United States
Environmental Protectioi
Agency
Office of the
Inspector General
350R89002
Office of the Inspector General
Semiannual Report
to the Congress
i ' . . , I
October 1,1988
through March 31, 1989
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Foreword
The effects of environmental pollution and neglect on
world health and safety are, unfortunately, becoming
increasingly obvious Magnified by trends in global
warming, industrial accidents and careless use or disposal of
harmful products and wastes, the importance of EPA's
mission has multiplied over the last decade As the Inspector
General, I share with William K. Reilly, EPA's new
Administrator, the sense of urgency with which the Agency
must work to succeed The work of the Office of Inspector
General, through audits, investigations, and fraud prevention
activities, acts as a strong advocate for making EPA's
programs and operations more efficient and effective
The long term strategies of the Administrator, including
enhanced enforcement, pollution prevention, ecosystem
protection, and international leadership, will require the most
efficient use of limited resources and a continued
receptiveness to critical review and constructive
recommendations The mutual application of OIG resources
to EPA's most important issues and the Agency's prompt
resolution of OIG audits will help ensure delivery of the best
possible programs of environmental protection
The success of the OIG in identifying dollars for recovery
or savings, making recommendations for improvement, and
pursuing prosecutive, civil, and administrative actions is
increasingly related to the Agency's success This report
represents only a brief glance at the breadth and depth of
OIG involvement and concern for EPA's mission Although
the OIG is statutonly independent, we are enthusiastically
looking forward to working with Mr Reilly and Agency
management to help meet the expanding challenges of EPA
John C Martin
Inspector General
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•'"* *
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Contents
Executive Summary
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
A Look at EPA's Mission and the Hazards We Face
Section 1 — Significant Problems, Abuses, and Recommendations
Summary of Audit Activities and Results
Agency Management
Construction Grants
Superfund Program . .
Special and Prospective Reviews
Other Contracts and Grants
Section 2 — Audit Resolution
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 EPA Funds
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Section 4—Fraud Prevention and Resource Management Improvements 29
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
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Executive Summary
Section 1—
Significant Problems,
Abuses, and
Recommendations
1. Aggressive Enforcement
Needed to Ensure Success of
the New Gray Market Vehicle
Program
The elimination or reduction of
key controls will further impair
EPA's ability to detect whether
"gray market" vehicle importers
are appropriately modifying and
testing automobiles to ensure
compliance with U S emission
standards (page 9)
2. Improvements Still Needed
in EPA's Contract
Management
Despite improving its contract
monitoring process, EPA was
still not effectively administering
contracts supporting the Office
of Solid Waste (OSW) EPA's
failure to properly manage
contracts resulted in contractors
performing unauthorized and
unfunded work, and Agency
personnel engaging in potential
conflicts of interest (page 9)
3. Management
Improvements Needed for
Better Compliance with
Hazardous Waste Law
Monitoring and enforcement of
Consent Agreement/Final
Orders (CA/FO) under the
Resource Conservation and
Recovery Act (RCRA) were not
timely and adequate to require
hazardous waste violators'
compliance with RCRA
requirements Noncompliance
provides economic benefits for
the violators and potentially
exposes the public to unknown
hazards (page 10)
4. Slow Processing of State
Plans Adversely Affects
Enforcement
EPA's slow processing of State
Implementation Plans (SIP) has
adversely affected enforcement
under the Clean Air Act through
significantly reduced penalties
from those originally proposed
and the Department of Justice's
refusal to pursue some cases
(page 11)
5. Complete Data Not
Available to Evaluate
Compliance and Enforcement
Actions
Incomplete data and unreliable
software in the Permit
Compliance System (PCS)
prevent EPA from measuring
compliance with the National
Pollutant Discharge Elimination
System (NPDES) and taking
appropriate actions to control
pollution discharges (page 11)
6. Different Monitors Can
Lead EPA to Different
Conclusions About Air Quality
EPA's policy of accepting air
monitor measurements without
regard to the type of monitor
used can result in inconsistent
conclusions of whether air
quality standards have been met
(page 12)
7. Noncompliance with
Special Grant Condition
Requires Grantee to Repay
over $9 Million
The Sacramento Regional
County Sanitation District,
California, did not adhere to a
special grant provision
prohibiting new sewer
connections, requiring the
grantee to repay costs claimed
plus interest totaling over $9
million (page 14 )
8. Ineligible and Unsupported
Costs of $5,648,219 on Nassau
County, New York, Project
The county of Nassau, New
York, claimed $1,773,999 of
ineligible construction costs,
administrative expenses,
engineering fees, and force
account costs An additional
$3,874,220 of unapproved costs
were questioned (page 14)
9. Grantee Claims over $2.9
Million of Ineligible or
Unsupported Costs
The town of Amherst, New
York, claimed over $1 million for
ineligible work, services, and
expenses such as development
and construction of a recreation
area and bond issuance costs of
the municipality An additional
$1 9 million of unsupported
costs were questioned (page
14)
10. Improper Contracting
Procedures Increase Grantee's
Costs by over $1.5 Million
Ft Myers, Florida, incurred an
additional $1 5 million due to a
failure to take the lowest bid on
a construction contract,
improper computation for
innovative funding, duplicative
and excessive administrative
costs, and contracting for
engineering services at three to
four times the average rate
(page 15)
11. Grantee Claims $2,489,055
of Unsupported or Ineligible
Costs
The Pima County Wastewater
Management Department,
Tucson, Arizona, claimed
$1,768,752 of ineligible
inspection fees, architectural
engineering fees, construction
costs, and administrative
expenses An additional
$720,303 of unsupported costs
were questioned (page 15)
12. Better Health and Safety
Programs Needed in Region 2
Properly functioning health and
safety programs were needed
to protect EPA employees from
exposure to moderate- and
high-risks from hazardous waste
operations (page 17)
13. Documentation Still Not
Available to Support
$5,140,503 of Love Canal
Superfund Costs
Inadequate documentation of
the New York State Department
of Environmental Conservation's
(DEC) final credit claim for the
Love Canal hazardous waste
cleanup resulted in over $3 3
million of ineligible costs, and
$1 8 million of unsupported
costs (page 17 )
14. Scientists Critical of EPA's
Monitoring of Ocean Dumping
Members of the scientific
community disagree with the
adequacy of EPA's monitoring
at the 106-Mile Deepwater
Municipal Sludge Dump (DMSD)
site (page 18)
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15. $3.7 Million in Grant
Funds to California Grantee
Should Not Have Been
Awarded
Erroneous calculations of
community population by the
California State Water
Resources Control Board
(SWRCB) allowed a sewer
collection project to proceed
that will greatly benefit
developmental interests (page
19)
16. Grantee Lacks Managerial
and Financial Capability to
Build a Needed $2.4 Million
Wastewater Treatment
Facility
The Weott Community Services
District, Weott, California, plans
to build a $2 4 million
wastewater treatment facility
although it lacks the managerial
and financial capabilities
required for effective
accomplishment of its EPA
grant project (page 19).
17. Accuracy of Contractor's
Claimed Costs in Question
Significant internal control
weaknesses in an EPA
contractor's financial
management system cast
doubts on the accuracy of $23
million of claims (page 20)
Section 2—Audit
Resolution
During the first half of fiscal
1989, the Office of Inspector
General issued 793 new audit
reports and closed 953 The 365
audit reports remaining in the
Agency followup system are
scheduled for resolution within
the next 6 months
Of the audits closed, $30 8
million of questioned costs
were sustained, including $26 5
million to be recovered, and
$4 3 million in cost efficiencies
In addition, cost recoveries in
current and prior periods
included $2 1 million in cash
collections, and at least $142
million in offsets against billing
(page 21)
Section
3—Prosecutive
Actions
During this semiannual reporting
period, our investigative effort
resulted in 16 convictions and
27 indictments Also, this
semiannual period our
investigative work resulted in
over $580,000 in fines and
recoveries
A Connecticut company was
charged with fraudulently
claiming its employees had
completed EPA-certified
asbestos removal training; there
were 7 more indictments of
asbestos removal contractors in
the New York City area; an EPA
subcontractor was found to be
charging almost double the
allowable labor rate and ordered
to repay $23,683 Another EPA
subcontractor pled guilty to
assisting one of its employees .
in illegally obtaining another
vendor's bid proposal that gave
it a competitive advantage
There were more indictments
and convictions of "gray
market" auto importers, a
Georgia man previously
convicted of selling short-weight
bags of grout on an EPA-funded
project has been charged with
defrauding the Navy, a North
Carolina sewage treatment plant
operator was charged with
providing false effluent test
results so that the plant would
appear to meet permit
standards, and there was
another conviction of a New
Haven, Connecticut, police
officer on a charge of
submitting false claims for
police work on an EPA-funded
project (page 23)
Section 4—Fraud
Prevention and
Resource
Management
Review of Proposed
Legislation and Regulations
During this semiannual period,
we reviewed 56 legislative and
regulatory items The most
significant were the Inspector
General Act amendments of
1988, which create more offices
of inspector general, adds new
management reporting
requirements, and modify the IG
reporting requirements to
Congress, the Federal
Employees Liability Reform and
Tort Compensation Act of 1988,
which relieves the personal
financial liability of Federal
employees acting within the
scope of their positions; the
Computer Matching and Privacy
Protection Act, which imposes
new requirements on agencies
desiring to make computer
matches of data, and the
proposed Inspector General
Awards Act, which would set
up a new award program for
non-IG employees who report
on fraud, waste, and
mismanagement (page 29)
Suspension and Debarment
Activities
During this semiannual reporting
period, the number of
debarments, voluntary
exclusions, settlements, and
suspensions to deny or restrict
persons or firms from
participating in EPA programs or
operations has increased We
completed 73 cases during this
reporting period, resulting in 31
debarments, 3 voluntary
exclusions, 17 settlement
agreements, and 22 cases
closed after investigation There
were 280 active cases at the
close of this reporting period
(page 32)
Committee on Integrity and
Management Improvement
The committee is chaired by the
Inspector General Projects
completed by the committee
include an awareness bulletin
which summarizes the
requirements for maintenance
and disposition of official
Agency records CIMI believed
that many EPA employees were
unaware of which records they
could keep and which records
belong to EPA CIMI also
developed two posters to
promote employee interest in
its pamphlet "Ethics in a
Nutshell" (page 35)
Professional and
Organizational Development
The OIG-developed course
Detection and Prevention of
Fraud was presented twice
through the EPA Institute to
Agency employees and in our
Western Audit Division to
members of our staff, auditors
from the California State
Comptroller's office and
independent public accountants
performing audit work for the
OIG. Plans and materials for the
new course. Auditing Superfund
Activities, were finalized in
preparation for the pilot
presentation of the course in
late spring (page 36)
Human Resources Council
The Human Resources Council
sponsored a workshop for all
OIG secretaries in Arlington,
Virginia, in December 1988,
developed a proposal to
enhance the OIG's recruitment
efforts, and completed work on
a booklet which describes the
physical exam, counseling and
fitness services available at
Headquarters and in each EPA
region Because of great
interest, the booklet will be
distributed to all EPA employees
this spring The compressed
work week program, pioneered
in Headquarters by OIG, has
been adopted by most other
EPA Headquarters offices (page
37)
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Profile Of Activities And Results
Environmental Protection Agency
Office of Inspector General
October 1, 1988 to
March 31, 1989
Audit Operations
DIG MANAGED AUDITS
Audits Performed by EPA I PA and State
Questioned Costs
• Total Ineligible $ 30 0 million
• Federal Share Ineligible" $ 24 0 million
• Total Unsupported" S 67 8 million
• Federal Share Unsupported" S 42 3 million
Cost Disallowed to be Recovered
• Federal Share Ineligible S 19 3 million
• Federal Share Unsupported
(costs which EPA management agrees are unallowable and is committed to recover or offset against future payments) $50 million
Cost Disallowed as Cost Efficiency
• Federal Share Ineligible $ 9 million
• Federal Share Unsupported
made available by EPA management's commitment to implement recommendations in OIG performance or preaward audits} $ 8 million
OTHER AUDITS
Audits Performed by another Federal Agency or Single Audit Act Audits Questioned Costs
• Total Ineligible $92 1 million
• Federal Share Ineligible* $ 92 0 million
• Total Unsupported" $301 3 million
• Federal Share Unsupported* $301 3 million
Cost Disallowed to be Recovered
• Federal Share Ineligible $ 4 million
• Federal Share Unsupported $ 1 7 million
Cost Disallowed as Cost Efficiency
• Federal Share Ineligible $ 2 4 million
• Federal Share Unsupported $ 2 million
AGENCY RECOVERIES
Recoveries from Audit Resolutions of Current and Prior Periods
(cash collections
or offsets to future payments)** $163 million
REPORTS ISSUED
OIG MANAGED AUDITS
• EPA Audits Performed by the OIG 34
• EPA Audits Performed by Independent Public Accountants 67
• EPA Audits Performed by State Auditors 12
OTHER AUDITS
• EPA Audits Performed by another Federal Agency 173
• Single Audit Act Audits 507
TOTAL REPORTS ISSUED 793
Audit Reports Resolved
(agreement by Agency officials to take satisfactory corrective action) 953
Investigative Operations
• Fines and Recoveries (including civil) $580 137
• Investigations Opened 136
• Investigations Closed 139
• Indictments of Persons or Firms 27
• Convictions of Persons or Firms 16
• Administrative Actions Taken Against EPA Employees 22
Fraud Detection and Prevention Operations
i Debarments, Suspensions, Voluntary Exclusions, and Settlement Agreements (actions to deny persons or firms from participating in EPA programs or operations because of
misconduct or poor performance)
e Hotline Complaints Received
• Hotline Complaints Processed and Closed
• Proposed Legislative and Regulatory Items Reviewed
• Personnel Security Investigations Adiudicated
'Questioned Cost Ineligible and Unsupported are subject to change pending further review in the audit resolution process
"Information on recoveries from audit resolution is provided from the EPA Financial Management Division and is unaudited
73
46
35
56
229
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 The first
reports pursuant to the Amendments will be submitted to Congress by the inspectors general and agency management on May 30,
1990, based on data from the period October 1, 1989 to March 31, 1990 More information on the new law is contained in Section 4
(page 29)
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The Inspector General Act of
1978 (P L 95-452) 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 objective
audits and investigations,
• Issue subpoenas for
evidence and information,
• Obtain access to any
materials in the Agency,
• Report serious or flagrant
problems to Congress,
• Select and appoint OIG
employees, and
• Enter into contracts
The Inspector General is
appointed by, and can be
removed only by, the President
This independence protects the
OIG from interference by
Agency management and allows
it to function as the Agency's
fiscal and operational watchdog
Organization
and Staffing
The Office of Inspector General
functions through three major
offices, each headed by an
Assistant Inspector General.
