FY 87 IN
BLOOMFIELD FY 86/87 IN
GOVERNOR ST U FY 86/87 IL
BEND FY 88 IN
SPEEDWAY FY 87 IN
MITCHELL FY 87 IN
ELKHART FY 87 IN
HUDSON FY 86/87 IN

uuesi
noneu ousis
Rckfnm
Final Report Ineligible Unsupported Unnecessary/ Erf
Issued Costs Costs Unreasonable (Fund
Costs To Bel
5/17/89
5/17/89
5/18/89
5/18/89
5/22/89
5/22/89
5/25/89
5/25/89
5/30/89
6/ 9/89
6/ 9/89
6/ 9/89
6/ 9/89
6/ 9/89
6/12/89
6/12/89
6/14/89
6/15/89
6/16/89
6/16/89
6/16/89
6/16/89
6/20/89
6/29/89
7/25/89
7/25/89
7/25/89
7/26/89
7/26/89
8/ 2/89
8/ 3/89
8/ 3/89
8/ 4/89
8/ 4/89
8/ 7/89
8/ 8/89
8/ 9/89
8/ 9/89
8/11/89
8/11/89
8/11/89
8/15/89
8/15/89
8/16/89
9/ 5/89
9/18/89
9/18/89
9/21/89
9/25/89
4/11/89
4/11/89
4/19/89
4/27/89
5/ 3/89
5/ 3/89
5/ 3/89
5/11/89
5/11/89
5/11/89
5/11/89
5/18/89
6/ 9/89
6/16/89
6/27/89
7/19/89
7/26/89
8/ 7/89
8/ 8/89
8/11/89
8/16/89
8/16/89
8/23/89
8/23/89
8/29/89
8/29/89
8/29/89
8/29/89
8/30/89
8/30/89
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
36,414
0
0
0
0
0
0
0
0
0
16,171
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
imended
iciencies
s Be Put
tter Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
45

-------
Audit Control Auditee
Number
N3H M J9-05-0234-950 1 076
N3H M K9-05-02 1 5-950 1 089
N3HMJ9-05-0450-9501 172
N3HMJ9-05-0322-9501 173
N3HMK9-05-0462-9501 1 74
N3HMJ9-05-0422-9501 177

C3HWK9-06-0095-9500524
C3HWK9-06-01 02-9500542
C3HWK9-06-01 13-9500556
C3HWK9-06-01 16-9500561
C3HWK9-06-01 24-9500698
C3HWK9-06-01 25-9500699
C3HWK9-06-01 29-9500729
C3HWK9-06-0 1 38-9500830
C3HWK9-06-01 39-9500838
C3HWK9-06-0 1 40-9500839
C3HWK9-06-01 41 -9500848
C3HWK9-06-01 42-9500849
C3HWK9-06-0144-9500858
C3HWK9-06-01 46-9500892
C3HWK9-06-01 47-9500903
C3HWK9-06-0 1 48-95009 1 3
C3HWK9-06-0149-9500914
C3HWK9-06-0 1 5 1 -950094 1
C3HWK9-06-01 52-9500953
C3HWK9-06-01 53-9500962
C3HWK9-06-0 1 64-950097 1
C3HWK9-06-01 63-9500973
C3HWK9-06-0 1 65-9500995
C3HWK9-06-01 67-9501 002
C3HWK9-06-01 68-9501 004
C3 H WK9-06-0 1 69-950 1 006
C3HWK9-06-0171-9501010
C3HWK9-06-01 72-9501 01 1
C3 H WK9-06-0 1 73-950 1 024
C3HWK9-06-01 74-950 1 025
C3HWK9-06-01 77-950 1 029
C3HWK9-06-0 1 78-950 1 030
C3H MJ9-06-0 1 79-950 1 032
C3H WK9-06-0 1 80-950 1 036
C3HWK9-06-0 1 8 1 -950 1 037
C3HWK9-06-0 1 82-950 1 042
C3HWK9-06-0 1 83-950 1 052
C3HWK9-06-01 92-9501 104
C3HWK9-06-0193-9501 105
C3HWK9-06-01 94-9501 106
C3HWK9-06-01 95-9501 107
C3HWK9-06-0 1 96-950 1 1 08
C3HWK9-06-0201 -9501 145
C3HWK9-06-021 5-9501 153
C3HWK9-06-0216-9501 160
C3HWK9-06-021 7-9501 161
C3HWK9-06-021 9-9501 181
N3HMJ9-06-0093-9500522
N3HWK9-06-01 28-9500728
N3HWK9-06-0 1 89-950 1 096
N3HWK9-06-0 1 90-950 1 097
N3H WK9-06-0 1 9 1 -950 1 098
N3HWK9-06-0198-9501109
N3HWJ9-06-01 99-9501 1 10
N3HWK9-06-01 97-9501 1 1 1
N3HWK9-06-01 54-9501 193
N3HWK9-06-01 66-9501 194
N3HWK9-06-0 1 55-950 1 1 95
N3H M K9-06-0 1 6 1 -950 1 1 96
N3HMK9-06-0207-9501 198
N3HWJ9-06-0208-9501 199
N3HWK9-06-021 1-9501200
N3H WK9-06-02 1 4-950 1 2 1 0
N3H U K9-06-0 1 56-950 1 225
N3HWK9-06-01 57-9501 226
N3HWK9-06-01 58-9501 227
N3HWK9-06-01 60-9501 238
N3HWK9-06-0205-950 1 239
N3HWK9-06-0206-9501 241
N3HWJ9-06-02 1 0-950 1 243
CLERMONT CO FY 87 OH
WISCONSIN MED COLLEGE FY 87 Wl
MONTGOMERY CO OH
PORTAGE CO FY 87 OH
WISCONSIN MED COLLEGE FY 88 Wl
MN STATE OF FY 88 MN
TOTAL OF REGION 05 = 97
LOCKHART TX
GARLAND TX
PINEHURST TX
LOCKHART TX
HARRIS COUNTY WCID NO.1 TX
HARRIS COUNTY WCID NO. 1 TX
LEAGUE CITY TX
CLAREMORE OK
GRANBURY TX
GRANBURY TX
EUREKA SPRINGS AR
EUREKA SPRINGS AR
PORTER MUD TX
SAN ANTONIO TX
WESTLAKE LA
POTEAU OK
POTEAU OK
GAINESVILLE TX
GUYMON OK
KENNER LA
LAKE CHARLES LA
KENNEDALE TX
CONROE TX
MEMORIAL VILLAGES WATER AUTHTX
GAINESVILLE TX
JOHNSTON CO. RWD #1 OK
LEANDER TX
LOS FRESNOS TX
WALDRON AR
WALLIS TX
MELVILLE LA
LAS CRUCES NM
ARKANSAS DEPT. OF POLLUTION AR
MANGUM OK
COTULLA TX
DERIDDER LA
MEMORIAL VILLAGES WATER AUTHTX
KILGORE TX
KILGORE TX
BROWNWOOD TX
LUTHER OK
HARRAH OK
SHREVEPORT LA
LUFKIN TX
JACKSONVILLE WASTEWAT4ER UTIAR
JACKSONVILLE WASTEWATER UTILAR
EL PASO WATER UTILITIES TX
TEXAS, STATE OF TX
NACOGDOCHES TX
MCALLEN TX
BRYAN TX
OKLAHOMA CITY OK
SAN BENITO TX
HEALTH & ENVIRONMENT DEPT. NM
ABILENE TX
ST BERNARD PAR POLICE JURY LA
SAN BENITO TX
LOS LUNAS NM
HOUSTON TX
ALBUQUERQUE NM
ESPANOLA NM
MARSHALL TX
CLEBURNE TX
NEW MEXICO STATE UNIVERSITY NM
GUTHRIE OK
GUTHRIE OK
AUSTIN TX
FARMINGTON NM
PUEBLO OF ACOMA NM
ESPANOLA NM
Final Report
Issued
8/30/89
8/31/89
9/18/89
9/18/89
9/18/89
9/19/89

4/ 5/89
4/13/89
4/20/89
4/24/89
6/ 2/89
6/ 5/89
6/ 8/89
7/13/89
7/17/89
7/17/89
7/19/89
7/19/89
7/21/89
7/31/89
8/ 2/89
8/ 3/89
8/ 3/89
8/ 8/89
8/ 9/89
8/10/89
8/10/89
8/10/89
8/11/89
8/14/89
8/14/89
8/14/89
8/15/89
8/15/89
8/16/89
8/16/89
8/17/89
8/17/89
8/17/89
8/18/89
8/18/89
8/21/89
8/22/89
9/ 6/89
9/ 6/89
9/ 6/89
9/ 6/89
9/ 7/89
9/12/89
9/14/89
9/15/89
9/15/89
9/20/89
4/ 3/89
6/ 8/89
9/ 5/89
9/ 5/89
9/ 5/89
9/ 7/89
9/ 7/89
9/ 7/89
9/21/89
9/21/89
9/21/89
9/21/89
9/21/89
9/21/89
9/21/89
9/26/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
uuesi
lionea losis
DA/I/IITI
Ineligible Unsupported Unnecessary/ EH
Costs Costs Unreasonable (Fund
Costs To Bel
0
0
0
0
0
122,787
175,372
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
mended
iciencies
s Be Put
tter Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
46

-------
Audit Control Auditee
Number
N3HWK9-06-02 1 3-950 1 285
P3CWL9-06-0 127-91 003 1 8

C3HWK9-07-0085-9500528
C3HWK9-07-0087-9500529
C3HWK9-07-0091 -9500553
C3HWJ9-07-0095-9500704
C3HWK9-07-0097-95007 1 0
C3HWK9-07-0098-950071 1
C3HWK9-07-0099-9500719
C3HWK9-07-01 00-9500720
C3H WK9-07-0 1 0 1 -950072 1
C3HWK9-07-01 02-9500722
C3HWK9-07-0106-9500733
C3HWK9-07-01 07-9500734
C3HWK9-07-0 1 03-9500735
C3HWK9-07-0 1 08-9500742
C3HWK9-07-0109-9500743
C3HWK9-07-01 1 1-9500754
C3HWK9-07-01 1 2-9500765
C3HWK9-07-01 13-9500766
C3HWK9-07-01 16-9500836
C3HWK9-07-01 17-9500844
C3HWK9-07-01 18-9500845
C3HWK9-07-01 22-9500857
C3HWK9-07-01 23-9500873
C3HWK9-07-01 24-9500878
C3HWK9-07-01 28-9500893
C3HWK9-07-0 1 30-9500902
C3HWK9-07-0 1 3 1 -9500904
C3HWK9-07-0 1 32-9500905
C3HWK9-07-01 33-9500907
C3HWK9-07-01 34-9500908
C3HWK9-07-0 1 36-95009 1 5
C3HWK9-07-0 1 35-95009 1 8
C3HWK9-07-01 37-950091 9
C3HWK9-07-01 38-9500925
C3HWK9-07-01 39-9500926
C3HWK9-07-01 40-9500927
C3HWK9-07-0 1 4 1 -9500936
C3HWK9-07-01 42-9500937
C3HWK9-07-01 43-9500938
C3HWK9-07-0 1 44-9500940
C3HWK9-07-01 45-9500944
C3HWK9-07-01 46-9500945
C3HWK9-07-01 47-9500946
C3HWK9-07-01 48-9500950
C3H WK9-07-0 1 49-950095 1
C3HWK9-07-01 50-9500952
C3HWK9-07-0 1 5 1 -9500960
C3HWK9-07-01 52-9500961
C3HWK9-07-01 53-9500976
C3HWK9-07-01 54-9500980
C3HWK9-07-01 55-9500984
C3HWK9-07-01 56-9500987
C3HWK9-07-01 57-9500988
C3HWK9-07-0158-9500989
C3HWK9-07-01 59-9500993
C3HWK9-07-0160-9500994
C3HWK9-07-0 1 6 1 -950 1 000
C3H WK9-07-0 1 62-950 1 00 1
C3HWK9-07 -01 63-950 1 003
C3H WK9-07-0 1 64-950 1 0 1 4
C3HWK9-07-0 1 66-950 1 022
C3HWK9-07 -01 68-9501 023
C3H WK9-07-0 1 69-950 1 034
C3HWK9-07-01 70-9501 038
C3HWK9-07-0 1 7 1 -950 1 039
C3HWK9-07-01 72-9501 040
C3HWK9-07-0173-9501041
C3H WK9-07-0 1 74-950 1 043
C3HWK9-07-0 1 76-950 1 045
C3HWK9-07-0 1 77-950 1 046
C3H WK9-07-0 1 78-950 1 047
C3HWK9-07-0 1 79-950 1 05 1
C3HWK9-07-01 86-9501 1 03
C3HWK9-07-01 92-9501 1 23
CORPUS CHRISTI
TX
NATIONAL RURAL WATER ASSOC. OK
TOTAL OF REGION 06
KANSAS CITY,
OTTAWA
= 72
KS
KS
STANTON COUNTY SID NO.1 NE
ST. MARY
WAUKON
POSTViLLE
COFFEYVILLE
HALLSVILLE
HALLSVILLE
HALLSVILLE
HUXLEY
MARYVILLE
KNOXVILLE
JOPLIN
JOPLIN
LEADWOOD
MOUNTAIN GROVE
MOUNTAIN GROVE
FOWLER
OLATHE
OLATHE
MACKSVILLE
FLINT HILL
FLAT RIVER
FULTON
KNOB NOSTER
WINFIELD
WILLARD
WRIGHT CITY
TWIN LAKES SANITARY
TWIN LAKES SANITARY
POPULAR BLUFF
UTICA
GREENSBURG
GOVE
GARNAVILLO
HOLLISTER
HOLLISTER
GOODLAND
BROOKFIELD
RENICK
CLARENCE
CLARENCE
HUMBOLDT
HIGH HILL
HIAWATHA
IBERIA
KAHOKA
LABETTE
MO
IA
IA
KS
MO
MO
MO
IA
MO
IA
MO
MO
MO
MO
MO
KS
KS
KS
KS
MO
MO
MO
MO
KS
MO
MO
SEWER DIIA
SEWER DIIA
MO
KS
KS
KS
IA
MO
MO
KS
MO
MO
MO
MO
KS
MO
KS
MO
MO
KS
LITTLE BLUE VALLEY SEWER DISMO
FAIRFIELD
CARL JUNCTION
CREIGHTON
ALTOONA
ARCADIA
CLARKS
HOLLISTER
HUNNEWELL
DONIPHAN
LABETTE
LA PLATA
SILVER CREEK
MENDON
CENTER
ARKANSAS
CARL JUNCTION
DECORAH
GOODLAND
EOLIA
HUMANSVILLE
HUMBOLDT
HARTLEY
FAYETTE
LITCHFIELD
IA
MO
NE
IA
NE
NE
MO
MO
MO
KS
MO
NE
MO
MO
KS
MO
IA
KS
MO
MO
KS
IS
IA
NE
Final Report Ineligible Unsupported Unnecessary/ Efficiencies
Issued Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
9/29/89
6/ 8/89

4/ 6/89
4/ 6/89
4/19/89
6/ 6/89
6/ 6/89
6/ 6/89
6/ 7/89
6/ 7/89
6/ 7/89
6/ 7/89
6/ 8/89
6/ 8/89
6/ 8/89
6/ 9/89
6/ 9/89
6/14/89
6/16/89
6/16/89
7/14/89
7/18/89
7/18/89
7/21/89
7/24/89
7/25/89
7/31/89
8/ 2/89
8/ 2/89
8/ 2/89
8/ 3/89
8/ 3/89
8/ 3/89
8/ 4/89
8/ 4/89
8/ 7/89
8/ 7/89
8/ 7/89
8/ 7/89
8/ 7/89
8/ 8/89
8/ 8/89
8/ 8/89
8/ 8/89
8/ 8/89
8/ 9/89
8/ 9/89
8/ 9/89
8/10/89
8/10/89
8/11/89
8/11/89
8/11/89
8/11/89
8/11/89
8/11/89
8/11/89
8/11/89
8/14/89
8/14/89
8/14/89
8/16/89
8/15/89
8/16/89
8/17/89
8/18/89
8/18/89
8/18/89
8/18/89
8/21/89
8/21/89
8/21/89
8/21/89
8/22/89
9/ 6/89
9/ 7/89
0
0
0
0
0
0
46,500
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
874,730
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9,258
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
47