Office of Audit, Office of
Investigations, and Office of
Management 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
Staffing Distribution—Fiscal
1989 Ceiling
Office
Inspector General
Audit
Investigations
Management and
Headquarters
5
44
8
23
Field
148
52
Total
5
192
60
23
Purpose And
Requirements Of The
Office Of Inspector
General Semiannual
Report
The Inspector General Act of
1978 (P L 95-452) 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
Source
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
are listed below Also included
are additional requirements
resulting from Senate Report
96-829 on the Supplemental
Appropriations and Rescission
Act of 1980 (PL 96-304)
Section Page
Inspector General Act
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
4
1
1
29
8
8
Section 5(a)(3)
Section 5(a)(4)
Section 5(a)(5),
Section 5(a)(6),
Significant Problems, Abuses, and
Deficiencies
Prior Significant Recommendations 2
on Which Corrective Action Has Not
Been Completed
Matters Referred to Prosecutive 3
Authorities
Summary of Instances Where *
Information Was Refused
21
23
List of Audit Reports
Appendix 40
Senate Report
96-829
Senate Report, Page 11. Resolution of Audits
Senate Report, Page 12, Delinquent Debts
21
39
Technical Assessment
* 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.
Total
80
200
280
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Office of Inspector General — Who's Who
Headquarters
Inspector General
John C. Martin
Deputv Inspector General (Acting)
Anna Hopkins Virbick
Office of Audit
Ernest E Bradley, III
Assistant Inspector General
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
Anna Hopkins Virbick
Assistant Inspector General
Technical Assistance Staff
James 0. Rauch
Director
Technical Assessment and
Fraud Prevention Division
John C. Jones
Director
Planning and Resources
Management Staff
Edward Gekosky
Director
Administrative and
Management Services
Division
Michael J Binder
Director
Divisional Inspectors General
Region 5
Anthony C Carrollo, Audit
Alex Falcon, Investigations
Region 8, 9 & 10
Truman R Beeler, Audit
Michael J Fitzsimmons,
Investigations (Acting)
Region 4, 6 & 7
Mary Boyer, Audit
James F Johnson
Investigations
Region 1 & 2
Paul Mckechnie, Audit
Robert M Byrnes.
Investigations
Region 3
Paul R Gandolfo, Audit
Martin Squitien,
Investigations
Headquarters
Kenneth Hockman,
Internal Audit
Francis C Kiley
Washington Field Office.
Investigations
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A Look at EPA's Mission and the Hazards We Face
When the Environmental
Protection Agency (EPA) was
established in 1970, 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 EPA is
responsible for implementing
the Federal laws designed to
protect the environment
This section concerns EPA's
challenges for restoring and
protecting the quality of the air
we breathe, the land where we
live, and the water we depend
on
LAND—Overview of
the Problem
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 Approxi-
mately 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
• 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
Major Laws Administered by EPA
Statute
Toxic Substances
Control Act
Federal Insecticide,
Fungicide and
Rodenticide Act
Federal Food, Drug
and Cosmetic Act
Resource
Conservation and
Recovery Act
Comprehensive
Environmental
Response,
Compensation and
Liability Act
Clean Air Act
Clean Water Act
Safe Dnnking
Water Act
Marine Protection
Research and
Sanctuaries Act
Asbestos School
Hazard Act
Asbestos Hazard
Emergency
Response Act
Emergency
Planning and
Community
Right-to-Know Act
Provisions
Requires that EPA be notified of any
new chemical prior to its
manufacture and authorizes EPA to
regulate production, use, or disposal
of a chemical.
Authorizes EPA to register all
pesticides and specify the terms and
conditions of their use, and remove
unreasonably hazardous pesticides
from the marketplace.
Authorizes EPA in cooperation with
FDA to establish tolerance levels tor
pesticide residues on food and food
products.
Authorizes EPA to identity hazardous
wastes and regulate their generation,
transportation, treatment, storage, and
disposal.
Requires EPA to designate hazardous
substances that can present
substantial danger and authorizes the
cleanup of sites contaminated with
such substances.
Authorizes EPA to set emission
standards to limit the release of
hazardous air pollutants.
Requires EPA to establish a list of
toxic water pollutants and set
standards.
Requires EPA to set drinking water
standards to protect public health
from hazardous substances.
Regulates ocean dumping of toxic
contaminants.
Authorizes EPA to provide loans and
grants to schools with financial need
for abatement of severe asbestos
hazards.
Requires EPA to establish a
comprehensive regulatory framework
for controlling asbestos hazards in
schools.
Requires states to develop programs
for responding to hazardous chemical
releases and requires industries to
report on the presence and release of
certain hazardous substances.
each is virtually impossible
Leachate resulting from rain
water seeping through
municipal landfills may
contaminate underlying ground
water
• 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 Although
mining wastes are generally
considered to present low
hazards, they present a disposal
problem because of the
estimated 2 34 billion tons
generated per year Runoff from
these wastes increases the
acidity of streams and pollutes
them with toxic metals
AIR—Sources of the
Problem
The Clean Air Act of 1970
requires EPA to set National
Ambient Air Quality Standards
for those pollutants, termed
"criteria pollutant," which posed
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
Both criteria and hazardous air
pollutants come from mobile
and stationary sources
• Mobile sources include
passenger cars, trucks, buses,
motorcycles, boats, and aircraft
• Stationary sources range
from iron and steel plants and
oil refineries to dry cleaners and
gas stations
A major thrust of the next
decade will be to address
growing national and
international problems from acid
deposition and global warming
• Acid ram is now recognized
as a serious long-term air
pollution problem for many
industrial nations The process
of acid ram 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 During a
storm, these compounds fall to
earth as acid ram or snow; the
compounds also may join dust
or other dry airborne particles
and fall as "dry deposition "
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• Certain types of air pollutants
are producing long-term and
perhaps irreversible changes to
the global atmosphere. These
changes seriously threaten
human health and the
environment 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 Without
the greenhouse effect, the earth
would be a frozen planet like
Mars
WATER—Sources of
the Problem
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 consists primarily of
water from toilets and "gray
water" from sinks, showers,
and other uses This
wastewater which runs through
city sewers may be
contaminated by organic
materials, nutrients, sediment,
bacteria, and viruses Toxic
substances used in the
home—including crankcase oil,
paint, household cleaners, and
pesticides—also make their way
into sewers In many towns,
industrial facilities are hooked
into the municipal system and
frequently discharge toxic
New Administrator
Sets L®r»f-Term
Strategies
President George Bush
conducted the swearing-in
ceremony for new EPA
Administrator William K.
Reilly on February 8, 1989, at
EPA's Washington, D.C.
Headquarters. Earlier, at his
Senate confirmation
hearings, Mr. Reitly revealed
his long-term strategies for
EPA:
Enhanced Enforcement and
Better Management
* Invigorate EPA
enforcement efforts
» Speed hazardous waste
cleanup
Pollution Prevention
» Prevent pollution from
occurring in the first place
» Establish strong incentives
for pollution prevention
• Greatly expand recycling
programs
Ecosystem Protection
* No net loss of wetlands
I
William K, Reilty
• Ftght ocean pollution
» Enhance water quality
• Invest in ecological
research
International Leadership
• Revitalize important
environmental treaties
• Foster international
cooperation
• Help developing countries
manage their environments
» Enlarge EPA's international
office
metals and organic chemicals
into the systems Storm water
from downspouts, streets, and
parking lots sometimes enters
the municipal system through
street sewers and may carry
with it residues, toxic
chemicals, and sediments
• Industrial Sources The use of
water in industrial processes,
such as the manufacturing of
steel or chemicals, produces
billions of gallons of wastewater
daily Some industrial pollutants
are similar to those in municipal
sewage but often more
concentrated Others are more
exotic and include a great
variety of heavy metals and
synthetic organic substances
• 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 Primary nonpomt
sources of pollution include
water runoff from farming,
urban areas, mining, forestry,
and construction activities
• 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 When these
sediments are dumped in the
ocean, the contaminants can be
taken up by marine organisms
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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, 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
six areas: Summary of Audit
Activities and Results, Agency
Management, Construction
Grants, Superfund, Special
and Prospective Reviews, and
Other Contracts and Grants.
Summary of
Audit Activities
and Results
Unsupported and Ineligible
Costs by Type of Audit
Construction
Others
Superfund
Non-Federal Ineligible
Federal Ineligible
Non-Federal Unsupported
Federal Unsupported
Distribution of Audit Effort by
Staff Days
Superfund Financial
Compliance
4865 249%
Superfund Performance
3245 16 6%
Distribution of Audit Reports
Issued by Source
State Auditors 12 1 5%_
Performance
3848 197%
EPA
34 4 3%
Independent
Public Accountants
67 8 4%
TOTAL- 19,571 Days
TOTAL REPORTS-793
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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
Aggressive
Enforcement Needed
to Ensure Success of
the New Gray Market
Vehicle Program
Problem
The elimination or reduction
of key controls will further
impair EPA's ability to detect
whether "gray market"
vehicle importers are
appropriately modifying and
testing automobiles to ensure
compliance with U.S.
emission standards.
Background
Foreign vehicles specifically
manufactured for sale overseas
generally do not conform to
U S safety and emission
standards These gray market
vehicles may be imported
providing they are modified to
meet U S standards EPA's
Office of Mobile Sources within
the Office of Air and Radiation
is responsible for ensuring that
these vehicles comply with
emission standards The large
number of criminal prosecutions
by the OIG with other Federal
agencies against gray market
vehicle importers and test
laboratories for false
certifications of these vehicles
(page 25) encouraged our
review of interim changes in the
new program which became
effective on July 1, 1988
We Found That
The new gray market vehicle
program reduces the Agency's
ability to ensure that imported
vehicles meet emission
standards The new program
reduces EPA's oversight,
reduces or eliminates some
major controls, and allows
importers to operate without
prior on-site inspection of their
facilities For example, the new
program eliminates Agency
oversight of emission test
laboratories by making
independent commercial
importers (ICIs) responsible for
importing, modifying, and
testing the vehicles Each ICI
would get permission to operate
through a certificate of
conformity issued by EPA for
each make, model year, and
engine type of vehicle being
imported based solely on the
quality of changes made to a
prototype vehicle Also, the new
program eliminated the
Customs bond previously
required on each imported
vehicle, reduced vehicle
inspection hold periods, and
reduced test data submission
requirements
EPA's Environmental Testing
Laboratory engineers examine
and test the vehicle and review
the Id's test results While
examination of the prototype
vehicle potentially gives the
Agency an idea of the quality of
the Id's modification work, the
new program does not require
Office of Mobile Sources staff
to conduct on-site inspections
of ICI facilities before the
certificate is awarded The
majority of ICI prototypes
submitted for certificates of
conformity were unable to pass
the emission test requirements.
As the program evolved, the
Agency concluded that ICI
interest in the program was less
than expected, with only a few
ICIs being awarded certificates
of conformity Due to limited ICI
interest and our concerns over
certifications without on-site
inspections, the Agency
reconsidered its precertification
inspection policy and conducted
an on-site inspection of the ICI
facility after awarding a
certification of conformity
In addition, the revised
program does not have a formal
penalty policy to encourage
program compliance and ensure
consistent, fair enforcement
We believe criminal activity will
continue under the new
program unless surveillance
over the program participants is
maintained
We Recommended That
The Acting Assistant
Administrator for Air and
Radiation
• Modify the planned
inspection program,
• Develop a formal penalty
policy;
• Request stronger penalty
provisions in the next
reauthonzation of the Clean Air
Act;
• Coordinate enforcement
actions and obtain input from
the OIG and other Federal law
enforcement organizations on
how to limit the extent of
criminal activity in the program,
and
• Coordinate future program
revisions with the OIG Office of
Investigations
What Action Was Taken
The Acting Assistant
Administrator for Air and
Radiation generally agreed with
recommendations in our draft
report, stating that some had
already been implemented The
final audit report (9100148) was
issued January 10, 1989 A
response to the audit report
was received March 22, 1989
The proposed actions, when
implemented, will satisfy our
concerns
Improvements Still
Needed in EPA's
Contract Management
Problem
Despite improving its contract
monitoring process, EPA was
still not effectively
administering contracts
supporting the Office of Solid
Waste (OSW). EPA's failure to
properly manage contracts
resulted in contractors
performing unauthorized and
unfunded work, and Agency
personnel engaging in
potential conflicts of interest.
We Found That
In response to numerous audit
reports, EPA has increased
contract management resources
to improve its management of
contracts and provide assurance
that quality work was received
at a reasonable price and
contractors complied with the
terms of the contracts The
Office of Administration and
Resources Management
requested this audit to help
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identify and resolve problems in
managing OSW support
contracts We identified many
of the same problems as
previously reported
• On 13 of the 43 contract
actions reviewed, OSW
personnel requested contractors
to perform work before a formal
agreement was reached On
four other contract actions,
contractors performed work
before funds were obligated or
work that exceeded the
estimated cost As a result,
contractors incurred an
estimated $532,723 in
unauthorized or unapproved
costs Also, for two other
contracts requested by
management to be reviewed,
the contractors incurred
approximately $400,000 in
unauthorized costs before the
work was ordered by the
contracting officer
• EPA paid $814,682 to
contractors for work completed
before an agreement was
reached on how the work was
to be performed and how much
it should cost Also, contractors
were paid without EPA
adequately reviewing progress
reports and billing invoices
• Half of the 34 OSW
personnel interviewed were
selecting and directing the work
of subcontractors even though
this infringed on the authority
and responsibility of prime
contractors This increases the
potential for and appearance of
possible wrongdoing and
conflicts of interest on the part
of EPA employees
• On seven contract actions,
EPA paid an estimated
$115,216 in general and
administrative costs and fees to
the prime contractors that had
minimal involvement in the
work assignments, added little
value to the work, and could
have been saved by contracting
directly with the subcontractors
or consultants
We Recommended That
The Assistant Administrator for
Administration and Resources
Management and the Acting
Assistant Administrator for Solid
Waste and Emergency
Response
• Expand contract reviews to
ensure that contractors only
perform work that is authorized
and funded Revoke contract
managers' certifications when
work is improperly requested
• Require contractors to submit
detailed information on how
subcontractors are selected
Expand contract reviews to
ensure that EPA personnel are
not improperly involved in
selection and supervision of
subcontractors' work
• Improve procedures for
reviewing contractors' invoices
and monthly status reports
• Emphasize to OSW personnel
proper contracting procedure
What Actions Was Taken
The Assistant Administrators for
Administration and Resources
Management and for Solid
Waste and Emergency
Response took prompt
corrective actions on some of
our recommendations and
agreed to do so on others The
final audit report (9700209) was
issued on March 13, 1989, and
a response is due on June 11,
1989
Management
Improvements
Needed for
Better Compliance
with Hazardous
Waste Law
Problem
Monitoring and enforcement
of Consent Agreement/Final
Orders (CA/FO) under the
Resource Conservation and
Recovery Act (RCRA) were
not timely and adequate to
require hazardous waste
violators' compliance with
RCRA requirements.
Noncompliance provides
economic benefits for the
violators and potentially
exposes the public to
unknown hazards.