-------
Audit Control Auditee
Number
C3HWK9-07-0 193-9501 125
C3HWK9-07-0 194-9501 127
C3HWK9-07-0 195-9501 128
C3HWK9-07-0196-9501 135
C3HMJ9-07-01 97-9501 136
C3HMJ9-07-01 98-9501 137
C3HWK9-07-0235-9501 152
C3HWK9-07-0236-9501 159
C3HWK9-07-0237-9501 170
C3HWK9-07-0238-9501 171
C3HWK9-07-0239-9501 182
C3HWK9-07-0246-9501 186
C3HWK9-07-0240-9501 187
C3HWK9-07-024 1-9501 188
C3HWK9-07-0242-9501 189
C3HWK9-07-0243-9501 190
C3HWK9-07-0244-9501 191
C3HWK9-07-0245-9501 192
N3HWK9-07-0086-9500523
N3HWK9-07-0 1 04-950073 1
N3HBK9-07-01 05-9500732
N3HWK9-07-01 75-9501 044
N3HUK9-07-01 82-9501 094
N3HWK9-07-0 1 8 1 -950 1 095
N3HUJ9-07-0184-9501 101
N3HWK9-07-0 185-9501 102
N3HAK9-07-01 87-9501 112
N3HWK9-07-0188-9501 1 1 3
N3HWK9-07-0 1 89-950 1114
N3HWK9-07-0 190-9501 1 1 7
N3HWK9-07-0 1 9 1 -950 1119
N3HUK9-07-0247-9501203
N3HWK9-07-0248-950 1 204
N3HWK9-07-0249-9501 205
N3HWK9-07-0209-950 1 286
N3HWK9-07-0208-950 1 287
N3HWK9-07-0234-9501 288
N3H UK9-07-02 1 6-950 1 289
N3HWK9-07-0222-9501 290
N3HMK9-07-0224-9501291
N3HWK9-07-0223-9501 292

C3H M K9-08-0057-9500545
C3H M J9-08-0058-950057 1
C3HMJ9-08-0062-9500586
C3HMJ9-08-0071 -9500638
C3HMJ9-08-0073-9500694
C3HMK9-08-0077-9500780
C3HMK9-08-0080-9500831
C3H M K9-08-0083-9500855
C3H M K9-08-0084-950086 1
C3HMK9-08-0085-9500866
C3HMK9-08-0089-9500956
C3HMK9-08-0090-9500990
C3HMK9-08-009 1 -9501 02 1
C3HMJ9-08-0093-9501063
C3HMK9-08-0094-9501 1 1 5
C3HMK9-08-0096-9501 179
C3HMK9-08-01 13-9501277
N3H M K9-08-0063-9500592
N3H M K9-08-0064-9500607
N3H M J9-08-0067-9500626
N3HUJ9-08-0068-9500635
N3HMK9-08-0069-9500636
N3HMJ9-08-0070-9500637
N3HMK9-08-0072-9500693
N3HMK9-08-0074-9500705
N3HMK9-08-0076-950075 1
N3HMK9-08-0078-950081 4
N3HMK9-08-0079-9500823
N3HMK9-08-0081-9500832
N3HMK9-08-0082-9500833
N3HMJ9-08-0086-9500889
N3HMJ9-08-0087-9500890
N3HMJ9-08-0088-9500899
N3HMK9-08-0095-9501 1 78
N3HMK9-08-0097-9501 183
NEHAWKA NE
MARION KS
GALLATIN MO
LITTLE BLUE VALLEY SEWER DISMO
NEBRASKA DEPT.OF ENVIRONMENTNE
DEPARTMENT OF ENVIRONMENTAL NE
GALENA MO
METRO ST. LOUIS SEWER DISTR MO
EXCELSIOR SPRINGS MO
BELLWOOD NE
GAINESVILLE MO
MOKANE MO
IRONDALE MO
GLENVIL NE
NORTHEAST PUBLIC SEWER DIS. MO
ANKENY IA
BAYARD NE
LYMAN NE
CAMDENTON MO
JOHNSON COUNTY KS
UNIVERSITY OF MISSOURI MO
PARSONS KS
UNIVERSITY OF IOWA IA
LAWRENCE KS
UNIVERSITY OF IOWA IA
POLK COUNTY IA
LINCOLN NB
CHANUTE KS
CHANUTE KS
AUGUSTA KS
AUGUSTA KS
UNIVERSITY NEBRASKA SYSTEM NE
DES MOINES IA
WATERLOO IA
HUTCHINSON KS
COFFEYVILLE KS
INDEPENDENCE KS
KS UN OF (LARWENCE CAMPUS) KS
CHERRYVALE KS
KS DEPT HEALTH & ENVIRONMENTKS
JEFFERSON CITY MO
TOTAL OF REGION 07 = 115
MISSOULA, CITY OF MT
ELK MOUNTAIN, TOWN OF WY
HARLEM, CITY OF MT
DEPT OF ENVIRONMENTAL QUAL. WY
WEST FARGO, CITY OF ND
MINOT, CITY OF ND
BRECKENRIDGE SANITATION Dl CO
HELENA, CITY OF MT
METRO DENVER SEW DISP Dl #1 CO
CO SPRINGS DEPT OF UTILS. CO
GRAND FORKS, CITY OF ND
BROOMFIELD, CITY OF CO
HELENA, CITY OF MT
WALHALLA PUB SCHOOL DIST #27ND
BURKE SCHOOL DIST. NO. 26-2 SD
BIGFORK CTY WTR & SEWER Dl MT
GUNNISON, CITY OF CO
THREE AFFILATED TRIBES ND
SOUTHERN UTE INDIAN TRIBE CO
COLORADO, STATE OF CO
NORTH DAKOTA STATE UNIV. ND
LOWER BRULE SIOUX IND. TR. SD
NORTH DAKOTA PARKS & REC DP ND
CHEYENNE RIVER SIOUX TRIBE SD
GREAT FALLS, CITY OF MT
RIVERTON, CITY OF WY
CONF SALISH & KOOTENAI TR. MT
CROW TRIBE OF INDIANS MT
NORTHERN CHEYENNE TRIBE MT
NORTHERN CHEYENNE TRIBE MT
DRAYTON PUB. SCH. DIS. #19 ND
MILNOR SCH DIST NO. 2 ND
OAKES PUBLIC SCHOOL DIS.#41 ND
FARGO, CITY OF ND
WYOMING HLTH & SOC SVCS DEPTWY
Final Report
Issued
9/ 7/89
9/ 7/89
9/ 8/89
9/11/89
9/11/89
9/11/89
9/14/89
9/15/89
9/18/89
9/18/89
9/20/89
9/20/89
9/20/89
9/20/89
9/20/89
9/20/89
9/20/89
9/20/89
4/ 3/89
6/ 8/89
6/ 8/89
8/21/89
9/ 5/89
9/ 5/89
9/ 6/89
9/ 6/89
9/ 7/89
9/ 7/89
9/ 7/89
9/ 7/89
9/ 7/89
9/22/89
9/22/89
9/22/89
9/29/89
9/29/89
9/29/89
9/29/89
9/29/89
9/29/89
9/29/89

4/14/89
4/26/89
5/ 3/89
5/12/89
6/ 2/89
6/22/89
7/13/89
7/19/89
7/21/89
7/24/89
8/ 9/89
8/11/89
8/16/89
8/24/89
9/ 7/89
9/19/89
9/28/89
5/ 4/89
5/ 8/89
5/11/89
5/12/89
5/12/89
5/12/89
6/ 2/89
6/ 6/89
6/13/89
7/ 7/89
7/12/89
7/13/89
7/13/89
7/31/89
7/31/89
8/ 1/89
9/19/89
9/20/89
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
544,435
0
7,122
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,482,045
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,685
0
0
0
0
0
0
0
3,151
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
48

-------
Questioned Costs
Audit Control Auditee
Number
N3HMJ9-08-0098-9501 184
N3HMK9-08-01 1 1-9501 211
N3HMK9-08-01 12-9501276
N3HMJ9-08-01 14-9501278
WYOMING GAME & FISH
LARIMER COUNTY
LONGMONT, CITY OF
SIOUX FALLS, CITY OF
TOTAL OF REGION 08 =
COMM WY
CO
CO
SD
39
DAS«nn-
Final Report Ineligible Unsupported Unnecessary/ Efl
Issued Costs Costs Unreasonable (Fund
Costs To Be
9/20/89
9/26/89
9/28/89
9/28/89
0
0
0
0
4,836
0
0
0
0
0
0
0
0
0
0
imended
iiciencies
Is Be Put
tier Use)
0
0
0
0
0
 C3HMK9-09-0183-9500707
 C3HMK9-09-0198-9500753
 C3HMK9-09-0200-9500758
 C3HMK9-09-0224-9500813
 C3HMK9-09-0279-9501031
 C3HMK9-09-0300-9501282
 M3FMP9-09-0220-9400036
 N3HMK9-09-0130-9500537
 N3HMK9-09-0131-9500538
 N3HMK9-09-0132-9500546
 N3HMK9-09-0133-9500547
 N3HMK9-09-0134-9500549
 N3HMK9-09-0136-9500577
 N3HMK9-09-0137-9500578
 N3HMK9-09-0138-9500587
 N3HMK9-09-0139-9500593
 N3HMK9-09-0140-9500594
 N3HMK9-09-0144-9500608
 N3H M K9-09-0145-9500609
 N3H M K9-09-0147-9500627
 N3HMK9-09-0148-9500628
 N3 H M K9-09-0149-9500629
 N3HMK9-09-0150-9500630
 N3HMK9-09-0151-9500639
 N3HMK9-09-0153-9500644
 N3HMK9-09-0155-9500657
 N3 H M K9-09-0156-9500658
 N3H M K9-09-0164-9500659
 N3HMK9-09-0181-9500697
 N3HMK9-09-0182-9500706
 N3HMK9-09-0184-9500708
 N3HMK9-09-0185-9500724
 N3H M K9-09-0186-9500726
 N3HMK9-09-0187-9500727
 N3HMK9-09-0188-9500730
 N3HMK9-09-0197-9500750
 N3HMK9-09-0199-9500756
 N3HMK9-09-0201-9500759
 N3HMK9-09-0202-9500762
 N3HMK9-09-0203-9500763
 N3HUK9-09-0204-9500764
 N3HMK9-09-0205-9500773
 N3 H M K9-09-0206-9500774
 N3HMK9-09-0207-9500775
 N3HMK9-09-0208-9500776
 N3HMK9-09-0209-9500777
 N3 H M K9-09-0210-9500781
 N3HMK9-09-0211-9500782
 N3HMK9-09-0213-9500787
 N3HMK9-09-0212-9500788
 N3HMK9-09-0214-9500789
 N3 H M K9-09-0215-9500790
 N3HMK9-09-0216-9500791
 N3HMK9-09-0218-9500799
 N3HMK9-09-0219-9500800
 N3HMK9-09-0221 -9500804
 N3HMK9-09-0222-9500805
 N3HMK9-09-0226-9500824
 N3H M K9-09-0227-9500825
 N3HMK9-09-0228-9500834
 N3HMK9-09-0229-9500835
 N3HMK9-09-0233-9500851
 N3HMK9-09-0234-9500852
 N3HMK9-09-0235-9500854
 N3HMK9-09-0236-9500862
N3HMK9-09-0237-9500863
 N3HMK9-09-0238-9500864
 N3HMK9-09-0239-9500867
N3HMK9-09-0240-9500868
N3 H M K9-09-0241 -9500869
N3HMK9-09-0242-9500870
N3HMK9-09-0244-9500885
 ELKO, CITY OF          NV                6/ 6/89         0
 WATSONVILLE, CITY OF     CA             6/14/89         0
 VALLEY CENTER MUNI WTR. DIS.CA          6/15/89         0
 HENDERSON, CITY OF      NV             7/ 7/89         0
 SOUTH COAST AIR QUALITY MGMTCA        8/17/89         0
 MONTEREY WTR POLL CONTROL AGCA       9/28/89         0
 NO MARIANA ISLANDS, COMM OF            6/29/89         0
 EUREKA, CITY OF        CA               4/10/89         0
 VALLEY CENTER MUNI WATER Dl CA          4/10/89         0
 KERN COUNCIL OF GOVERNMENTS CA       4/14/89         0
 KAUI, COUNTY OF        HI               4/14/89         0
 RENO, CITY OF         NV                4/18/89         0
 SAN JOSE, CITY OF      CA              5/ 1/89         0
 MAUI, COUNTY OF        HI               5/ 1/89         0
 COLFAX, CITY OF        CA               5/ 3/89         0
 SAN JOAQUIN,  COUNTY OF    CA           5/ 4/89         0
 TRACY, CITY OF         CA                5/ 4/89         0
 ASSOCIATION OF BAY AREA GOV CA          5/ 8/89         0
 GUAM, GOVERNMENT OF                   5/ 8/89         0
 SAN BERNADINO, COUNTY OF   CA          5/11/89         0
 DINUBA, CITY OF        CA                5/11/89         0
 TULARE, COUNTY OF       CA             5/11/89         0
 SOUTH LAKE TAHOE, CITY OF  CA           5/11/89         0
 FED STATES OF MICRO NTL GOVT           5/12/89         0
 PETALUMA, CITY OF       CA              5/15/89         0
 CORONA,  CITY OF        CA              5/18/89         0
 LA COUNTY SANITATION DIST   CA           5/18/89         0
 GOLETA SANITARY DISTRICT   CA            5/22/89         0
 CORNING, CITY OF       CA              6/ 5/89         0
 SAN JOSE, CITY OF       CA               6/ 6/89         0
 WASHOE,  COUNTY OF       NV            6/ 6/89         0
 AVALON, CITY OF         CA               6/ 8/89         0
 SOUTH EAST REG RECL AUTH  CA          6/ 8/89         0
 LOS ANGELES, CITY OF    CA             6/ 8/89         0
 FORT MOJAVE  INDIAN TRIBE   CA            6/ 8/89         0
 MODESTO, CITY OF        CA              6/13/89         0
 FLAGSTAFF, CITY OF      AZ               6/14/89         0
 KINGS, COUNTY OF        CA              6/15/89         0
 LOS ALAMOS COMM SVCS DIST  CA          6/16/89         0
 SEWERAGE AGCY. OF SO. MARIN CA          6/16/89         0
 PIMA COUNTY COMM  COLLEGE   AZ         6/16/89         0
 WATSONVILLE,  CITY OF    CA             6/21/89         0
 SANTA CRUZ, CITY OF      CA              6/21/89         0
 SACRAMENTO,  COUNTY OF    CA           6/21/89         0
 NOVATO SANITARY DISTRICT  CA           6/22/89         0
 GUAM, PORT AUTHORITY OF    GU           6/22/89         0
 HUGHSON, CITY OF        CA              6/22/89         0
 EAST BAY  MUNICIPAL UTIL DIS CA            6/22/89     9 485
 SOUTH BAY DISCHARGERS AUTH. CA          6/23/89         0
 SEELEY COUNTY WATER DIST   CA           6/23/89         0
 CLEARLAKE OAKS CNTY WTR Dl CA          6/23/89         0
 SAN  DIEGO ASSOC OF GOVTS  CA          6/26/89         0
 BANNING,  CITY OF        CA               6/26/89         0
 MONTEREY BAY UNIFIED APCD  CA           6/28/89         0
 SAN  DIEGO, CITY OF      CA               6/28/89         0
 AUBURN, CITY OF         CA               6/29/89         0
 SOUTH TAHOE PUBLIC UTL DIS  CA           6/30/89    39,538
 WESTERN  CONS FOR PUBLIC HL CA          7/12/89         0
 CAYUCOS  SANITARY DISTRICT   CA           7/12/89         0
 NATL PRO  PERS MAYORES, ASSN CA          7/13/89         0
 BANNING, CITY  OF       CA               7/13/89         0
 NEWMAN, CITY  OF        CA               7/19/89          0
 SOUTH COAST AIR QUALITY MG CA           7/19/89          0
 SAN DIEGO, COUNTY OF     CA             7/19/89          0
 BAY AREA AIR QUALITY MGMT.  CA            7/21/89          0
 UPPER SAN GABRIEL VALLEY WD CA          7/21/89          0
 ALAMEDA, COUNTY OF      CA             7/21/89          0
 MONTEREY RG WTR POL CTRL AG CA         7/24/89          0
 SAN FRANCISCO, CITY & CO   CA            7/24/89          0
 BURLINGAME, CITY OF      CA              7/24/89          0
ARCATA, CITY OF         CA                7/24/89          0
WATSONVILLE, CITY OF     CA              7/27/89          0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
0
0
0
0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
0
0
 0
 0
0
0
0
0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
 0
0
0
0
0
                                                                                                                           49

-------
Audit Control Auditee
Number
N3HMK9-09-0245-9500886
N3HMK9-09-0246-9500891
N3HMK9-09-0247-9500894
N3HMK9-09-0255-9500900
N3HMK9-09-0256-9500906
N3HMK9-09-0268-9500957
N3HMK9-09-0269-9500958
N3HMK9-09-0270-9500959
N3HMH9-09-0271 -9500968
N3HMK9-09-0272-9500969
N3H M K9-09-0273-9500974
N3H M K9-09-0274-9500975
N3H M K9-09-0275-950099 1
N3HM K9-09-0276-950 1 026
N3HMJ9-09-0277-9501027
N3HMK9-09-0278-950 1 028
N3HMK9-09-0285-9501 162
N3HMK9-09-0286-9501 163
N3HMK9-09-0287-9501 164
N3HMK9-09-0289-9501 165
N3HMK9-09-0288-9501 166
N3HMK9-09-0290-9501 180
N3HMK9-09-0294-9501212
N3HM J9-09-0297-950 1 279
N3HMK9-09-0298-9501 280
N3HMK9-09-0299-9501281