Background
EPA's responsibility for
administering and enforcing
RCRA begins by issuing a notice
of violation or warning letter,
without penalty, followed by an
administrative order requiring
compliance and a negotiated
settlement, or a consent
agreement and final order
CA/FOs are tantamount to
contracts, in which EPA forgoes
its right to continue with
enforcement proceedings in
return for the violator's
agreement to comply by
performing specified remedial
actions, CA/FOs may include
the payment of specific
penalties Violators' failure to
take action under the CA/FOs
would allow EPA to take civil
enforcement actions
We Found That
Reviews at three regional
offices disclosed that regional
procedures were ineffective in
assuring that violators complied
with RCRA CA/FO
requirements Of the 29 CA/FOs
reviewed that were executed
during January 1983 through
April 1987 covering a cross
section of the major regulatory
violations, 83 percent of RCRA
enforcement files could not
demonstrate compliance with
the terms and conditions of
CA/FOs As a result of
inadequate regional procedures,
EPA did not detect
noncompliance and
unauthorized time extensions
and modifications to CA/FOs
Violators were allowed time
extensions to comply with
program requirements from
which they could economically
benefit by delaying or avoiding
the cost of compliance In
addition, RCRA goals of
preventing future hazardous
waste sites could be
jeopardized by inadequate and
untimely corrective actions by
violating facilities We attributed
these conditions to regional
managements' failure to:
• Use stipulated penalty
provisions in the executed
CA/FOs;
• Adequately define technical
requirements and establish clear
timeframes for compliance,
• Perform routine followup
inspections;
• Establish tracking systems
and procedures for monitoring
compliance, and
• Maintain post-order
compliance files on RCRA
violators
We Recommended That
The Assistant Administrators for
Solid Waste and Emergency
Response, and Enforcement
and Compliance Monitoring
improve the effectiveness of
EPA's compliance monitoring
program by
• Instituting a more aggressive
oversight program of regional
CA/FO activities,
• Publishing guidance on
regional standards for
monitoring CA/FO provisions
and for maintaining post-order
compliance files; and
• Establishing an effective
automated regional CA/FO
tracking system that can be
uniformly implemented by the
regions to improve compliance
monitoring
10
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What Action Was Taken
The Assistant Administrators for
Solid Waste and Emergency
Response, and Enforcement
and Compliance Monitoring are
issuing guidance on Certification
of Compliance with
Enforcement Agreements and
implementing corrective actions
The Office of Solid Waste and
Emergency Response is
restructuring its regional
reviews to include analyses of
both enforceability of CA/FO
terms and documentation of
compliance oversight A new
RCRA information system, to be
implemented in fiscal 1990, will
correct the data management
deficiencies The final audit
report (9100215) was issued on
March 17, 1989, and a response
is due on June 15, 1989
Slow Processing of
State Plans Adversely
Affects Enforcement
Problem
EPA's slow processing of
State Implementation Plans
(SIP) has adversely affected
enforcement under the Clean
Air Act through significantly
reduced penalties from those
originally proposed and the
Department of Justice's
refusal to pursue some cases.
Background
SIPs are State plans for
attaining and maintaining EPA's
air quality standards under the
Clean Air Act. EPA must
approve or disapprove initial
SIPs, or portions thereof, before
they become federally
enforceable The act requires
EPA to review initial SIPs within
4 months The act also requires
States to petition EPA for
revision to existing SIPs,
especially when compliance
with original SIPs has not
achieved or maintained the
desired ob|ectives, or to
incorporate new regulatory
requirements or standards EPA
currently receives and
processes approximately 350
SIP revisions a year
We Found That
The Office of Air and Radiation
was far exceeding its 14-month
goal for processing SIPs As of
May 31, 1988, SIPs that EPA
planned to disapprove had been
under Headquarters review for
an average of 30 months, while
those under regional review
averaged 28 months Slow SIP
processing resulted in court
decisions unfavorable to the
Agency's air enforcement
efforts Certain courts have
ruled that EPA could not collect
civil penalties until it acted on
the SIP revision This has been
a significant factor, but not the
sole factor, in EPA's decision to
reduce civil penalties from $4
million to $495,000 in the five
cases we reviewed and the
Department of Justice's refusal
to pursue some cases In
addition, these court decisions
have made air enforcement in
certain areas difficult
EPA lacks an accountability
system for meeting SIP review
timeframes One method used
for fiscal 1986 and 1987 to track
the 14-month goal was the
Strategic Planning and
Management System (SPMS)
However, the compliance
tracking sections in SPMS were
removed because it was
deemed ineffective in ensuring
timely SIP processing As a
result, the Agency lost its
formal mechanism for
monitoring and promoting
compliance with its 14-month
goal
Many reforms were either
planned or underway to reduce
SIP processing time, including
the delegation of
decision-making authority to
Regional Administrators for
certain SIP actions, procedures
for determining whether SIP
submittals contain the
necessary information, and
improved oversight of SIP
processing
We Recommended That
The Acting Assistant
Administrator for Air and
Radiation
• Seek support of Congress to
amend the Clean Air Act to
specify a realistic time period for
reviewing initial SIPs and
revisions,
• Evaluate compliance with SIP
processing time goals, and
• Resolve issues adversely
affecting policy development.
What Action Was Taken
We issued a final report
(9100210) to the Acting
Assistant Administrator for Air
and Radiation on March 13,
1989 In the interim, the Office
of Air and Radiation has
established procedures for (1)
determining whether SIP
submittals contain the
necessary information and (2)
processing SIP submittals with
concurrent enforcement action
in a priority manner A response
to the final report is due on
June 11, 1989
Complete Data Not
Available to Evaluate
Compliance and
Enforcement Actions
Problem
Incomplete data and
unreliable software in the
Permit Compliance System
(PCS) prevent EPA from
measuring compliance with
the National Pollutant
Discharge Elimination System
(NPDES) and taking
appropriate actions to control
pollution discharges.
We Found That
EPA controls pollution and
enforces the Clean Water Act
through the NPDES by requiring
emitting sources to have
permits for all discharges into
the nation's waterways PCS
provides the information critical
to the tracking and monitoring
of permits, compliance, and
evaluations of the NPDES
However, the PCS data base
which identifies and measures
environmental quality was
missing a significant amount of
data Of 14 states sampled, an
average 23 percent of the
required permit compliance
measurement data of actual
effluent levels was missing
from the system As a result,
management has no assurance
that actions taken are correct or
appropriate The incomplete
data was the result of user
difficulty in making complex
data entries, insufficient training
of EPA and State users,
inadequate system instructional
or reference materials, and
system unreliability Inadequate
testing and evaluation of
software contributed to the
system's unreliability
We Recommended That
The Acting Administrator for
Water develop a specific plan to
resolve all major software
reliability problems, improve
data entry, and provide users
with complete, well organized
documentation
What Action Was Taken
The Acting Assistant
Administrator for Water plans to
make the system "user
friendly" for retrieval and make
system documentation available
to the user community The
final audit report (9100192) was
issued on February 15, 1989
The Office of Water's response
is due on May 12, 1989
11
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Different Monitors
Can Lead EPA to
Different Conclusions
About Air Quality
Problem
EPA's policy of accepting air
monitor measurements
without regard to the type of
monitor used can result in
inconsistent conclusions of
whether air quality standards
have been met.
Background
The Clean Air Act requires EPA
to identify and set standards for
airborne pollutants and to
establish a nationwide air
monitoring system The act
assigns the State and local
agencies responsibility for
identifying and controlling air
pollution To implement the act,
EPA established National
Ambient Air Quality Standards
for six pollutants, including small
particulates called PM10 (a
broad class of chemically and
physically diverse substances 10
micrometers or less in
diameter) Various types of
monitors produced by two
manufacturers have been used
to measure PM10, but can
result in different readings
We Found That
• Opposite attainment
decisions could be made, for
identical PM10 concentrations
near the standard, solely
because of the type of monitors
used One of the two
EPA-approved monitors may
give consistently higher
measurements than the other
For example, we identified 27
areas with PM10 readings
slightly above the standard
which indicated that the areas
were potentially
out-of-attamment and may
require controls to limit PM10
pollutants However, had these
areas used the other
manufacturer's monitor, it is
possible that some of these
measurements would have
been below the standard and no
corrective action would be
required
• EPA may have difficulties
enforcing attainment decisions
and should anticipate being
challenged on the validity of
data from the monitors When
measurements are near the
standard, EPA's practice of
accepting all monitor
measurements at face value
without regard to the type of
monitor does not provide an
authoritative basis to determine
whether attainment has or has
not been achieved Also,
regulations allowing new
monitor types to be approved
for use in measuring PM10
concentrations, if they provide
measurements within 10
percent of certain monitor
types, will widen the
differences between PM10
measurements
• EPA may delay attainment
decisions because it will only
use data from nonapproved
monitors to supplement and
corroborate data from approved
monitors. EPA should use data
from nonapproved monitors, if
necessary, to make attainment
decisions when monitor data is
far above or below the
standards
We Recommended That
The Acting Assistant
Administrator for Air and
Radiation allow for flexibility in
interpreting measurements near
the PM10 standard and consider
additional uses for data from
nonapproved monitors in
making attainment decisions
What Action Was Taken
The audit report (9100227) was
issued to the Acting Assistant
Administrator for Air and
Radiation on March 37, 7989 A
response is due by June 29,
1989
12
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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 the
first half of fiscal 1989, a total of
$426 million was obligated on
55 new awards and 228
increases to existing grants At
the end of this period, there
were a total of 1,744 active
construction grants representing
$11 2 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 m the
Clean Water Act, which
addresses the process of
phasing out the construction
grants program by providing
incentives for development of
alternative funding mechanisms
by the States The new title VI
charges EPA to develop and
implement a program to provide
grants to capitalize State
revolving funds for financing
wastewater projects
At midyear, a total of $327
million was awarded on nine
new capitalization grants and
five continuation grants EPA
awarded the nine new
capitalization grants to New
Jersey, Nebraska, South
Carolina, Alaska, Arkansas,
South Dakota, Kentucky,
Oklahoma, and North Carolina
As of the end of this
semiannual period, EPA has
obligated a total of $577 million
to 17 States under the revolving
fund program
13
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Noncompliance with
Speciaj Grant
Condition Requires
Grantee to Repay
over $9 Million
.Sacramento Regional CSD, CA
Millions of Dollars
Non-Federal |
Problem
The Sacramento Regional
County Sanitation District,
California, did not adhere to a
special grant provision
prohibiting new sewer
connections, requiring the
grantee to repay costs
claimed plus interest totaling
over $9 million.
We Found That
The grantee violated the grant's
special condition The violation
occurred when it allowed the
Sacramento Sports Association
to construct the new Arco
Arena within the prohibited
North Natomas area The new
arena, which served as the
home court for the Sacramento
Kings professional basketball
team, was connected to the
Natomas interceptor system
The connection violated the
prohibition of new connections
to the interceptor system As a
result, the grantee must
reimburse EPA and the State all
project costs and accrued
interest As of September 1988,
this amounts to $9,046,579
We Recommended That
The Regional Administrator,
Region 9 recover the full
Federal share of costs paid the
grantee along with accrued
interest.
What Action Was Taken
The audit report (9300035) was
issued to the Regional
Administrator on March 31,
1989. A response to the audit
report is due on June 29, 1989.
ARCO Arena, Sacramento, CA
(Photo by DIG Staff)
Ineligible and
Unsupported Costs
of $5,648,219 on
Nassau County,
New York, Project
Millions of Dollars
Problem
The county of Nassau, New
York, claimed $1,773,999 of
ineligible construction costs,
administrative expenses,
engineering fees, and force
account costs. An additional
$3,874,220 of unapproved
costs were questioned.
We Found That
EPA awarded four grants
totaling $77,416,587 to Nassau
County, New York, for the
construction of an advanced
wastewater treatment works
and modifications We
questioned $1,773,999 of costs
claimed by the grantee,
including
• $1,272,861 of construction
costs and architectural
engineering fees claimed in
excess of eligible costs,
• $431,117 of project
inspection fees, administrative
expenses for accounting
services which were disallowed
by the New York State
Department of Environmental
Conservation, engineering fees,
and force account costs
incurred after the project cutoff
date, and
• $68,865 of ineligible project
inspection fees associated with
easement drawings, and
construction completion and
cleanup
In addition, we questioned
$3,874,220 of unsupported
construction costs,
administrative expenses, and
project inspection fees pending
submission of adequate
supporting documentation, or
pending review and approval of
the force account
We Recommended That
The Acting Regional
Administrator, Region 2, not
participate in the Federal share
of the ineligible costs
($1,330,499) and determine
whether EPA should participate
in the Federal share of
unsupported costs ($2,905,665)
What Action Was Taken
The audit report (9100119) was
issued to the Acting Regional
Administrator, Region 2, on
December 21, 1988 A response
to the audit report, due on
March 21, 1989, had not been
received as of April 25, 1989
Grantee Claims over
$2.9 Million
of Ineligible or
Unsupported Costs
Town of Amherst, NY
Millions of Dollars
^^^^1 Federal Non-Federal [
Problem
The town of Amherst, New
York, claimed over $1 million
for ineligible work, services,
and expenses such as
development and
construction of a recreation
area and bond issuance costs
of the municipality. An
additional $1.9 million of
unsupported costs were
questioned.
We Found That
EPA awarded two grants
totaling $38,628,707 to the
14
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town of Amherst, New York, for
the construction of sanitary and
interceptor sewers, a lift and
pump station, and additions and
alterations to treatment
facilities We questioned
$1,052,341 of the final costs
claimed as ineligible, including
• $698,150 of architectural
engineering fees allocable to
another grant, costs claimed in
excess of contract ceilings, and
services outside the scope of
the grant,
• $236,790 of administrative
and miscellaneous expenses
previously disallowed by the
New York State Department of
Environmental Conservation,
costs in excess of those
acceptable for local government
including issuance and sale of
bonds, and expenses outside of
the scope of the project
(primarily for the construction of
a recreation area), and
• $117,401 for construction
change orders and property
damages unallowable under
EPA regulations or in excess of
eligible contract costs
Also, we questioned $1,904,074
of unsupported cost claims
pending EPA's evaluation of
their eligibility associated with
architectural engineering fees,
preliminary and miscellaneous
costs not included in the grant
budget, and administrative costs
lacking adequate documentation
We Recommended That
The Acting Regional
Administrator, Region 2, not
participate in the Federal share
of ineligible costs ($789,255),
determine the eligibility of the
Federal share of unsupported
costs ($1,428,056), and recover
the applicable amount from the
grantee
What Action Was Taken
The audit report (9100118) was
issued to the Acting Regional
Administrator, Region 2, on
December 21, 1988 A response
to the audit report, due on
March 21, 1989, had not been
received as of April 25, 1989
Improper Contracting
Procedures Increase
Florida Grantee's
Costs by over $1.5
Million
Questioned Costs
|0 5 10 15 20 25 30 35 40
Millions of Dollars
^^H Federal Non-Federal I I
Problem
Ft. Myers, Florida, incurred an
additional $1.5 million due to
a failure to take the lowest
bid on a construction
contract, improper
computation for innovative
funding, duplicative and
excessive administrative
costs, and contracting for
engineering services at three
to four times the average
rate.