C3HMK9-10-0132-9500535
C3HMK9-10-0141-9500550
C3HMJ9-1 0-01 42-9500579
C3HMJ9-1 0-01 43-9500588
C3HMJ9-1 0-01 49-9500660
C3HMJ9-10-0150-9500661
C3HMK9-10-0157-9500806
C3H M K9- 1 0-0 1 58-9500826
C3HMJ9-10-0162-9500895
C3H M J9- 1 0-0 1 63-9500970
C3HMK9-1 0-01 64-9501 048
C3HMK9-1 0-01 68-9501 062
C3HMJ9-10-0171-9501118
C3HMK9-10-0176-9501213
N3HMJ9-10-0136-9500548
N3HMJ9-10-0137-9500551
N3HMJ9-1 0-01 40-9500568
N3HMJ9-10-0139-9500569
N3HM J9- 1 0-0 1 38-9500570
N3HMJ9-10-0147-9500651
N3HMJ9-10-0152-9500709
N3HMK9-10-0153-9500752
N3HMK9-10-0154-9500801
N3HMK9-10-0159-9500853
N3H M J9- 1 0-0 1 60-9500880
N3HMJ9-10-0161-9500887
N3HMJ9-10-0165-9501053
N3HMJ9-10-0166-9501054
N3HMJ9-10-0170-9501 1 16
N3HMK9-10-0172-9501 185
N3HMJ9-10-01 77-9501 283

NAVAJO NATION A2
TRACY, CITY OF CA
NAVAJO NATION AZ
CENTRAL MARIN SAN. AG CA
LA. DEPT. OF WATER & POWER CA
PHOENIX, CITY OF AZ
ALBANY, CITY OF CA
FRESNO CTY GOVTS., COUNCIL OFCA
LAS GALLINAS VALLEY SAN DIS CA
RURAL COMMUNITY ASSIST COR CA
MONTEREY, COUNTY OF CA
FRESNO, CITY OF CA
VENTURA, COUNTY OF CA
GUSTINE, CITY OF CA
CALIFORNIA, STATE OF CA
FRESNO, COUNTY OF CA
SANTA BARBARA, COUNTY OF CA
SONOMA, COUNTY OF CA
VALLEJO SAN & FLOOD C TRL DICA
CALAVERAS CTY. WATER Dl CA
PIEDMONT, CITY OF CA
EDGEMONT COMM SVCS DIST CA
SIERRA LAKES COUNTY WTR DIS CA
MARICOPA COUNTY AZ
WOODLAND, CITY OF CA
MADERA, COUNTY OF CA
TOTAL OF REGION 09 = 98
CHEHALIS, CITY OF WA
NEWBERG, CITY OF OR
PUGET SOUND AIR POLL CON AG WA
FEDERAL WAY WATER & SEW. Dl WA
SOUTH BEND, CITY OF WA
GRAND COULEE, CITY OF WA
COUNCIL, CITY OF ID
SPRINGFIELD, CITY OF OR
TIETON, TOWN OF WA
SPOKANE CTY AIR POL CTRL WA
HOMER, CITY OF AK
JUNEAU, CITY & BOROUGH OF AK
YAKIMA CTY CLEAN AIR AUTH WA
FAIRBANKS N STAR BOROUGH AK
SPOKANE, CITY OF WA
IDAHO DEPT OF LABOR & IND ID
MCCLEARY, CITY OF WA
ALASKA DEPARTMENT OF LABOR AK
KITSAP, COUNTY OF WA
OREGON STATE OF OR
ANACORTES SCHOOL DIST. #103 WA
LUMMI BUSINESS COUNCIL WA
LUMMI BUSINESS COUNCIL WA
BOISE CITY ID
CLALLAM COUNTY WA
ISLAND, COUNTY OF WA
MUNI OF METRO SEATTLE WA
WASHINGTON, STATE OF WA
AK STATE DEPT OF COM & ECON AK
PORTLAND, CITY OF OR
AK DEPT OF COM & ECON DEV AK
TOTAL OF REGION 10 = 31
Final Report
Issued
7/27/89
7/31/89
7/31/89
8/ 1/89
8/ 2/89
8/ 9/89
8/ 9/89
8/ 9/89
8/10/89
8/10/89
8/10/89
8/10/89
8/11/89
8/17/89
8/17/89
8/17/89
9/15/89
9/15/89
9/15/89
9/15/89
9/15/89
9/19/89
9/26/89
9/28/89
9/28/89
9/28/89

4/10/89
4/18/89
5/ 1/89
5/ 3/89
5/22/89
5/22/89
6/30/89
7/12/89
8/ 1/89
8/10/89
8/21/89
8/24/89
9/ 7/89
9/26/89
4/18/89
4/18/89
4/25/89
4/26/89
4/26/89
5/17/89
6/ 6/89
6/13/89
6/28/89
7/19/89
7/25/89
7/27/89
8/22/89
8/22/89
9/ 7/89
9/20/89
9/28/89

Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
49,023
0
0
0
143,359
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
143,359
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
      TOTAL OTHER GRANT AUDITS
                  =  766
                         2,817,671
                          8,088
5. SUPERFUND GRANTS

P5CG*8-08-0117-9100484
M5BFL9-11-0029-9100259
M5BFL9-11-0038-9100275
M5BFL9-11-0037-9100276
M5BFL9-11 -0048-9100415
M5BFP9-11 -0044-9400039
COLORADO DOH
TOTAL OF REGION 08 =
CO
                                                1
SF IAG WITH FEMA - FY 87
SF IAGS COAST GUARD FY 87
SF IAG-JIBBOOM SITE
SF IAG-MISSOURI (HHS)
CORPS OF ENGINEERS FOLLOWUP
TOTAL OF HDQ - IAD AUDITS =   5
9/21/89
                5/ 1/89
                5/10/89
                5/10/89
                8/ 9/89
                9/19/89
221,969
221,969

     0
236,385
     0
     0
     0
236,385
967,468
967,468

     0
 71,303
     0
     0
     0
 71,303
0
0

0
0
0
0
0
0
      TOTAL SUPERFUND GRANTS
                                                                            458,354
                                                               1,038,771
50

-------
 Audit Control
 Number
Audit**
Final Report
Issued
8. OTHER CONTRACT AUDTTS

  D8CM L9-01 -0120-9100237
  D8CM L9-01 -0124-9100288
  D8BML9-01 -0126-9100289
  D8BML9-01 -0146-9100300
  D8AML9-01-0147-9100311
  D8AML9-01-0151-9100312
  D8AML9-01-0155-9100313
  D8AML9-01-0172-9100336
  D8CML9-01-0170-9100337
  D8AM L9-01 -0168-9100344
  D8CML9-01 -0167-9100345
  D8AML9-01 -0169-9100346
  D8AML9-01 -0180-9100370
  D8BML9-01-0181-9100371
  D8BML9-01-0182-9100376
  08 AM L9-01 -0210-9100433
  D8AM L9-01 -0209-9100434
  D8AML9-01 -0204-9100436
  D8AML9-01 -0203-9100437
  D8AML9-01 -0205-9100449
  P8DW*8-01-0179-9100263
  D8AM L9-02-0261 -9100256
  D8AML9-02-0300-9100323
  D8 B WL9-02-0351 -9100358
  D8AML9-02-0352-9100359
  D8AM L9-02-0355-9100372
 D8AM L9-03-0162-9100230
 D8AML9-03-0163-9100231
 D8BML9-03-0164-9100232
 D8AM L9-03-0165-9100233
 D8DM L9-03-0166-9100234
 D8DML9-03-0167-9100235
 D8 AM L9-03-0181 -9100243
 D8AML9-03-0182-9100244
 D8AM L9-03-0183-9100246
 D8AM L9-03-0190-9100252
 D8AM L9-03-0191 -9100253
 D8AML9-03-0192-9100254
 D8 AM L9-03-0193-9100255
 D8AM L9-03-0197-9100257
 D8BML9-03-0198-9100262
 D8AML9-03-0199-9100264
 D8A M L9-03-0200-9100265
 D8DML9-03-0201 -9100266
 D8AML9-03-0202-9100267
 D8AM L9-03-0207-9100272
 D8AML9-03-0211-9100277
 D8AML9-03-0213-9100278
 D8A M L9-03-0212-9100279
 D8AML9-03-0216-9100291
 D8AM L9-03-0222-9100302
 DSD M L9-03-0223-9100303
 D8AML9-03-0224-9100304
 D8AML9-03-0225-9100305
 D8AM L9-03-0226-9100306
 DSC M L9-03-0227-9100307
 D8DML9-03-0228-9100308
 D8DML9-03-0229-9100309
 DSC M L9-03-0219-9100314
 D8DML9-03-0236-9100320
 D8AML9-03-0237-9100321
 D8AML9-03-0241 -9100328
 D8DML9-03-0242-9100329
 D8DML9-03-0243-9100330
 D8DML9-03-0268-9100361
 D8DML9-03-0269-9100362
 D8AM L9-03-0270-9100363
 D8DML9-03-0272-9100364
 D8CM L9-03-0282-9100373
 D8CML9-03-0283-9100374
 D8BML9-03-0284-9100375
 D8AML9-03-0291-9100379
    ARTHUR D LITTLE         MA
    ARTHUR D LITTLE INC      MA
    COM FEDERAL PROGRAM CORP   VA
    COM FPC              MA
    COM FED PROGRAMS CORP.    VA
    CADMUS GROUP INC        MA
    INDUSTRIAL ECONOMICS INC. MA
    CADMUS GROUP          MA
    CHARLES RIVER ASSOC. INC.  MA
    ARTHUR D. LITTLE         MA
    E.G. JORDAN COMPANY, INC.  ME
    EASTERN RESEARCH GROUP    MA
    ARTHUR D LITTLE         MA
    BOOZ ALLEN HAMILTON INC.  MD
    CC JOHNSON & MALHORTA     MD
    ENSR CONSULTING & ENGINEER MA
    SIGMA  RESEARCH          MA
    SCIENCE APPLICATION  INT CORPCA
    EASTERN RESEARCH GROUP    MA
    METCALF & EDDY         MA
    PORTLAND WATER DISTRICT ME  ME
    TOTAL  OF REGION 01 =  21

    SYRACUSE RESEARCH CORP    NY
    MITCHELL TITUS & CO      NY
    MALCOLM PIRNIE         NY
    LOPEZ  ALEJANDRO & CO     PR
    DELOITTE HASKINS & SELLS   NY
    TOTAL  OF REGION 02 =   5

    BRUCE  COMPANY          DC
    LAWRENCE JOHNSON & ASSOC  DC
    COMPUTER SCIENCE CORP    VA
    LABAT-ANDERSON INC       VA
    SOBOTKA & COMPANY       DC
    WASHINGTON  CONSULTING GROUP DC
    ROY F WESTON INC        PA
    DEVELOPMENT PLANNING RESCH KS
    CLEMENT ASSOCIATES  INC    VA
    INTERNAT'L SCIENCE &  TEC  VA
    VIGYAN RESEARCH ASSOCIATES  VA
    EG&G WASHINGTON ANALYTICAL MD
    ICF INCORPORATED       VA
    DYNAMAC CORPORATION     MD
    AMERICAN MANAGEMENT SYSTEMS VA
    PRC ENVIRONMENTAL MGMT     IL
    VIGYAN RESEARCH ASSOC INC  VA
    MCMANIS ASSOCIATES INC    DC
    ICF INCORPORATED       VA
    AMERICAN MANAGEMENT SYSTEMS VA
    TECHNICAL RESOURCES INC   MD
    DYNAMAC CORPORATION     MD
    TECHNICAL RESOURCES INC   MD
    AMERICAN SCIENTIFIC INTER  VA
    AMERICAN SCIENTIFIC INTER  VA
    INTER SYSTEMS  INC       VA
    VERSAR INCORPORATED     VA
    DYNAMAC CORPORATION     MD
    TECHNICAL RESOURCES INC   MD
    PEAT MARWICK MAIN &  CO    DC
    PEAT MARWICK MAIN &  CO    DC
    SCIENTIFIC & COMMERCIAL SYS VA
    INTER SYSTEMS  INC       VA
    SRA TECHNOLOGIES INC     VA
    BAKER/TSA INCORPORATED   PA
    UNISYS CORPORATION       VA
    GKY & ASSOCIATES INC     VA
    GKY & ASSOCIATES INC     VA
    VERSAR INCORPORATED     VA
    DYNAMAC CORPORATION     MD
    BENDIX FIELD ENGINEERING  MD
    SRA TECHNOLOGIES       VA
    PEAT MARWICK MAIN &  CO    DC
    MIRANDA ASSOCIATES INC    DC
    BOOZ ALLEN & HAMILTON     MD
    S COHEN & ASSOCIATES     VA
     4/10/89
     5/23/89
     5/23/89
     5/31/89
     6/ 5/89
     6/ 5/89
     6/ 5/89
     6/27/89
     6/28/89
     7/ 5/89
     7/ 5/89
     7/ 5/89
     7/17/89
     7/17/89
     7/19/89
     8/24/89
     8/24/89
     8/24/89
     8/24/89
     8/30/89
     5/ 2/89
     4/19/89
     6/12/89
     7/11/89
     7/11/89
     7/17/89


    4/ 6/89
    4/ 6/89
    4/ 6/89
    4/ 6/89
    4/ 6/89
    4/ 6/89
    4/12/89
    4/12/89
    4/12/89
    4/18/89
    4/18/89
    4/19/89
    4/19/89
    4/25/89
    5/ 2/89
    5/ 2/89
    5/ 2/89
    5/ 2/89
    5/ 2/89
    5/ 8/89
    5/11/89
    5/11/89
    5/11/89
    5/24/89
    6/ 1/89
    6/ 1/89
    6/ 1/89
    6/ 1/89
    6/ 1/89
    6/ 1/89
    6/ 1/89
    6/ 1/89
    6/ 5/89
    6/12/89
    6/12/89
    6/19/89
    6/19/89
    6/19/89
    7/12/89
    7/12/89
    7/12/89
    7/12/89
    7/19/89
    7/19/89
    7/19/89
    7/25/89
*The dollar value of contract audits have not been shown.
 Public disclosure of the dollar value of financial reco-
 mendations could prematurely reveal the Government's
 negotiating positions or release of this information is
not routinely available under the Freedom of Information
Act. The number of these reports and dollar value of the
findings have been included in the aggregate data displayed
 below  Such data individually  excluded in this listing will
 be provided to the Congress under separate memorandum within
30 days of the transmittal of the semiannual report to the
agency head. The transmitted  data will contain appropriate
cautions regarding disclosure.
                                                                                                                            51

-------
                                                                                       Questioned Costs
Audit Control Auditee Final Report Ineligible Unsupported Unnecessary/ Efficiencies
Number Issued Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
D8CML9-03-0290-91 00380
D8AML9-03-0296-9100388
D8AML9-03-0297-9100389
D8AM L9-03-0298-9 1 0039 1
D8AML9-03-0299-9100393
D8AML9-03-0300-9100394
D8AM L9-03-030 1 -9 1 00395
D8AML9-03-0302-9 1 00396
D8AML9-03-0303-9100397
D8DML9-03-0304-9100400
D8AM L9-03-0305-9 1 0040 1
D8AM L9-03-0306-9 1 00402
D8AM L9-03-0307-9 1 00403
D8AM L9-03-03 1 0-9 1 00404
D8AML9-03-0317-9100421
D8AM L9-03-03 1 9-9 1 00422
D8CM L9-03-0323-9 1 00428
D8BML9-03-0324-9100429
D8CM L9-03-0325-9 1 00430
D8DML9-03-0320-9100431
D8CM L9-03-0328-9 1 00432
D8AML9-03-0330-91 00435
D8DML9-03-0335-9100450
D8AML9-03-0333-9 1 0045 1
D8AML9-03-0334-91 00452
D8AML9-03-0336-9100455
D8AML9-03-0337-9100456
D8DML9-03-0338-9100460
D8AM L9-03-0339-9 1 0046 1
D8AML9-03-0343-9100469
D8DM L9-03-0344-9 1 00473
D8AML9-03-0368-9 1 00495
D8AML9-03-0369-9100496
D8AML9-03-0370-9100497
D8AML9-03-0371-9100498
D8AML9-03-0372-91 00499
D8AML9-03-0373-91 00500
D8AML9-03-0374-9100501
D8BML9-03-0375-9100502
D8AML9-03-0376-9100503
D8AML9-03-0377-9100504