We Found That
Ft Myers required prospective
construction contractors to
submit separate bids for a
wastewater treatment plant and
support facilities Instead of
accepting the lowest
combination of bids, the grantee
accepted the lowest base bid
for the plant but also improperly
awarded the same contractor a
change order for the support
facilities even though four other
contractors submitted lower
bids This was in violation of
procurement requirements and
resulted in unnecessary costs of
$775,800 The grantee also
negotiated contracts with its
consulting engineering firm for
operation and maintenance
manuals and startup services
that were three to four times
higher than the average costs
for a comparable size plant,
$587,000 of the contracted
amount was questioned as
unsupported The grantee
claimed that EPA had approved
these costs to support an
innovative project
The grantee could not support
$45,000 of administrative
expenses and claimed ineligible
duplicative costs of $80,000 for
grant accounting and
construction monitoring
We Recommended That
The Regional Administrator,
Region 4, recover the Federal
share of the questioned costs
($1,283,461) and review the
unsupported costs ($276,789) to
determine their eligibility for
grant participation
What Action Was Taken
The audit report (9100134) was
issued to the Chief, Facilities
Construction Branch, on
December 29, 1988 A response
to the audit report, due on
March 29, 1989, was received
on April 26, 1989 and is under
evaluation
Grantee Claims
$2,489,055
of Unsupported or
Ineligible Costs
Pima County, AZ
Audited Costs
fQuestioned Costs
0 10 20
Millions of Dollars
^|^H Federal Non-Federal I I
Problem
The Pima County Wastewater
Management Department,
Tucson, Arizona, claimed
$1,768,752 of ineligible
inspection fees, architectural
engineering fees, construction
costs, and administrative
expenses. An additional
$720,303 of unsupported
costs were questioned.
We Found That
EPA participated in grants
totaling $63 5 million to assist
the Pima County Wastewater
Management Department plan,
design, modify, and construct
its wastewater treatment
systems We questioned
$1,768,752 of the grantee's final
claim as ineligible for Federal
grant participation, including
• $474,195 of project
inspection fees incurred after
the approved construction
contract completion cutoff dates
and use of the prohibited
method for calculating
engineering costs,
• $457,205 of architectural
engineering fees that were not
properly or adequately
supported, exceeded allowable
limits, costs incurred outside
the scope of the approved
project, and unallowable plant
startup costs,
• $427,777 of construction and
project improvement for change
orders not approved by EPA and
construction work ineligible for
reimbursement, and
• $409,575 of administrative
expenses that were not
adequately supported, force
account and indirect costs not
approved by EPA or in excess
of the grant amount
We also questioned $720,303 of
subagreement engineering bills
not segregating costs between
categories such as direct labor,
indirect cost, and profit as
required, pending the grantee
submitting supporting
documentation
We Recommended That
The Regional Administrator,
Region 9
• Disallow the $1,768,752 of
costs questioned in the audit
reports, and recoup the
$1,327,808 Federal share
previously paid to the grantee,
and
• Assess the eligibility of the
$720,303 of unsupported costs
What Action Was Taken
Three reports (9300013,
9300014, and 9300027) were
issued to the Regional
Administrator, Region 9, on
December 13, and 20, 1988,
and March 9, 1989 A response
to the audit reports is due
within 90 days (March 13,
March 20, and June 7, 1989)
As of April 25, 1989 we had not
received responses to the
reports
15
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Super-fund
Program
The Superfund program was
created by the Comprehensive
Environmental Response,
Compensation, and Liability Act
of 1980 (CERCLA) The act
provided a $1 6 billion trust fund
for removal and remedial
actions, liability, compensation,
cleanup, and emergency
response for hazardous
substances released into the
environment and uncontrolled
and abandoned waste sites
Taxing authority for the trust
fund expired on September 30,
1985 For more than a year, the
Superfund program operated at
a reduced level from carryover
funds and temporary funds
provided by Congress
On October 17, 1986, the
Superfund Amendments and
Reauthorization Act of 1986
(SARA) was enacted It provides
$8.5 billion to continue the
program for 5 more years and
makes many programmatic
changes
The parties responsible for
the hazardous substances are
liable for cleaning up the site
themselves or reimbursing the
Government for doing so
States in which there is a
release of hazardous materials
are required to pay 10 percent
of the costs of fund-financed
remedial actions, or 50 percent
if the source of the hazard was
operated by the State or local
government
The enactment of SARA has
increased the audit
requirements for the Inspector
General In addition to providing
a much larger and more
complex program for which the
OIG needs to provide audit
coverage, SARA gave the IG a
number of specific
responsibilities Mandatory
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 IG
deems appropriate The first
annual report, covering fiscal
1987, was issued in September
1988.
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 the
act 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 signed by the Acting
Assistant Administrator for Solid
Waste and Emergency
Response on April 6, 1989 The
OIG review of the report was
a/so issued on April Q, 1989
The Administrator had not
signed the report as of April 21,
1989 and transmitted it to the
Congress The report for fiscal
1988, and the IG review of it,
are still in preparation
16
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Better Health and
Safety Programs
Needed in Region 2
Problem
Properly functioning health
and safety programs were
needed to protect EPA
employees from exposure to
moderate- and high-risks from
hazardous waste operations.
Background
The Superfund Amendments
and Reauthonzation Act required
the establishment of a standard
for the health and safety of
employees engaged in
hazardous waste operations
Also, EPA is required to
promulgate standards identical
to those issued by the
Occupational Safety and Health
Administration (OSHA) As of
December 1988, the final
standards had not been finalized
by OSHA However, under
provisions of the
Comprehensive Environmental
Response, Compensation, and
Liability Act, EPA has
established a program to protect
the health and safety of
employees responding to
hazardous substance releases,
removals, or remedial actions
We Found That
Although Region 2 has
improved the organization and
administration of the health and
safety programs, scheduled
medical examinations, provided
training, and purchased
equipment, additional actions
were warranted to improve the
programs' effectiveness
Specifically, we found that
Region 2
• Did not have safety personnel
with adequate management or
field experience to provide the
technical guidance that
Superfund and Resource
Conservation and Recovery Act
(RCRA) field personnel needed
in hazardous waste operations
and emergency response
activities Instead, the Region
relied on the assistance of other
employees and outside
contractors to provide field
expertise
• Was permitting field personnel
to work at Superfund and RCRA
sites without receiving required
medical monitoring
examinations before their
assignment or termination from
the Agency The medical
monitoring program serves as a
basis to ensure fitness for duty,
detect adverse effects of
occupational exposure, and
initiate prompt corrective action
• Did not establish a respiratory
protection program for its
employees although Agency
regulations required such a
program As a result, the Region
has limited assurances that
personnel have been properly
trained in safety procedures and
have adequate, well-maintained
equipment
We Recommended That
The Acting Regional
Administrator, Region 2
• Consider supplementing the
Region's health and safety staff
with a full-time health and
safety specialist having
sufficient expertise in moderate-
and high-risk work areas,
• Establish and implement a
policy to perform termination
examinations in accordance with
OSHA regulations; and
• Establish a formal regional
respiratory protection program
What Action Was Taken
The audit report (9100213) was
issued to the Acting Regional
Administrator, Region 2, on
March 15, 7989 A response is
due on June 13, 1989
Documentation Still
Not Available to
Support $5,140,503 of
Love Canal Superfund
Costs
Millions of Dollars
Problem
Inadequate documentation of
the New York State
Department of Environmental
Conservation's (DEC) final
credit claim for the Love
Canal hazardous waste
cleanup resulted in over $3.3
million of ineligible costs, and
$1.8 million of unsupported
costs.
Background
Between 1942 and 1953,
21,800 tons of chemical wastes
from the Hooker Chemical
plants were deposited in the
16-acre Love Canal landfill
located in the southeast end of
the city of Niagara Falls During
the 1950's, homes were built
adjacent to the site and a public
school was built on the
property As a result of leaking
hazardous waste chemicals
from the Love Canal landfill, the
United States undertook a major
Federal emergency cleanup to
save lives and protect property
A second Federal emergency
was declared to purchase
homes, relocate more than 700
families who still lived near the
toxic waste dump, and perform
remedial construction of the
Love Canal area
We Found That
DEC claimed $17,619,773 for
credit under the Comprehensive
Environmental Response,
Compensation and Liability Act
of 1980 (CERCLA) for
non-Federal funds expended at
Love Canal between January 1,
1978, and December 11, 1980
This credit is used toward
offsetting the State's cost share
requirement We questioned
$5,140,503 of the net costs
reimbursed by other Federal
agencies and costs incurred
after the December 11, 1980,
cutoff date due to a lack of
adequate documentation
supporting the reasonableness
and acceptability of costs
claimed for property
acquisitions, relocations,
administrative and personal
service costs, payroll, fringe
benefits, supplies, and
equipment Since our March
1983 audit report of the State's
initial claim, DEC has had ample
opportunity to provide the
necessary documentation to
support the expenditures
claimed
We Recommended That
The Acting Regional
Administrator, Region 2, not
allow credit under CERCLA for
the $5,140,503 of questioned
costs
What Action Was Taken
The audit report (9100221) was
issued to the Acting Regional
Administrator, Region 2, on
March 23, 1989 A response to
the audit report is due on June
21, 1989
17
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Special And
Prospective
Reviews
This is a new section in our
semiannual report describing
significant and potential
findings, deficiencies, and
recommendations which have
been identified through
evaluations, analyses, projects
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
Scientists Critical of
EPA's Monitoring of
Ocean Dumping
Problem
Members of the scientific
community disagree with the
adequacy of EPA's monitoring
at the 106-Mile Deepwater
Municipal Sludge Dump
(DMSD) site.
We Found That
EPA established the 106-Mile
DMSD site in May 1984 EPA is
required to conduct a program
of research and monitoring of
the effects of dumping on the
ocean environment Since
municipal sludge was first
dumped at DMSD in March
1986, over 8 million wet tons of
sewage sludge containing toxic
materials that pose a potential
danger to human and marine
health are being dumped every
year
Scientists from EPA and other
organizations disagree about the
adequacy of EPA's monitoring
program at the 106 Mile DMSD
site Scientists are concerned
whether' (1) monitoring should
have been accelerated, (2)
current actions should have
been taken years ago; and (3)
much of the data gathering is
duplicative and unnecessary;
and why the Agency has not
begun to look at the cumulative
effects of the dumping after
two years and spending $2
million Also, the fishing industry
in New York and New England
has claimed that sludge
dumping is harming their catch
Although EPA has begun
collecting data on individual
dumping events it will not begin
to study the cumulative effects
of sludge dumping until 1990
EPA has not acted
expeditiously to reduce sludge
dumping to prevent toxicity
levels from violating established
limits. EPA's survey cruises
proved toxicity thresholds were
being exceeded which would
require the dumping rate to be
slowed The new rates are to
be incorporated in dumping
permits beginning on August
15, 1989 The two year delay in
setting new sludge dumping
rates was avoidable because,
instead of relying on field data,
EPA could have used an
allowable method of calculating
discharge rates Additionally,
EPA has not developed
contingency plans for dealing
with possible emergencies if
sludge dumping proves to
threaten human health or the
marine environment The
Agency has not encouraged the
sharing of scientific data
gathered at the DMSD site with
other interested agencies or
scientific groups
We Recommended That
• The Agency establish an
independent panel of scientific
experts to prioritize monitoring
needs and recommend
allocation of resources
• Discharge rates be reduced
so that toxicity thresholds are
not exceeded
• Contingency plans be
developed for situations where
sludge dumping endangers
human health or the ocean
environment
• Development of a program
for exchanging scientific data on
sludge dumping research
• Manpower resources be
augmented, where necessary
to better manage and
coordinate site monitoring
activities
What Action Was Taken
The Ocean Dumping Special
Review report (9400024) was
issued to the Acting Assistant
Administrator for Water and to
the Acting Regional
Administrator, Region 2, on
March 31, 7989 A response to
the report is due on June 29,
1989.
O S V. Peter W Anderson
(Photo by Steve Delaney)
18
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Construction Grant
Early Warning System
7?7/s 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
construction grants program is
to reduce the discharge of
municipal wastewater pollutants
to improve water quality and
protect public health EPA
provides grants to municipal
agencies to assist in financing
the construction of wastewater
treatment works, which takes 2
to 10 years
Because audits are generally
performed after the project is
complete, problems which
affect the efficient design,
construction, management, or
operation of a treatment plant
are not disclosed until
thousands or millions of dollars
are spent The OIG early
warning system reviews
projects before construction
begins to identify problems and
preclude the ineffective
expenditure of funds Our
reviews focus on certain
indicators and attributes that
can suggest the likelihood of a
potential problem
$3.7 Million in Grant
Funds to
California Grantee
Should Not Have
Been Awarded
Questioned Costs
0 5 10
Millions of Dollars
^^HH Federal Non-Federal I I
Problem
Erroneous calculations of
community population by the
California State Water
Resources Control Board
(SWRCB) allowed a sewer
collection project to proceed
that will greatly benefit
developmental interests.
We Found That
EPA participated in an
$11,162,497 construction grant
to the Eastern Municipal Water
District for a collection system,
pump station, interceptor, and
treatment plant expansion in the
communities of Homeland and
Green Acres in Riverside
County, California The Federal
share of the collection system
portion is estimated at over $3 7
million
We determined that the
grantee did not meet the EPA
requirement that two-thirds of
the flows within the
Homeland-Green Acres service
area be from the portion of the
community in existence on
October 18, 1972 We
calculated that these existing
dwellings would require less
than half of the flow capacity in
the system and as a result the
collection system portion of the
grant is ineligible The project
would greatly benefit
development interests By the
grantee's own calculations, the
immediate buildout on the
collection system would serve
more than a threefold increase
over existing needs
The SWRCB erroneously
calculated the population
percentage numerous times,
with the results ranging
between 61 6 and 62 6 percent
Although the SWRCB's
calculations resulted in less than
the two-thirds requirement
being met, both SWRCB and
Region 9 allowed the grant to
be awarded since they
considered a percentage in
excess of 60 percent as
generally satisfying the
requirement of the regulation
The "California Rule,"
proposed by the SWRCB m
response to our flash report,
uses a different basis for
calculating the population
served by a proposed project
The SWRCB claims that using
this rule would make the
Homeland-Green Acres project
eligible We believe that this
alternative method allows for
funding of at least portions of
practically any new collection
system, even if the main
beneficiaries are developmental
interests
We Recommended That
The Regional Administrator,
Region 9'
• Obtain written concurrence
from the EPA Headquarters
General Counsel, Office of
Administration, Grants
Administration Division, and
Office of Municipal Pollution
Control, Municipal Construction
Division, that the "California
Rule" meets the intent of EPA
regulations or whether a
deviation from the grant
regulations is required; and
• Advise the grantee that the
collection system portion of the
grant is ineligible for grant
funding unless a grant deviation
to the regulations is obtained
from EPA's Grants
Administration Division
What Action Was Taken
A construction grant early
warning flash report was issued
to the Regional Administrator,
Region 9, on February 7, 1989,
to alert EPA management of the
grantee's meligibility for the
collection system portion of the
project and provide the grantee
an opportunity to minimize the
ineligible costs incurred Our
early warning review report
(9400025) was issued on March
31, 1989. A response to the
early warning review report is
due May 2, 1989
Grantee Lacks
Managerial and
Financial Capability to
Build a Needed $2.4
Million Wastewater
Treatment Facility
Millions of Dollars
Problem
The Weott Community
Services District, Weott,
California, plans to build a
$2.4 million wastewater
treatment facility although it
lacks the managerial and
financial capabilities required
for effective accomplishment
of its EPA grant project.
We Found That
To alleviate a potentially severe
surface water contamination
problem from failing septic
tanks, EPA and the California
State Water Resources Control
Board (SWRCB) awarded a
grant and a State loan to the
Weott Community Services
District for the planning, design,
and construction of a
wastewater treatment facility
However, the Weott
Community Services District
lacks the necessary managerial
capabilities, accounting and
procurement systems, and
financial resources needed to
competently undertake and
manage the $2 4 million project
in accordance with EPA
regulations
The grantee does not have an
adequate staff or other
capabilities necessary to provide
effective day-to-day project
management The District relies
on its consulting engineering
firm's project engineer for all
project management functions
The project engineer has already
performed several actions on
the grantee's behalf which may
have resulted in a
conflict-of-interest situation For
example, during the process of
procuring engineering services,
the engineer assisted the
grantee in evaluating various
proposals including his own
firm's proposal, his own firm
was selected to provide
engineering services Since the
grantee has authorized the
project engineer to continue to
oversee all project activities, the
need for an independent project
manager becomes all the more
evident and critical The district
was previously advised in an
SWRCB evaluation performed
over a year earlier that it needed
to obtain the services of a
qualified, independent manager
However, our review pointed
Non-Federal L
19
-------
out that the delegated State
agency's suggestions for
improving the district's overall
management capabilities were
not implemented during the
intervening 16 month period
Further, the grantee's
accounting records were
inadequate and did not comply
with grant requirements Vendor
invoices and other individual
cost items were not always
recorded, nor did the grantee's
records adequately identify the
source and application of all
monies received and expended
This lack of proper accounting
was due, in part, to the
grantee's reliance on the project
engineer to maintain the
records
The grantee may have a
problem financing its share of
the project While the project is
100-percent funded by a
combination of EPA and State
grant funds and a State loan,
the district did not have any
additional funds available to
cover any subsequent
determination that some project
costs may be ineligible for grant
participation Also, under State
policy, some funds must be
withheld until an audit of the
project has been completed
Therefore, any significant
combination of ineligible costs
or withholding of payments
could cause the grantee to
experience cash flow problems
We Recommended That
The Regional Administrator,
Region 9 suspend grant
payments until the District has
complied with EPA regulations
by obtaining an independent,
qualified project manager to
perform day-to-day management
functions, implementing an
adequate accounting system to
meet grant requirements,
establishing an adequate
procurement system, and
demonstrating the ability to
finance any unallowable costs
and all of the costs incurred
until State and EPA
reimbursements are received
What Action Was Taken
The construction grant early
warning review report (9400018)
was issued on March 16, 1989
A response is due on May 19,
1989.
Other Grants
and Contracts
These are independent reviews
of the records and performance
of individual grantees and
contractors made in accordance
with the U S General
Accounting Office standards for
audits of governmental
organizations, programs,
activities, and functions These
audits are conducted to
determine the accuracy of
financial statements and the
degree of compliance with
statutes, regulations, and terms
of agreements under which
Federal funds are made
available
Accuracy of
Contractor's Claimed
Costs in Question
PEI Associates
Questioned Costs
0246
Millions of Dollars
^^^^| Federal Non-Federal I I
Problem
Significant internal control
weaknesses in an EPA
contractor's financial
management system cast
doubts on the accuracy of $23
million of claims.
Background
The contractor, PEI Associates,
Inc , was awarded contracts to
provide environmental
management, technical and
scientific services in the areas
of solid/hazardous waste
management, energy and
environmental engineering,
environmental analysis/control
of toxic substances, and
laboratory services
We Found That
Poor and improper accounting
prevented us from attesting to
the accuracy of claims by the
contractor under EPA contracts
during 1982 to 1984 We
questioned $19,685,062
pending a determination of the
allowability of these costs The
contractor did not properly use
its payroll and purchasing
systems to bill costs under EPA
contracts, and costs that were
billed did not reconcile to the
contractor's accounting records
because the contractor made
unsubstantiated revisions to
timesheets after they had been
entered into the accounting
system, delayed billing labor
hours for several months,
commingled labor charges from
prior months with current
billings; and billed hours for
selected employees at rates
less than the employee's actual
pay rates. In addition, we also
questioned $1,983,082 as
ineligible claims, including
• $1,079,008 of indirect costs
such as fringe benefits,
overhead, and general
administration in excess of the
allowable amounts,
• $698,534 billed in excess of
the costs as recorded or
incurred in the contractor's
books of account;
• $126,779 of labor, other
direct, and related indirect costs
incurred before the effective
date of the contract; and
• $78,761 of profit billed to
EPA work by a subcontractor
that was a wholly owned
subsidiary of PEI, related
subcontract administrative
costs, costs billed in excess of
work assignment ceilings, and
excessive fees
In addition, $1,752,001 of
unsupported costs were
questioned primarily consisting
of $1,539,109 of indirect costs
for fringe benefits, overhead,
and general and administrative
expenses claimed in excess of
the audited indirect rate that
was not deemed reasonable or
allocable to the contracts, and
$105,293 of purchases made
without written agreements
We Recommended That
The Contract Management
Division, Research Triangle Park,
recover the questioned costs of
$1,983,082; obtain
documentation supporting costs
of $1,752,001, determine the
allowability of $19,685,062
questioned; and require the
contractor to revise its current
accounting policies and
practices so that all contract
costs claimed and billed to
Federal contracts conform to
the terms of the contracts and
Federal regulations
What Action Was Taken
The audit reports (9100045,
9100071, and 9100077) were
issued to the contracting officer
on November 1, November 21,
and December 2, 1988
Because of the complexities
identified in the reports, we
extended the response date to
May 31, 1989
20
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Section 2—Audit Resolution
As required by the Inspector
General Act, this section
describes significant problems
identified in previous
semiannual reports which
remain unresolved. Also, as
required by the Supplemental
Appropriations and Rescission
Acts of 1980 and 1981, this
section includes a summary
of unresolved audit reports
and a list of officials
responsible for resolving audit
findings over 6 months old.
Overdue Audit
Resolution
EPA management and the
Office of the Inspector General
report overdue audit resolutions,
as of March 31, 1989, at 38, an
increase from the 29 reported at
September 30, 1988 During the
first half of fiscal 1989, the
Office of Inspector General
closed 953 audits and issued
793 new audit reports There
are 365 audits remaining in the
Agency followup system for
resolution during the second six
months of fiscal 1989
Of the audits closed, $308
million of questioned costs
were sustained including $26 5
million to be recovered and $4 3
million in cost efficiencies In
addition, cost recoveries in
current and prior periods
included $2 1 million in cash
collections and at least $142
million in offsets against billings
During the past year, EPA
formed a task force to develop
quality training materials and an
approach to help all managers
improve their management skills
and the performance of their
programs This effort was called
"Strengthening the Audit
Management Ability of EPA
Managers "
The task force produced
several products which should
strengthen managers'
understanding of the importance
of audits, enhance their ability
to respond to audits, work with
auditors, and resolve audits
promptly and properly. Three of
these products are
- An Audit Handbook for EPA
Managers This is a "how to"
manual for all those who are
involved in audits and the audit
process
- A Model Audit Management
System that highlights
organization and staffing for
audit resolution, communication
channels among offices, and
tracking corrective action
- A Videotaped Training
Package to educate both
appointed and career managers
about their roles and
responsibilities regarding audits
and their resolution
The task force is now ready
to tram the EPA Audit Follow-up
Coordinators (AFCs) from its
Headquarters and Regional
Offices on how to use the
process as a positive
management tool and to
prepare them to tram their
staffs. A two day training
session is currently being
scheduled for May The AFCs
will receive a copy of the
training videotape and sufficient
copies of the audit handbook
and model for distribution to
their program managers
EPA is currently developing
an audit resolution and
corrective action tracking
system and are consulting the
IG to ensure that their system
will meet the requirements of
the Inspector General Act
Amendments of 1988
-------
Previously Reported
Items—Corrective
Actions Not Taken
The Inspector General Act
requires that each semiannual
report identify unresolved audits
Audit Grantee/Contractor
Number
discussed in previous reports
Two hundred and three reports
were discussed in all previous
reports, 197 have been
resolved. The six audit reports
listed below had not been
resolved as of March 31, 1989
Issue Date
Status*
7100358 Ahso Water Mgmt Agency. CA 06/16/87
8100927 Program Review R-4 Removal Sites 09/26/88
8100958 Maui County, HI
8100966 NUS Field Investigations
8100468 Miami-Dade, FL
09/29/88
09/30/88
07/02/88
8100761 Moses Lake, WA
08/31/88
No Response
In Headquarters
OIG/Program
Office for Final
Resolution
No Response
Incomplete
Response— In
Process of
Resolving
IG In Agreement
With 10/25/88
Proposed Final
Determination
Letter-
Awaiting Final
Determination
Letter to Close
Out
In Headquarters
OIG/Program
Office for Final
Resolution
Action Officials for Audit Reports Outstanding More
Than Six Months as of March 31, !989
Action Official
EPA Aministration
Assistant Administrator for
Solid Waste and Emergency Response
EPA CONTRACTS
Director, Piocurement and
Contracts Management Division
EPA Grants Programs
Director, Grants Administration Division
Regional Administrator, Region 1
Regional Administrator, Region 4
Regional Administrator, Region 5
Regional Administrator, Region 9
Regional Administrator, Region 10
3
1
5
18
1
1
13
Total
38
17
17
•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
"Awaiting an acceptable final determination letter The final determination
letter submitted on March 30. 1989 significantly differed from the proposed
final detemination letter with which we were in agreement
'Incomplete audit responses open 90 days or more past report date wil
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
be
Resolution of Significant Audits from Prior Periods
Audit
Report Date
05/06/81 *]
1 2/28/87
04/07/88
06/20/88
06/02/87 *2
06/02/87 *2
01/29/88
09/1 3/88
09/04/84*3
06/07/88
09/08/88
09/26/88
08/30/88
Federal Share Questioned
Number
E2GWO-02-0092-
1000937
P2CW*6-02-0166-
8000382
P2CW5-02-0224
8000880
P2CWV-02-0017-
8100329
P2BW*4-03-0349-
7100265
P2BWM-03-0348-
7100266
P2 CW* 6-03-00 17-
8000535
N3GM*8-03-0322-
8100848
P2BW*3-04-0265-
4100499
P2CWP7-05-0046-
890001 1
S2CW6-09-0142-
8100828
S2CW6-09-0207-
8100931
P2CWV-1 0-0042-
8100748
Grantee
WEST WINDSOR, NJ
WESTERN MONMOUTH,
UA, NJ
READINGTON, NJ
JEFFERSONVILLE, NY
UPPER OCCOQUAN, VA
UPPER OCCOQUAN, VA
RICHMOND CITY, VA
PHILADELPHIA, PA
LEE COUNTY, FL
NEORSD CLEVELAND, OH
KINGS COUNTY, CA
CSD - ORANGE CO, CA
TWIN FALLS, ID
Ineligible
$ 493,050
549,615
352,029
577,122
349,861
822,518
438,664
1,012,595
1,105,756
69,215
16,798
7,770,805
1,053,550
Unsupported
$ 4,066,022
720,003
239,371
11,728
3,705,795
573,960
706,019
-0-
11,203,347
711,653
459,555
93,275
-0-
Cost to be Recovered
Ineligible
$ 394,367
472,866
352,029
7,556
445,154
500,669
438.664
1,012.595
970,174
67,451
16,798
7,146,238
897,649
Unsupported
$ 3,795,088
205,196
42,435
577,122
-0-
-0-
481,394
-0-
-0-
688,969
459,555
-0-
-0-
1*The litigation between
the grantee and contractors
in evaluation of the cause
of the problems and
submitting a proposed
resolution caused a delay in
final resolution However,
EPA had to issue a letter of
intent as a Final
Determination of the results
of the audit
2*The size of the two
audits ($74M) and the
number of findings and
complexities of the issues
required extra time for the
preparation of a response to
the reports, as well as, the
review and evaluation of
the response by the IG's
office
3*This audit was held open
pending results of final
litigation of this audit
'Federal share questioned
increased up to the amount
of costs sustained for
recovery in those cases
where costs sustained for
recover/ exceeded Federal
share questioned and were
the result of action taken on
Federal share set aside
22
-------
The following is a summary
of investigative activities
during this reporting period.
These include investigations
of alleged criminal violations
which may result in
prosecution and conviction,
investigations of alleged
violations of Agency
regulations and policies, and
OIG personnel security
investigations. The Office of
Investigations tracks
investigations in the following
categories: preliminary and
regular investigations, joint
investigations with other
agencies, and OIG
background investigations.
Summary Of
Investigative
Activity
During this period, we closed
139 investigations At the same
time, we continued to
emphasize long-term,
major-impact initiatives and
improve the quality of
investigative work
Pending Investigations as of
October 1, 1988 242
New Investigations Opened
This Period 136
Investigations Closed
This Period
139
Pending Investigations as of
March 31, 1989 239
Prosecutive and
Administrative
Actions
In this period, investigative
efforts resulted in 27
indictments and 16 convictions
Fines and recoveries, including
those associated with civil
actions, amounted to $580,137.
Twenty-two administrative
actions* were taken as a result
of investigations
Resignations/Terminations 2
Suspensions 2
Reprimands 4
Restitutions 7
Other 7
*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
Construction
28%
Procurement Fraud
21
88%
TOTAL - 239
Profile of Pending Active
Investigations by EPA Office
Unit
Enforcement & Compliance
1
4%
External Affairs
2
8°/
Personnel Security
4 1 7%
Administration
16
67%
Multi Prog/Other
15
63%
TOTAL - 239
23
-------
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
October 1, 1988.
Connecticut Asbestos
Contractor Indicted
The United Painting Company,
Inc., of Bethel, Connecticut, its
president, James McGuire, and
four employees, Jennifer
Gaboardi, Christopher Gaboardi,
Steven Kovacs, and Christopher
Weldon, were indicted February
23, 1989, on charges of
conspiring to defraud the
Government with false claims
and mail fraud
Bethel, Connecticut,
contracted with the United
Painting Company on July 18,
1988, to remove asbestos from
three schools in the Bethel
School District. Under the
specifications and instructions
to bidders for this contract, it
was required that the contractor
comply with all Federal
regulations governing asbestos
removal in schools. This
contract fell under the
jurisdiction of EPA, which
regulates the school asbestos
removal program under the
Asbestos Hazard Emergency
Response Act (AHERA).
Specifically, the indictment
alleges that all six defendants
conspired to defraud the
Government by engaging in
asbestos removal projects in
violation of the regulations
requiring all workers on such
projects to have completed EPA
approved training programs in
asbestos removal The
defendants also allegedly falsely
certified that the employees on
the project had completed the
required courses
This investigation was
conducted jointly by the EPA
Office of Inspector General and
the United States Postal
Inspection Service
Convictions Mount in
New York Bribery
Episode
Twenty-five asbestos removal
contractors in the New York
metropolitan area were arrested
January 5, 1988, and charged
with bribing an EPA inspector
Subsequently, 25 contractors
representing 19 companies
were indicted, charged with
bribing the inspector to (1)
overlook violations of Federal
rules and regulations regarding
asbestos removal conducted by
the defendants and (2) stay
away from job sites being
worked by their companies As
of March 31, 1989, 16
contractors have pled guilty to
the charges and 4 have been
convicted after a trial. Fourteen
contractors have been
sentenced and fined a total of
$535,000 and six and a half
years imprisonment
The arrest, indictments, and
convictions are the result of a
continuing investigation by the
Department of Labor's Office of
Labor Racketeering and the EPA
Office of Inspector General
EPA regulations require that
specific work practices be used
during demolition and
renovation of structures
involving asbestos to minimize
the potential exposure of
workers and the general public
in the vicinity of the removal
and disposal actions
Contractor's
Overcharging
Uncovered
EPA has recovered $23,682 in
labor overcharges on a contract
with a maior computer services
corporation
The investigation was initiated
originally on several allegations
directed at a subcontractor One
allegation substantiated by an
OIG investigation involved the
billing by the subcontractor for
two employees at the highest
labor rate in the contract EPA
had been billed, in turn, by the
prime contractor for these
excessive labor costs An OIG
inquiry disclosed that the two
employees did not meet the
experience and education
requirements of the highest
labor rate.