D8AML9-04-0236-91 0031 5
D8DML9-04-0255-91 0033 1
D8DML9-04-0254-91 00332
D8AML9-04-0248-9100333
D8AML9-04-0264-9100340
D8CML9-04-0263-91 0034 1
D8DML9-04-0261-9100342
D8AML9-04-0262-91 00343
D8DML9-04-0269-91 00353
D8AML9-04-0273-9100410
D8AML9-04-0272-910041 1
D8AML9-04-0271-9100412
D8AML9-04-0270-9 1 004 1 3
D8AML9-04-0342-9100424
D8AML9-04-0340-9100425
D8AML9-04-0341 -91 00426
D8AML9-04-0360-91 00438
D8AML9-04-0346-91 00439
D8AML9-04-0347-91 00440
D8AML9-04-0345-91 00441
H8AML9-04-0 1 78-9 1 00247
H8AM L9-04-0 1 79-9 1 00248

D8ASL9-05-0384-9 1 00327
D8EWL9-05-0394-9 1 00349
D8AML9-05-0395-9100350
D8 AWL9-05-0392-9 1 0035 1
D8ABL9-05-0476-9 1 00459
D8ARL9-05-0478-9 1 00482
E8AXL9-05-045 1 -9 1 0048 1

PEAT MARWICK MAIN & CO DC
TECHNICAL RESOURCES INC MD
JACK FAUCETT ASSOCIATES MD
JT&A INC DC
H. DANIEL ROTH ASSOCIATES MD
MOSHMAN ASSOCIATES INC MD
NOVA RESEARCH COMPANY MD
MERIDIAN RESEARCH INC MD
WASHINGTON CONSULTING GROUP DC
SYSTEX INC MD
NUS CORPORATION MD
E.H. PECHAN & ASSOCIATES VA
ENVIRON CORPORATION DC
WESTAT INCORPORATED MD
R.F. SIMON COMPANY INC PA
GENERAL PHYSICS CORPORATION MD
AMERICAN MANAGEMENT SYSTEMS VA
LABAT-ANDERSON INC VA
SRA TECHNOLOGIES INC VA
HALIFAX ENGINEERING INC VA
HALIFAX ENGINEERING INC VA
WESTAT INC MD
VERSAR INCORPORATED VA
TECHNICAL RESOURCES INC MD
DYNAMAC CORPORATION MD
VERSAR INCORPORATED VA
DYNAMAC CORPORATION MD
SRA TECHNOLOGIES INC VA
CACI INCORPORATED/COM VA
TECHNICAL RESOURCES INC MD
GENERAL SCIENCES CORP MD
HAMPSHIRE RESEARCH ASSOC VA
APOGEE RESEARCH INC MD
ICF INCORPORATED VA
ICF INCORPORATED VA
ICF INCORPORATED VA
E.H. PECHAN & ASSOCIATES VA
VERSAR INCORPORATED VA
IDEA TECH ASSOCIATES INC. VA
AUTOMATED SCIENCES GROUP MD
WESTAT INCORPORATED MD
TOTAL OF REGION 03 = 87
TECHNICAL RESOURCES INC FL
NSI TECHNOLOGY CORP. NC
NSI TECHNOLOGY NC
HUNTER ESE INC. FL
RESEARCH TRIANGLE INSTITUTE NC
SYSTEMS RESEARCH & DEV. CORPNC
NSI TECHNOLOGY SERVICES NC
NSI TECHNOLOGY SERVICES NC
SOUTHERN RESEARCH INSTITUTE AL
JONES OPERATION & MAINTENANCNC
JONES OPERATION & MAINTENANCNC
JONES OPERATION & MAINTENANCNC
JONES OPERATION & MAINTENANCNC
RESEARCH TRIANGLE INST NC
SYSTEMS RSCH & DEV CORP NC
NSI TECHNOLOGY SERVICES NC
NSI TECHNOLOGY SERVICES CORPNC
BLACK & VEATCH, INC. FL
JAMMAL & ASSOCIATES, INC. FL
RSCH & EVAL ASSOC. INC. NC
RESEARCH TRIANGLE INSTITUTE NC
RESEARCH TRIANGLE INSTITUTE NC
TOTAL OF REGION 04 = 22
BMI COLUMBUS OH
AT KEARNEY CHICAGO IL
AT KEARNEY CHICAGO IL
AT KEARNEY CHICAGO IL
EHR&T (CINCINNATI) OH
AT KEARNEY CHICAGO IL
OH MATERIALS (FT HILL) OH
TOTAL OF REGION 05 •= 7
7/25/89
7/31/89
7/31/89
7/31/89
7/31/89
7/31/89
7/31/89
7/31/89
7/31/89
8/ 1/89
8/ 1/89
8/ 1/89
8/ 1/89
8/ 2/89
8/16/89
8/16/89
8/17/89
8/17/89
8/17/89
8/21/89
8/23/89
8/24/89
8/31/89
8/31/89
8/31/89
9/ 5/89
9/ 5/89
9/ 6/89
9/ 6/89
9/11/89
9/12/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89
9/27/89

6/ 6/89
6/23/89
6/23/89
6/23/89
7/ 3/89
7/ 3/89
7/ 3/89
7/ 3/89
7/ 7/89
8/ 8/89
8/ 8/89
8/ 8/89
8/ 8/89
8/17/89
8/17/89
8/17/89
8/25/89
8/25/89
8/25/89
8/25/89
4/13/89
4/13/89

6/19/89
7/ 6/89
7/ 6/89
7/ 6/89
9/ 6/89
9/19/89
9/19/89

52

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                                                                                     Questioned Costs
 Audit Control
 Number
Auditee
Final Report
Issued
Ineligible
Costs
Unsupported
Costs
Unnecessary/
Unreasonable
Costs
Recommended
   Efficiencies
 (Funds Be Put
To Better Use)
 D8AML9-06-0101-9100245
 D8AML9-06-0120-9100280
 D8AM L9-06-0126-9100317
 D8CM L9-06-0136-9100357
 D8AM L9-06-0170-9100427
 D8 ML9-06-0186-9100457
 D8ML9-06-0187-9100458
 D8APL9-06-0202-9100475
 D8AM L9-06-0218-9100483
D8AML9-07-0089-9100249
D8AML9-07-0090-9100251
D8AML9-07-0167-9100419
D8AP L9-07-0183-9100454
D8AML9-08-0075-9100324
D8AM L9-09-0128-9100238
D8DML9-09-0129-9100240
D8AML9-09-0141-9100269
D8BML9-09-0142-9100270
D8BML9-09-0143-9100271
D8AM L9-09-0152-9100284
D8BML9-09-0157-9100285
D8BML9-09-0158-9100286
D8BML9-09-0159-9100287
D8AWL9-09-0174-9100292
D8BML9-09-0176-9100297
D8AM L9-09-0180-9100310
D8AM L9-09-0194-9100322
D8BML9-09-0217-9100334
D8AML9-09-0223-9100352
D8CML9-09-0225-9100360
D8AML9-09-0248-9100387
D8CML9-09-0249-9100398
D8CML9-09-0250-9100399
D8CML9-09-0262-9100405
D8CML9-09-0263-9100406
D8CML9-09-0264-9100407
D8CM L9-09-0265-9100408
D8DML9-09-0266-9100409
D8CML9-09-0280-9100453
D8AML9-09-0282-9100470
D8 AAL9-09-0283-9100471
D8APL9-09-0284-9100472
D8AM L9-09-0291 -9100489
D8AML9-09-0292-9100491
D8BML9-09-0293-9100492
D8BML9-09-0301-9100506
D8BML9-09-0302-91005O7
D8AMN9-09-0146-9300046
D8AMP9-09-0179-9400030
H8AML9-09-0193-9100319
S8CX*8-09-0201 -9300063
S8CT*8-09-0199-9300089
D8BML9-10-0134-9100242
   RADIAN CORPORATION       TX
   RADIAN CORPORATION       TX
   RADIAN CORPORATION       TX
   RADIAN CORPORATION       TX
   TECOM INCORPORATED       TX
   EG&G AUTOMOTIVE RESEARCH IN)TX
   EG&G AUTOMOTIVE RESEARCH INCTX
   RADIAN CORPORATION       TX
   TEXAS RESEARCH INSTITUTE   TX
   TOTAL OF REGION 06 =   9