In January 1989, the
Procurement and Contracts
Management Division advised
OIG that a fixed labor rate of
$23 99 per hour had been
agreed upon with the prime
contractor in lieu of the $47 05
per hour rate which had been
paid for the 1,027 hours which
had been questioned The
contract was subsequently
modified to recover the funds
due EPA.
EPA Contractor Pleads
Guilty To Being an
Accessory to Theft of
Government Property
SCS Engineers, Inc , of Reston,
Virginia, pled guilty in November
1988 to charges of accessory
after the fact to theft of U S
Government property As
previously reported, Gary L
Mitchell, a former staff engineer
with SCS Engineers, pled guilty
in June 1988 to removing
confidential procurement
information from an EPA facility
during 1985, before and during
the solicitation for a technical
support contract valued at about
$45 million The investigation
was based on an allegation from
a competitor that GCA
Technology Division, Inc, of
Bedford, Massachusetts,
possessed a copy of their bid
proposal At that time Mitchell
was an SCS employee on an
EPA project for the Office of
Solid Waste Further
investigation determined that
SCS Engineers knew of
Mitchell's offense after the fact
and assisted Mitchell The
information was taken to benefit
SCS as a potential subcontractor
to GCA, which subsequently
received this information
24
-------
Illegal "Gray Market" Florida Importer
Cars Sentenced
We continue to work with
Federal and State agencies
investigating "gray market" auto
dealers and emissions
modifications and testing
facilities who illegally sell,
modify, or test imported cars
that have been falsely certified
to meet Federal standards Gray
market auto dealers import cars
to the United States, modify
them to meet U S safety and
EPA emission standards, and
resell them for far less than
U S franchised dealers The
problem concerning EPA is that
many conversions of gray
market cars do not meet
emission standards (Please
refer to a description of
revisions in the EPA regulations
on page 9) The OIG is
concerned with modifiers and
certifiers of gray market cars
who submit or induce others to
submit false statements to EPA
claiming that such cars meet
these standards Five examples
of schemes to defraud the
public follow
North Carolina Trio
Indicted
Motorcars International (MCI),
Gardner H Altman, Jr,
Bernhardt Mueller, and Jerry L
Blackmon were indicted
February 14, 1989, on charges
of conspiring to defraud, making
false statements, false customs
declarations, and forgery
Altman and Mueller established
MCI to import vehicles from
Germany into the U S for
resale Blackmon conducted the
day-to-day operations of MCI
A joint investigation by the
EPA OIG and the U S Customs
Service revealed that between
November 1983 and May 1985,
the defendants imported
approximately 24 Mercedes
Benz and Porsche cars into the
United States for commercial
sale by means of fraudulent
practices and false invoices,
declarations, and written
statements
Nikos Athanassopoulos was
sentenced on February 10,
1989, to two years
imprisonment, to be followed by
a 5 year term of probation, for
illegally importing gray market
Mercedes Benz automobiles to
the U S and making false
statements to EPA regarding
such automobiles
Athanassopoulos was further
ordered to pay restitution to the
automobiles' purchasers, to
whom Athanassopoulos had
misrepresented the age of the
vehicles Athanassopoulos had
previously been indicted on May
11,1988, on charges of making
false statements and false
customs declarations in
connection with the entry of
gray market vehicles into the
United States
The case which was
investigated jointly by the U S
Customs Service and the EPA
OIG, had uncovered that
approximately 250 vehicles had
been illegally imported into the
United States through the Port
of Jacksonville, Florida.
Two Importers
Indicted in Las Vegas
Georgios I Gianakopoulos and
Karl Leon Lerner, along with
other unnamed individuals, were
indicted in Las Vegas, Nevada,
on October 12, 1988, on
charges of conspiring to import
foreign-made vehicles, generally
Mercedes-Benzes, and then
reselling them without
modifying them to meet Federal
emission and safety standards
The vehicles were
misrepresented to domestic
buyers through phony
documents identifying
"strawman" importers
The investigation leading to
this indictment was conducted
by the EPA OIG in cooperation
with the U S Customs Service
and the Department of
Transportation OIG
Dutch Importer
Sentenced
Harmon Westra of Vennep,
Holland, was sentenced on
January 9, 1989 to 3 years
unsupervised probation, fined
$2,500, and ordered to report to
any probation office within the
Judicial District of New Jersey
anytime he enters the United
States Westra had pled guilty
to charges of illegally importing
foreign vehicles through the
Port of Newark, New Jersey
Westra falsified import
documents on several vehicles,
including two Mercedes Benz
automobiles, stating that other
individuals were the owners of
the cars when, in fact, Westra
was the owner EPA regulations
provide for a one-time
exemption to an individual to
import one car, 5 years and
older, without complying with
the Clean Air Act requiring
modification of the vehicle's
emission control system
Georgia Supplier
Continued Criminal
Activity
Alan Blane Grant of
Douglasville, Georgia, was
arrested on December 19, 1988,
and charged with defrauding the
Government at least through
September 1988 on a contract
with the U S Navy to furnish a
van-mounted television sewer
inspection system for use at
naval bases in Hawaii
According to the indictment.
Grant conspired with others to
disconnect the odometer and
drive the sewer inspection van
from Georgia to San Bruno,
California, where the odometer
was reconnected and the
vehicle represented to the Navy
as a new vehicle The
indictment further alleges that
other equipment required by the
contract was missing when the
vehicle was delivered to the
Navy, despite Grant's certified
contract compliance Grant is
also charged with selling
equipment that the Navy turned
back to him for repair
As reported previously, Grant
pled guilty in November 1987 to
defrauding the Government by
providing underweight and
defective grout used in
EPA-funded sewer rehabilitation
projects The judge enjoined
Grant permanently and
personally from future
fraudulent conduct He also
received a 5-year suspended
sentence, with 6 months
residence in a halfway house,
and 200 hours of community
service His company, Polymer
Chemicals, Inc , was fined
$10,000
The new indictment charges
that Grant continued his
fraudulent conduct throughout
the period up until at least
September 1988 If convicted
on all counts, he could face
penalties totalling 77 years in
prison and a $250,000 fine
The charges against Grant
resulted from a joint
investigation by agents of the
Defense Criminal Investigative
Service and of the EPA OIG
Sewage Plant False
Test Results Lead to
Indictment
John G Mason of Raleigh, N C ,
the contract operator for five
wastewater treatment plants in
Wake County, N C , was
indicted in January 1989 and
charged with submitting false
lab test results on effluent from
the plants
The information, submitted to
the North Carolina Department
of Natural Resources and
Community Development, made
it appear that the plants
complied with the limits of a
permit issued under the
National Pollutant Discharge
Elimination System (NPDES)
The Clean Water Act provides
that no pollutants may be
discharged into navigable
waters of the United States
except under conditions stated
in an NPDES permit The North
Carolina Department of Natural
Resources and Community
Development administers the
NPDES permit program in North
Carolina as EPA's agent
25
-------
Impersonator of
Federal Officer
Sentenced
Alejandnno Ramos was
convicted in December 1988 of
mail fraud, impersonation of a
Federal officer, and improper
use of Government seals in a
scheme to defraud Water Wise,
Inc., of Leesburg, Florida, a
supplier of water purification
equipment and supplies, and
the Federal Government Ramos
was sentenced to 14 months in
prison, 24 months probation,
and required to pay $1,077
restitution
Doing business as National
Environmental Protection
Service of Lafayette, Louisiana,
Ramos mailed an order to
purchase some water distillation
equipment from Water Wise for
delivery on open account, in so
doing, he represented himself
as an agent of EPA Later he
told Water Wise that he would
provide a General Services
Administration purchase order
number authorizing payment for
the products by the U S
Government Based on these
false representations, Water
Wise shipped equipment and
accessories valued at $1,077 to
Ramos In addition, Ramos
further communicated with
Water Wise using a personal
business card and stationery
bearing the seal of EPA
Former Police Officer
Sentenced for Fraud
on EPA Project
Donna Amato, a former New
Haven, Connecticut, police
officer, was sentenced on
January 31, 1989, after being
convicted of making false claims
for pay for traffic control work
not actually performed on an
EPA-funded sewage treatment
improvement project in New
Haven Amato received a
one-year suspended sentence
and was fined $1,000 She was
also ordered to perform 500
hours of community service
over the 2 years of probation
Two other New Haven police
officers previously pled guilty to
similar charges The cases
resulted from an investigation
by the EPA DIG and the Internal
Affairs Division of the New
Haven Police Department
Consulting Engineer
on EPA Study
Convicted of Fraud
Samar Chatterjee, president of
Universal Engineering Services,
Inc , and AES Engineers, Inc ,
was sentenced on February 6,
1989, after being convicted of
conspiracy, mail fraud, and
making false statements in
connection with consulting work
he did on the EPA-funded South
Stickney Sanitary District,
Burbank, Illinois, sewer
rehabilitation study
Chatterjee was sentenced to
jail for 4 years, placed on
probation for 5 years, and
ordered to pay $110,000 in
restitution to EPA and another
$110,000 to the South Stickney
Sanitary District
Chatterjee had been charged
with submitting false testing
data concerning sanitary sewer
connections, flow gauging,
manhole inspections, and sewer
survey reports to EPA and the
Metropolitan Sewer District of
Greater Chicago In addition,
Chatterjee received EPA grant
funds of over $200,000 for work
that he allegedly did not
perform
Chatterjee's case resulted
from a 3-year investigation into
allegations of financial fraud in
the South Stickney Sanitary
District The investigation was
conducted jointly by the EPA
OIG, the EPA Office of
Enforcement and Compliance
Monitoring, and the FBI
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
26
-------
Former Region 4
Employee Charged
with Theft
A 9-year employee in Region 4
has been charged with theft of
four EPA-owned calculators
valued at $260. She
subsequently pawned the
machines. The employee was
removed from her position in
February Further investigation
revealed that she had been
arrested by local law
enforcement officers in
December 1988 for alleged
possession of narcotics and in
March 1989 for alleged
numerous bad check offenses
The investigation was a joint
effort by EPA OIG and General
Services Administration OIG
Bus Pass Money
Taken by Region 6
Employee
In November 1988 a Region 6
employee was sentenced to 3
years probation, 100 hours of
community service, and was
directed to enter a mental
health program for keeping
$8,000 due the Dallas Area
Rapid Transit (DART) system for
bus passes sold to EPA
employees. For over 8 months,
the employee received bus
passes worth approximately
$71,500 from DART for resale
to EPA employees The unsold
passes (but no money) were
returned to DART in March
1988, a month after the
employee's resignation from
EPA The Assistant U S
Attorney asked that restitution
of the stolen money be part of
the sentence, but the judge
declined because the employee
did not have any money This
investigation was a joint effort
by EPA OIG and the
Department of Transportation
OIG
Employee
Reprimanded for False
Statements
A Region 9 employee was
reprimanded for knowingly
submitting falsified income
statements to obtain Housing
Assistance Payments from the
Department of Housing and
Urban Development (HUD) The
employee had provided false
income and employment
information to EPA employees,
which was subsequently
provided to HUD, so she could
obtain payments The reprimand
followed the employee's guilty
plea and sentence to 5 years
probation and full restitution to
HUD
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, as amended, and
other authorities; working with
grantees using their own civil
litigation authorities, invoking
the restitution provisions of the
Victim and Witness Protection
Act during criminal sentencing;
using the Agency's authority to
administratively offset future
payments and to collect debts;
and negotiating voluntary
settlements providing for
restitution in the context of
suspension and debarment
actions.
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, in 53 Federal Register
75782 (codified at 40 C F R 27)
With these regulations in place,
we are now prepared to bring
cases to EPA's administrative
law judges for adjudication and
recovery
Civil and administrative
actions to recover funds usually
extend over several semiannual
reporting periods. What follows
is a brief description of the
progress being made on several
such matters
27
-------
EPA Wins $84,000
from Superfund
Defrauders
On January 13, 1989, a Federal
judge in Michigan ordered a
corporation and three of its
owner/officers to pay the United
States $84,362 in a Superfund
fraud case The order was a
response to a Department of
Justice complaint, filed on
behalf of EPA, seeking
approximately $500,000 under
the False Claims Act, as
amended The amount
represented treble damages and
civil penalties for false claims
submitted to EPA under a
contract.
An investigation by the OIG,
initiated as a result of an audit,
demonstrated that the Enmanco
Corporation and three of its
owner/officers, James Barnum,
Gary Domanski, and Daniel Toy,
had submitted false payroll
costs, manifests, and invoices
during the 1982-83 Superfund
cleanup of the Liquid Disposal,
Inc , hazardous waste site
During the investigation, haulers
admitted driving only half-full
trucks that Enmanco had
manifested as full, and a waste
disposal firm admitted paying
Enmanco a $25,041 kickback for
receiving its business The
defendants pleaded guilty to
one count of conspiring to
defraud the Government with
respect to claims and paid
criminal penalties, served jail
time, and made restitution of
$32,181 under the Victim and
Witness Protection Act
Appeal Denied in
Atlanta Area Claim
The Government's position in a
case to recover damages for
bidngging has been
strengthened by a recent court
decision upholding the
defendants' convictions
EPA filed a complaint on April
13, 1988, against Paxson
Electric Company, Dynalectric
Company, Fischbach & Moore,
Inc., G W Walther Ewalt, and
Wesley C Paxson, Sr, for triple
damages and civil penalties
under the False Claims Act, as
amended, and for damages
under common law The United
States seeks to recover its
damages, estimated at $1.3
million, which may be tripled
under the Act, plus up to
$10,000 in civil penalties for
each false claim submitted
These defendants were
previously indicted for, among
other things, conspiracy to rig
the bids on the electrical portion
of the EPA-funded Snapfmger
Creek Wastewater Treatment
Plant in DeKalb County, Georgia
Fischbach & Moore pled guilty
to the charges. The remaining
defendants were tried and
convicted They then appealed
to the 11th Circuit Court of
Appeals, which recently
affirmed the convictions
EPA Seeks to Debar
Acquitted Contractor
A Federal judge in Philadelphia
has authorized EPA to proceed
with a debarment action against
a contractor although the
contractor has been acquitted of
charges on which the
debarment was based EPA's
action against B E S
Environmental Specialists, Inc ,
and its founder, Richard
Baranowski, is apparently the
first time that a civilian Federal
agency has initiated debarment
proceedings in the wake of an
acquittal.
B E S. and Baranowksi were
acquitted in I987 of defrauding
EPA on a Superfund contract for
cleaning up the Brown's Battery
site near Lancaster,
Pennsylvania Nevertheless, the
Office of Inspector General
maintained that the transcript of
the criminal case showed that
B E.S had defrauded EPA
On September 29, I988, EPA
initiated the debarment action,
raising three allegations First,
the Agency charged that B E S
and Baranowski had defrauded
EPA on the Brown's Battery
project, citing the record from
the criminal trial Second, it
alleged that Baranowksi had
given an EPA on-scene
coordinator gratuities free
construction work on his home
and an expense-paid Canadian
vacation. Finally, EPA charged
that B E S had refused to
submit to an audit, breaching its
contracts In light of the
evidence of overcharges from
the criminal trial, the Office of
Audit had sought to audit
several B E S projects When
B E S. resisted, the Inspector
General subpoenaed B E S '
cost records
B E S asked for a preliminary
injunction against both the
debarment action and the
subpoena in Federal district
court in Philadelphia On
November 23, I988, Judge
Marvin Katz denied B E S '
motion. He found that the
failure of the Government to
prove its criminal case beyond a
reasonable doubt did not
preclude EPA from seeking a
debarment under a standard
based on preponderance of the
evidence He also ruled that
EPA's debarment procedures
satisfy all due-process
requirements The court ordered
B E S. to produce the
subpoenaed documents within
15 days.
EPA held an administrative
debarment hearing in early
February 1989. A decision is
expected soon In the
meantime, B E S has been
suspended from receiving EPA
contracts
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oGCtlOn 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 specifies
that it is the duty and
responsibility of the Office of
Inspector General to review
existing and proposed legislation
and regulations relating to
programs and operations
concerning their impact on
economy and efficiency or the
prevention and detection of
fraud and abuse We reviewed
56 items this semiannual
reporting period, 24 legislative
and 32 regulatory The most
significant items reviewed are
summarized below
Inspector General Act
Amendments of 1988
Former President Reagan
signed the legislation known as
the Inspector General Act
Amendments of 1988, Public
Law 100-504, on October 18,
1988 The amendments create
new statutory IGs, appointed by
the President, at the
Departments of Justice and
Treasury, the Federal
Emergency Management
Agency, the Nuclear Regulatory
Commission, the Office of
Personnel Management, and
the Government Printing Office
The law also creates OIGs at 33
smaller Federal agencies, with
Inspectors General to be
appointed by the agency head
Other features include separate
budget appropriations for OIGs,
oath administration authority,
uniform salaries for inspectors
general, and clarification of the
IGs' authority to fill Senior
Executive Service positions
A major provision of the
amendments changes reporting
definitions for the DIG and
requires Agency management
to report semiannually to
Congress on its response to
DIG findings A detailed
description follows
New reporting requirements
for offices of inspectors
general
Questioned Costs
A Number of previously issued
reports with questioned costs
pending management decision
at start of period, and the dollar
amount of total questioned
costs, as well as unsupported
costs
B Number of new reports
issued during period with
questioned costs, and the dollar
amount of total questioned
costs, as well as unsupported
costs
C Number of reports with
recommendations for which
management decisions were
made during reporting period,
including totals of costs
disallowed by management and
not disallowed by management
D Number of reports for which
no management decision has
been made within 6 months
after the date the report was
issued, including the dollar
amount of total questioned and
unsupported costs
Recommendations
That Funds Be Put To
Better Use
A Number of previously issued
reports with recommendations
that funds be put to use where
no management decision has
been made by start of period
B Number of reports containing
such recommendations that
were issued during reporting
period, including the dollar
amount of such
recommendations
C Number of reports that were
decided by management during
the period, and the dollar
amount, in two categories (1)
agreed to by management and
(2) not agreed to by
management
D Number of reports pending
action at end of period, and the
dollar value of recommendations
E Number of reports for which
no management decision has
been made within 6 months
after the date the report was
issued, and the dollar value of
recommendations
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Definitions
(IG Act
Amendments
of 1988)
Questioned cost—a cost
questioned by the IG
because of.
• an alleged violation of
law, regulation, contract,
grant, agreement, or
document governing the
expenditure of funds
(ineligible costs)
• a finding that such cost
is not supported by
adequate documentation
(unsupported costs)
• a finding that the
expenditure for the
intended purpose is
unnecessary or
unreasonable.
Unsupported cost—a
cost questioned by the IG
because it is not
supported by adequate
documentation.
Disallowed cost—a
questioned cost that
management, in a
management decision,
has sustained or agreed
should not be charged to
the Government
Recommendation that
funds be put to better
use—a recommendation
by the IG that funds could
be used more efficiently if
management
implemented and
completed the
recommendation by
reductions in outlays,
deobligation of funds,
withdrawal of interest
subsidy costs on loans,
guarantees, insurance, or
bond; not incurring costs
by implementing
recommendations related
to the operation of the
Agency, contractor, or
grantee; avoiding
unnecessary expenditures
noted in preaward reviews
of contract or grant
agreements; or taking
specifically identified
actions
New reporting requirements by
management'
Disallowed Costs
A. The number of reports and
their dollar value where final
action was not taken by the
start of reporting period
B Where a management
decision has been made during
the reporting period, the
number of reports and their
dollar value in two categories:
(1) disallowed costs recovered
and (2) disallowed costs written
off
C Number of reports and dollar
value on which final action was
not taken by the end of the
reporting period
Recommendations
That Funds Be Put to
Better Use
A Number of reports and their
dollar value on which (1) final
action had not been taken by
start of reporting period and (2)
a management decision was
made during the reporting
period.
B Where final action was taken
during the reporting period (1)
the number of reports and the
dollar amount of
recommendations that were
completed and (2) the number
of reports and the dollar amount
of recommendations that
management subsequently
concluded should not or could
not be implemented.
C The number of reports and
their dollar amount of
recommendations on which no
final action has been taken by
the end of the reporting period
Reports Over a Year
Old Where a
Management Decision
Has Been Made but
Final Action Has Not
Been Taken
A title
B. date Issued
C. dollar value of disallowed
costs
D dollar value of
recommendations that funds be
put to better use (agreed to by
Management)
E. explanation why final action
was not taken
Major Fraud Act of
1988
Signed into law on November
19, 1988, the Major Fraud Act,
Public Law 100-700, amends
Title 18 of the U.S Code and
creates a new crime of intent to
defraud the Government on
contracts of $1 million or more
The fine for conviction is not
more than $1 million or not
more than 10 years
imprisonment, or both The fine
may be increased to $5 million
if the gross loss to the
Government or gross gain to
the defendant is $500,000 or
more, or the offense involves
conscious or reckless risk of
serious personal injury There is
a cap of $10 million on the fine
for a single defendant in a
multiple count-prosecution, and
a 7 year statute of limitations
Federal Employees
Liability Reform and
Tort Compensation
Act of 1988
We supported the intent of this
legislation, which was signed
into law (Public Law 100-694) by
former President Reagan on
November 18, 1988 A Supreme
Court decision (Westfall v Ervin)
severely restricted the scope of
the judicially created doctrine of
common law immunity for
Federal employees We believe
that this legislation will provide
a proper balance between a
Federal worker's right to
protection from personal liability
for common law torts
committed within his/her scope
of employment, and the right of
a victim of these torts to
appropriate compensation from
the United States
Computer Matching
and Privacy Protection
Act of 1988
The Computer Matching and
Privacy Protection Act, Public
Law 100-503, is intended to
ensure privacy, integrity, and
verification of data disclosed for
computer matching The act
requires written agreements
between the source and
recipient agencies stating the
purpose, legal authority,
justification and including a cost
benefit analysis of each
proposed match Copies of each
agreement must be sent to
Congress and the Office of
Management and Budget
(OMB) and published in the
Federal Register Also, each
Agency conducting or
participating in a matching
program must establish a Data
Integrity Board to review
proposed matching programs
and prepare an annual report to
OMB The Inspector General of
each agency will be a member
of the Board, but may not serve
as chairman If the Board
disapproves a match proposed
by the IG, the IG may report the
disapproval to the head of the
agency and to Congress
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Independent Defense
Department Inspector
General Act
We concurred with virtually all
the other IGs that this proposal
(H R. 102), which would make
the DOD IG a separate agency,
is unnecessary and would
probably prove to be
unproductive for several
reasons
— the IGs have operated
successfully under the IG Act of
1978, as part of each agency,
for over 10 years without
compromising their objectivity,
impartiality, or independence
There appear to be no
documented reasons to alter
the relationship thus
established
— one of the great strengths of
the IGs is gained because they
are an integral part of their
agencies. The IGs became part
of top management with all the
access to information that
accompanies such a position
The IG's employees are agency
employees and are not regarded
as outsiders by the rest of the
agency Accordingly, they are
able to acquire inside
information and programmatic
skills that would be otherwise
unavailable
— duplicative and costly efforts
by the separate IG and the
agency would result If the IG is
removed from top management,
the head of an agency almost
surely will create another
internal unit to do some similar
work
— of overall concern is the
concept embodied in this bill
that an outside force, if
endowed with sufficient power,
can force an agency to do the
right thing Our experience is
otherwise All IGs have found
that working cooperatively,
albeit independently, within an
agency is the way to get things
done
Related to the issue of IG
independence was a recent
court decision The Third Circuit
Court of Appeals, in DCIS, DOD
v Federal Labor Relations
Authority, ruled that the DOD IG
was a representative of the
agency, entitling Federal
employees to the presence of a
union representative when
being questioned about a matter
that could lead to the imposition
of disciplinary sanctions A
survey of the IGs reached the
conclusion that, at this point, a
legislative remedy was not
necessary, noting that only one
circuit has ruled definitively on
this issue Accordingly, it is not
yet clear that the law is so
settled that OMB and the
Congress would be amenable to
a legislative change. The PCIE
Legislation Committee
recommends that IGs continue
to vigorously defend the
proposition that they are not
representatives of the agency
because of their independent
authority to audit and
investigate under the IG Act
Inspector General
Awards Act
We joined with most of the
other IGs in supporting this
legislation, H R 4574, which
would amend Title 5, U S Code,
with respect to certain
programs under which awards
may be made for superior
accomplishments or cost
savings disclosures There is a
consensus among the IGs that
there will be occasions when
such an award will be both
deserved and appropriate, even
if the number of opportunities
to use authority may not be
significant The publicity
surrounding such an award may
encourage other employees
We did suggest that the
legislation be revised to make
OIG employees ineligible for the
award since reporting fraud,
waste, and mismanagement is
an inherent part of their jobs
Administrative
Conference Act
We commented on an OMB
proposal to amend the
Administrative Conference Act
The amendment stated that any
agency proposing to enter into a
contract with a person outside
the agency to study the
efficiency, adequacy and
fairness of an agency
proceeding must first consult
with the chairman of the
Administrative Conference to
determine whether the study
would be more appropriately
undertaken by the Conference
We did not concur with this
proposal, which we believe
could delay contracted studies
We suggested that consultation
with the Chairman be
suggested rather than
mandatory, or that a dollar
threshold be established for
mandatory consultation
EPA Personal Property
Management Policy
We commented on a proposed
EPA policy on personal property
management The Agency
reported this item to OMB in
1988 as a material weakness
under the Federal Managers
Financial Integrity Act. We
suggested several changes that
the same individual should not
perform both the physical
inventory and the reconciliation
of records, that the appointing
official for the positions of
property administrator and
contract property administrator
be clearly identified; that
software accountability be
addressed, and that
accountability for property under
other trust funds, such as that
for leaking underground storage
tanks, also be addressed. We
also clarified statements in the
policy on audits, noting that the
EPA OIG rarely audits
mteragency agreements These
audits are normally done by
other IG organizations which
have responsibility according to
the Single Audit Act. We noted
that requests for audits of
specific mteragency agreements
can be made through the OIG
EPA Information
Security Manual for
Personal Computers
We had several comments on
an Agency security manual for
personal computers We
recommended that the Agency
establish procedures for
removing personal computers
from EPA buildings for official
use; prohibit the installation of
privately owned software on
EPA computers to preclude the
possibility of sabotage
("viruses"), clarify the degree of
sensitivity of those positions
dealing with computers; and
ensure that personnel leaving
the Agency no longer have
access to ADP systems
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Suspension And
Debarment
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 who have acted
improperly, have a history of
substandard work, or have
willfully failed to perform on
contracts funded by EPA (or in
some cases contracts that are
funded by other Federal
agencies). The convicted felon
is by far the most frequent
subject of an EPA debarment
Suspensions, debarments, and
voluntary exclusions deny
participation in Agency
programs and activities to those
who represent a risk of cheating
the Government Such actions
aid in preventing our tax dollars
from being given to dishonest
or nonresponsible contractors
and grantees
The effectiveness of the
suspension and debarment
(S&D) program has been
enhanced by new regulations
that provide all Federal agencies
a uniform system for debarring
contractors from receiving work
funded by Federal grants, loans,
or cooperative agreements The
new system, required by
Executive Order 12549, was
implemented on October 1,
1988
The new system provides
that a nonprocurement
debarment or suspension by
one agency is effective in all
and requires the 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 identifies situations
where the need for suspension
or debarment is indicated and
makes referrals to Agency S&D
action offices This requires
frequent reviews and analyses
of several systems of records,
both EPA records and those of
other agencies To expedite this
process, we established a
computerized matching program
that will compare thousands of
records in a very short time and
identify same or similar names
This process allows us to
review large volumes of records
with minimal resources and
extract meaningful information
for suspension/debarment,
investigative, or audit purposes
The OIG will soon be issuing
instructions (an OIG Manual
chapter) to Headquarters and
field offices that cover recent
changes in the S&D system
The OIG Manual chapter and
training course will provide a
better understanding of the
S&D program and will result in
greater use of the S&D remedy
Summary of
Suspension and
Debarment Activities
EPA is aggressively seeking
debarment and suspension of
dishonest and nonresponsible
contractors and grantees The
following is a summary of S&D
actions taken during this
reporting period.