   DEVELOPMENT PLANNING & RES KS
   DEVELOPMENT PLANNING AND RE KS
   ASK ASSOCIATES, INC.     KS
   MIDWEST RESEARCH  INSTITUTE MO
   TOTAL OF REGION 07 =   4
   RCG/HAGLER, BAILLY, INC.
   TOTAL OF REGION 08 =   1
                                                   CO
   SCIENCE APPLICATIONS INTL  CA
   MATRECON, INC         CA
   SYSTEMS APPLICATION, INC.  CA
   SYSTEMS DEVELOPMENT CORP.  CA
   SYSTEMS DEVELOPMENT CORP  CA
   SCIENCE APPLICATIONS INTL  CA
   MATRECON, INC.         CA
   MATRECON, INC.         CA
   MATRECOM, INC.         CA
   SCIENCE APPLICATIONS INTL  CA
   SYSTEMS DEVELOPMENT CORP.  CA
   C-E ENVIRONMENTAL, INC.   CA
   C-E ENVIRONMENTAL, INC.   CA
   SCS ENGINEERS         CA
   DECISION FOCUS, INC.     CA
   TRW, INC.            CA
   SCIENCE APPLICATIONS INTL  CA
   XONTECH, INC.         CA
   MATRECON, INC.         CA
   MATRECON, INC.         CA
   MATRECON, INC.         CA
   MATRECON, INC.         CA
   MATRECON, INC.         CA
   SCIENCE APPLICATIONS INTL  CA
   ROCKWELL INTL CORP      CA
   TECHNOLOGY SVCS CO      CA
   ACUREX CORP           CA
   SCIENCE APPLICATIONS INTL  CA
   JACOBS ENG GROUP, INC.    CA
   ACUREX CORP           CA
   S-CUBED              CA
   ENGINEERING SCIENCE      CA
   STERLING SOFTWARE, INC    CA
   INTERNATIONAL TECH CORP.   CA
   ACUREX CORP ENV SYS DIV   CA
   RESEARCH TRIANGLE INSTITUTE NC
   JAMES M.  MONTGOMERGY ENG.  CA
   JAMES M.  MONTGOMERY ENG.   CA
   TOTAL OF REGION 09 =   38

   BATTELLE SEATTLE RES CTR   WA
   TOTAL OF REGION 10 =   1
   4/12/89
   5/12/89
   6/ 8/89
   7/11/89
   8/17/89
   9/ 5/89
   9/ 5/89
   9/12/89
   9/20/89
   4/14/89
   4/18/89
   8/15/89
   9/ 1/89
   6/12/89
   4/10/89
   4/10/89
   5/ 5/89
   5/ 5/89
   5/ 5/89
   5/15/89
   5/18/89
   5/18/89
   5/18/89
   5/24/89
   5/30/89
   6/ 5/89
   6/12/89
   6/27/89
   7/ 6/89
   7/11/89
   7/31/89
   7/31/89
   7/31/89
   8/ 3/89
   8/ 3/89
   8/ 3/89
   8/ 3/89
   8/ 7/89
   8/31/89
   9/11/89
   9/11/89
   9/11/89
   9/25/89
   9/25/89
   9/25/89
   9/28/89
   9/28/89
   5/ 8/89
   6/ 5/89
   6/ 8/89
   7/ 6/89
   9/ 1/89
                                                                 4/10/89
     TOTAL OTHER CONTRACT AUDITS
                                          =  195
                                                                                                                          53

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Audit Control Auditee
Number
9. SUPERFUND CONTRACTS
D9BML9-01-0215-9100443
D9BML9-01-0214-9100448
E9CFL9-03-0 1 32-9 1 00326
E9CH N9-04-0234-9300082
P9DMN8-04-031 6-9300083
P9DH L8-05-0309-9 1 0026 1
P9DKN8-05-0635-9300097
P9CHN7-05-0558-9300098
D9AKL9-09-0175-9100296
D9BM L9-09-0243-9 1 00382
S9DK*8-09-0161-9300071

ROY F WESTON PA
AMERICAN ENVIRONMENTAL MGT CA
TOTAL OF REGION 01 = 2
TICHENOR & EICHE CPAS KY
TOTAL OF REGION 03 = 1
PALMETTO WOODS - REMOVAL SC
HAZTECH INC. GA
TOTAL OF REGION 04 = 2
MAECORP INC FY 87 IL
OH MATERIALS FY 87 OH
PEI ASSOC (LEE'S FARM) OH
TOTAL OF REGION 05 = 3
SCIENCE APPLICATIONS INTL CA
JRB ASSOCIATES VA
JM MONTGOMERY CONSULTING CA
Final Report Ineligible
Issued Costs

8/28/89
8/30/89
6/14/89
8/18/89
8/21/89
5/ 2/89
9/19/89
9/27/89
5/30/89
7/25/89
7/18/89
Unsupported Unnecessary/ Efficiencies
Costs Unreasonable (Funds Be Put
Costs To Better Use)






P9CT*8-11-0055-9100268
KAAREN JOHNSON ASSOCIATES
TOTAL OF HDO - IAD AUDITS =   1
5/ 5/89
     TOTAL SUPERFUND CONTRACTS

         TOTAL AUDITS =  1128
                 =  12
                                              32,820,595
                     25,975,967
603,960
                                                                                     31,803,521
         HDQ 771 - - REPORTS ISSUED BY TYPE OF AUDIT AND REGION

         SEMIANNUAL PERIOD ENDING 9/30/89
54

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 Mailing Addresses and Telephone Numbers  •  OIG HOTLINE (800) 424-4000 or (202) 382-4977
Headquarters Office of Inspector General
401 M Street, S.W  (A109)
Washington, DC 20460
(FTS or 202) 382-3137
Sacramento
Office of Inspector General
801 I Street, Room 466
Sacramento, CA 95814
Audit  (916) 551-1076 FTS 460-1076
 Atlanta
 Office of Inspector General
 1375 Peachtree Street, NE
 Suite 276 Atlanta, GA 30309
 Audit  (404)347-3623 FTS 257-3623
 Investigations (404)347-3623
 FTS 257-3623
San Francisco
Office of Inspector General
2II Main Street
Room 220
San Francisco, CA 94105
Audif (415) 974-7084 FTS 454-7084
Investigations (415)974-8151 FTS 454-8151
 Boston
 Office of Inspector General
 John F. Kennedy Federal Building Room 191'
 Boston, MA 02203
 Audit  (617) 535-3160 FTS 835-3160
 Investigations-(617) 565-3928
 FTS 565-3928
Seattle
Office of Inspector General
111 3rd Avenue, Suite 350
Seattle, WA98101
Investigations  (206) 442-1273 FTS 399-1273
 Chicago
 Office of Inspector General
 10 West Jackson Boulevard
 4th Floor
 Chicago, IL 60604
 Audit- (FTS or 312) 353-2486
 Investigations- (FTS or 312) 353-2507


 Dallas
 Office of Inspector General
 1445 Ross Avenue,  Suite 1200
 Dallas, Texas 75202-2733
 Audit. (214) 255-6621 FTS 255-6621
 Investigations. (214) 655-6610
 FTS 255-6610


 Denver
 Office of Inspector General
 999 18th Street, Suite 500
 Denver, CO 80205-2405
 Audit  (303) 294-7520 FTS 564-7520


 New York
 Office of Inspector General
 90 Church Street, Room 802
 New York, NY 10007
 Audit  (FTS or 212) 264-5730
 Investigations (FTS or 212)  264-0399


 Philadelphia
 Office of Inspector General
 841 Chestnut Street, 13th Floor
 Philadelphia, PA 19107
 Audit  (FTS or 215) 597-0497
 Investigations- (FTS or 215)  597-9421


 Research Triangle Park, NC
 Office of Inspector General
 EPA Administration Building
 Alexander Drive,  Room  113
 Research Triangle Park,  NC 27711
 Audit-  (919) 541-1028 FTS 629-1028
                                                                                                                       55

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U.S.  v!.^v-;rev ?,-".:  "•  '"  -+?'.• ricn Agency
Rt • •'        ..  •) •          -" '*. '•
23U  o.  .Oy;... Lw..n  Li.  ._;..,  /.com  1670
" " 'cago, IL    60504

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                    REPORT:
                    FRAUD,
                    WASTE
                      OR
                    ABUSE
                    TO THE
                   INSPECTOR
                   GENERAL
                HOTLINE
      Information is Confidential
      Caller Can Be Anonymous
800-424-4000
or
202-382-4977
            vvEPA
   U.S. Environmental Protection Agency • Office of the Inspector General
         401 M Street SW. • Washington, DC

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