October 1, 1988,
to March 31, 1989
CASES OPEN AT BEGINNING
OF PERIOD 271
CASES OPENED
DURING PERIOD
82
CASES COMPLETED
Debarments 31
Voluntary Exclusions 3
Settlements 17
Closed after Investigation 22
Subtotal 73
Total 280
Active cases
as of March 31. 1989
Under Investigation 38
Under Program or
Counsel Review 208
Proposed for Debarment 7
Suspended or Suspended and
Proposed for Debarment 27
Total
280
The following are several
examples
• Paxson Electric Company of
Jacksonville, Florida, was
debarred for two and one-half
years on November 7, 1988
Also debarred for the same
period was Wesley C Paxson,
Sr., president of the firm. The
company and Mr Paxson had
been convicted of bidnggmg and
mail fraud resulting from their
participation m a conspiracy to
submit collusive,
complementary and rigged bids
for electrical work at the
EPA-funded Snapfmger Creek
Waste Water Treatment Plant in
DeKalb County, Georgia
• Denver Sanitary Company of
Denver, Colorado, accepted a
voluntary exclusion for 20
months on January 17, 1989,
after being convicted of making
false statements, transporting
hazardous waste to an
unpermitted facility, and illegally
storing hazardous waste Donald
C. Hughes, operations
supervisor of the company's
hazardous waste division, Frank
R. Giardmo, the company's vice
president and chief operating
officer, and Andrew Fedorowicz
were debarred after being
convicted as accessories to
illegal transportation of
hazardous waste to an
unpermitted facility, illegal
storage of hazardous waste, and
making a false statement on a
hazardous waste manifest
• Arnold N Graham, of Kansas
City, Missouri, was debarred for
3 years on October 13, 1988
after being convicted for
conspiring to use the mails in
connection with a scheme to
defraud and for obtaining money
by false pretenses The
violations were in connection
with the operation of a
wastewater treatment plant and
the preparation of documents
containing falsified EPA test
data
• Charles R Barren of Slidell,
Louisiana, was debarred for 3
years on October 13, 1988,
following his conviction for
bidnggmg in connection with
32
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dredging contracts with the U S
Army Corps of Engineers By
agreement with EPA, the
remainder of Barren's
debarment period was changed
to a voluntary exclusion
beginning February 13, 1989
• George W Shearer of San
Diego, California, was debarred
for 2 years on December 23,
1989, based on his conviction
for making and using false
documents in connection with a
scheme to illegally export
hazardous wastes from the
United States for unlawful
disposal at a site in Mexico
• Fred 0 Uhle of Valley Park,
Missouri, was debarred for 8
months on November 2, 1988,
after being convicted for making
false declarations before a grand
jury concerning bidnggmg
activities in the electrical
construction industry
• Meade Electric Company,
Inc , of Hammond, Indiana, and
Joseph P Condon, a branch
manager for the company,
voluntarily excluded themselves
for 9 months on November 2,
1988, following their conviction
for bidnggmg in the electrical
construction industry
CORRECTION
Three debarred electrical
inspectors, Julius
Mastnana, Thomas
DiMicelh, and Eugene
Riccardelh, were
incorrectly identified as
EPA electrical inspectors
in the semiannual report
for the period ending
September 30, 1988 The
inspectors were
employees of New York
City The DIG regrets this
error
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 participation by
specific segments of the
concerned population in
recognizing and reporting
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
Semiannual Reports
Over 1,500 copies of each
semiannual report to Congress
is 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
Presentations to Management
and Associations
The Inspector General, Acting
Deputy Inspector General, and
other OIG managers have
participated in a vigorous
schedule of presentations and
briefings to EPA managers in
Headquarters and the field
Also, presentations have been
made to grantees, professional
and governmental associations,
State and local government
officials, and educational
institutions
IG Testifies Before Congress
On February 23, 1989, the
Inspector General testified
before the Subcommittee on
Human Resources of the House
Post Office and Civil Service
Committee The IG discussed
three audit reports which
focused on the Agency's
contracting policies and
administration The first two
audits dealt with the Superfund
program, while the last dealt
with contracting activities
supporting the Resource
Conservation and Recovery Act
program The IG testified that
the audits conducted showed a
need for greater Agency
oversight of contractors Major
problem areas included (1) the
use of highly qualified contractor
technical personnel to perform
routine administrative and
clerical work, (2) the use of
contractor personnel for
personal services, (3) award
fees that were overgenerous
and awarded for deficient work,
(4) EPA technical personnel
directing contractors to perform
work before it was properly
ordered or funded, and (5)
subcontractors were not being
procured in accordance with
Federal regulations The IG
concluded his testimony by
stating we will continue to
perform audits of contracting
policies and administration and
to work with Agency
management to ensure that we
are getting the best return on
our contract dollars
Presentation at Superfund
Conference
OIG representatives participated
in and moderated a panel
discussion at a national
conference on Superfund
mteragency agreements and
cooperative agreements The
panel was comprised
representatives from the OIG
community whose agencies
receive millions of dollars in
Superfund monies to carry out
the activities the agencies are
either mandated to perform or
are requested to do by EPA
The panel included
representatives from EPA, Army
Audit Agency, Federal
Emergency Management
Agency, and the Departments
of Transportation, Energy, and
Health and Human Services
The objective of the panel
discussion was to increase
awareness of the OIGs' audit
requirements mandated by
Congress and to inform the
participants of how the other
Federal agencies are managing
and controlling the use of the
Superfund Trust Fund
Articles and Publications
We have been working with
several professional associations
to develop publications and
articles which have a wide
audience in the areas of
environmental protection,
auditing, government financial
management, and law
enforcement We have also
continued to develop and
publish articles for EPA
33
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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
Presentation of Fraud
Detection Awareness Course
to Agency Managers
This semiannual period we gave
several presentations of our
in-house developed awareness
course entitled "Detecting and
Preventing Fraud in EPA." This
course was developed for
presentation to independent
public accountants who perform
audits for the OIG on a contract
basis, the course was designed
to increase their awareness of
and ability to detect and refer
indicators of fraud to our Office
of Investigations However, the
course has also been designed
for presentation to a variety of
audiences concerned with the
ability to detect and prevent
fraud in EPA operations,
projects, and contracts During
this semiannual period we
presented the course twice
through the EPA Institute We
will continue presenting this
course through the EPA
Institute and by request when
possible.
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 229
investigations. The following
conditions were identified and
administrative actions taken
• Two employees received
7-day suspensions, one for
numerous arrests and
convictions while employed in a
sensitive position, the other for
falsification by not listing a
conviction for possession of
controlled substances on a
SF-171 used when applying for
a promotion.
• Two employees were
terminated during their
probationary periods, one for
unprofessional conduct, the
other for materially falsifying the
SF-171.
• Two contract employees had
to submit corrected SF-86s to
reflect previous convictions for
misdemeanors
• Two employees were
required to submit corrected
SF-171 s for failure to list
previous misdemeanors and
convictions
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
Mr. Martin's committee, as
reorganized in February 1988,
incorporates activities of the
former Prevention Committee,
Inspections and Special
Reviews Committee, Training
Committee, and the Standards
Committee The functions of
the 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
published 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 staff participate as
members of the Legislation,
Computer, Coordination, and
Integrity and Law Enforcement
Committees Members of our
staff represent the OIG on the
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 HHS, were
recently appointed to 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
34
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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 during this
semiannual reporting period
Some of these special reviews
conducted during this reporting
period are summarized below
Committee Survey on Ethics
Violations
A survey of 700 ethics cases
investigated by Inspectors
General provided a sample of
182 cases which were
categorized to provide an
overview of the types of
government ethics violations
The majority of the cases fell
into four categories
• Improper use of government
property-28 percent
• Conflict of mterest-20 percent
• Using public office for private
gam-15 percent and
• General conduct preiudicial to
the government-14 percent
Results of the survey were
provided to the Presidential
Commission on Ethics Law
Reform
Employee Exchange Program
Best Handled on an Ad Hoc
Basis
The Administration, Inspections,
and Special Reviews Committee
conducted a survey of the PCIE
to determine if members would
be in favor of an employee
exchange/loan program Such a
program might be useful to
fulfill the increased
responsibilities of the IG Act
amendments in that IGs with
personnel on their staffs with
specialized knowledge could
help other IGs with particular
aspects of their operations The
second part of the survey dealt
with ensuring broad distribution
of OIG vacancy announcements
The consensus of the PCIE
was that informal consultation
between OIG staffs appeared to
be working well as a way to
share information, and when
detailing staff to another OIG
was necessary, arrangements
were best worked out between
the two IGs involved On the
issue of distribution of vacancy
announcements, we provided
the results of our survey to the
IG Personnel
Officer/Representative
Conference for discussion and
implementation of a vacancy
announcement distribution
system
Computer System Identifies
Illegal Aliens
On December 14, 1988, the
EPA OIG sponsored a
demonstration for PCIE
members on how OIGs can
access a data system which
identifies illegal aliens The
presentation was conducted by
Neville Cramer, Deputy
Assistant Commissioner,
Employer Labor Relations,
Immigration and Naturalization
Service This data system could
be particularly useful to OIGs in
agencies which administer
entitlement programs or
agencies that award grants and
contracts where illegal aliens
may be part of the work force
Training Officers Study
Computer-Based Training,
More Cooperation
In addition to these reviews, the
Support Activities Working
Group, chaired by EPA,
sponsored two meetings of the
OIG training officers, now
organized as the PCIE Training
Officers Forum The first, in
November, featured a
presentation by a representative
from the office of the
Comptroller of the Currency,
who demonstrated a
computer-based program used
to tram entry level bank
examiners The training officers
examined the concept in
relation to common training
needs. In February, the training
officers heard a presentation by
William Broadus of the General
Accounting Office on
implementation of the increased
continuing professional
education requirements for
Federal employees involved in
auditing activities Presentations
were also given by a
representative of GSA
concerning training for OIG
personnel answering "Hotline"
calls; a representative of the
Interagency Auditor Training
Program (IATP), who spoke on
expanded course offerings; and
the dean of the EPA Institute
The EPA Institute is a vehicle
which allows EPA employees to
share their knowledge and
experience at minimum or no
cost The training officers are
considering the establishment
of an IG Institute, which would
facilitate sharing within the IG
community of courses
developed by individual IG
organizations
The training officers are also
working to identify their fiscal
1989 and fiscal 1990 common
course training needs in the
regional locations. Working
closely with IATP, which would
present the courses, they hope
to reduce training travel costs
by offering common core
classes in the regional cities
The increased continuing
professional education
requirements in the revised
GAO "yellow book" are the
impetus for this effort to
maximize the dollars provided
for training of OIG personnel
Freedom of Information Act
Session Held
The Support Activities Working
Group also sponsored a seminar
in December for 30 OIG
personnel who handle Freedom
of Information Act requests
Conducted by representatives of
the Department of Justice's
Office of Information and
Privacy, the session examined
the effects of 1986 changes in
the law and recent court
decisions Fees, fee waivers,
and the law enforcement
exemption under FOIA were
also discussed
Committee On
Integrity And
Management
Improvement
The Committee on Integrity and
Management Improvement
(CIMI) was established in 1984
by EPA Order 1130.1. The
purpose of CIMI is to coordinate
the Agency's effort to minimize
the opportunities for fraud,
waste, and mismanagement in
EPA programs and to advise the
Administrator on policies to
improve the efficiency and
effectiveness of EPA programs
and activities The Committee is
chaired by the Inspector
General The following
examples describe projects
completed during this reporting
period
Awareness Bulletin on the
Disposition of Official Records
and Personal Papers
Official EPA records are
Government property and may
not be disposed of except in
accordance with EPA records
control schedules These
schedules contain authorized
retention periods and
instructions for the disposition
of official Agency records which
have been approved by the U S
Archivist, National Archives and
Records Administration CIMI
believed that many EPA
employees were unaware of
which records they could keep
and which records belong to
EPA As a result, CIMI
developed an awareness
bulletin to summarize the
requirements concerning the
maintenance and disposition of
official Agency records
Employees transferring to other
EPA organizations or leaving the
Agency were reminded that the
documents they have
accumulated — except for
personal papers—belong to the
Agency, this requirement
35
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includes records maintained in
private offices as well as those
filed centrally. Employees were
also advised that criminal
penalties are provided for the
willful and unlawful destruction,
removal from file, or private use
of Federal records
Poster Campaign
As stated in our last semiannual
report, CIMI developed a
pamphlet entitled "Ethics in a
Nutshell " It is a brief
explanation of the
conflict-of-interest statutes and
EPA ethical standards The
question-and-answer format is
designed to anticipate and
answer some of the more
common concerns facing
Federal employees. In an effort
to promote employee interest in
reading this pamphlet, CIMI
developed two posters in a
planned series of posters
designed to raise employee
awareness of ethics A
question-and-answer format
was used which required
employees to refer to the
pamphlet to obtain the answer
to the question To increase the
effectiveness of the poster
campaign, only practical
questions relevant to current
issues were utilized The
posters are on display at
Headquarters and all regional
offices.
Hotline Activities
The OIG Hotline Center
received 46 new complaints and
completed and closed 35 cases
during the reporting period Of
the 35 cases closed, 8 cases
resulted in environmental,
prosecutive, or administrative
corrective action, while 27 were
not valid and 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 625
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 an
EPA manager used Government
materials and employees to
perform work at his home on
government time A review of
the complaint disclosed that the
manager used government
employees to perform repairs
and maintenance on his home
on three occasions In addition,
a government employee and
government materials were
used to construct a personal
item for the manager on
government time As a result of
this misuse of government
personnel and property, the
manager's employment with
EPA was terminated
• A complaint alleged that an
EPA employee attempted to
use Government mail services
(EPA mail room) for private use
A review of the complaint
disclosed that the employee
tried to use express mail to ship
personal documents out of state
at Government expense As
result of this misconduct, the
employee was counseled and
action was taken to prevent the
attempted misuse of
Government mail services from
recurring
Professional And
Organizational
Development
During this semiannual period,
the EPA OIG has 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, projects of our
Human Resources Council,
publication and distribution of
our own training catalog, and
organization wide training on
self-awareness and
organizational culture For this
semiannual period, we approved
365 training enrollments for a
total of 1,215 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 twice
through the EPA Institute and m
our Western Audit Division to
members of our staff, auditors
from the California 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
throughout the country during
the remainder of fiscal 1989
• 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/client relations. This course
includes sections on effective
oral communication, visual
imagery, confrontational
management, and a video
36
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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
• Auditing Superfund
Activities Orientation
During this semiannual reporting
period, we completed plans and
materials for presentation of a
course on auditing the
Superfund The development of
this course, coordinated by the
OIG training specialist, is a
combined effort of all three
primary components of the OIG,
and is scheduled for a pilot
presentation in late spring 1989.
OIG Training Activities
To help OIG supervisors identify
and select appropriate
development opportunities for
their staff, we have updated the
previously developed OIG
Training and Development
Sources Catalog This catalog
lists, describes, and provides
schedules of over 75 courses
that are included in the OIG
computerized career profiles for
auditors, investigators, and
secretaries. The catalog includes
profiles of required or
suggested training for the OIG
staff, and a description of the
new General Accounting Office
"yellow book" requirements for
training. These new 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 any year
These requirements became
effective beginning January 1
1989
Human Resources Council
The OIG Human Resources
Council, 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
Deputy Inspector General
The fourth meeting of the
OIG Human Resources Council
was held December 13 and 14,
1988, in Arlington, Virginia
Council members first reviewed
the HRC's significant
accomplishments during 1988'
• an orientation session for
new OIG employees, held at
Headquarters March 30-31
• training profiles for the OIG
support staff
• a workshop for OIG
secretaries, held in Arlington,
Virginia, December 6-8 Topics
included career development,
computer training, and travel
regulations Highlighting the
workshop was a panel and
discussions on secretarial
initiatives to improve OIG
operations
• a list of recommended
reference material for the OIG
support staff The material was
circulated at the secretarial
workshop
• a proposal to make cash
awards to OIG staff who pass
professional certification exams
(After consideration by OIG
management, the proposal was
rejected )
• a policy which allows ill or
temporarily disabled employees
who are expected eventually to
return to full- or part-time work
and who have used up their
accumulated leave to work out
of their homes. (This proposal
was not approved by OIG
management, who believes
such decisions should be made
on a case-by-case basis )
The HRC then decided to
focus its 1989 efforts in six
areas
• developing a proposal to hold
OIG staff conferences
• preparing an OIG brochure to
aid in recruitment
• exploring the possibility of
creating investigative assistant
and auditing assistant positions
• developing a proposal for
rotating clerical assignments
within the OIG
• examining the Agency's leave
donation program to determine
whether OIG employees are
covered under the Headquarters
or regional programs (or both)
and to decide whether to initiate
a separate OIG program
• developing and instituting a
pilot program in our Boston
office for rewarding deserving
employees in innovative ways
Three projects initiated in
1988 will also be concluded:
• The HRC has developed 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
now plan to distribute the
booklet to all EPA employees
later this spring.
• The HRC has developed
innovative proposals to enhance
the OIG's recruitment efforts
The proposals are currently
under review by OIG
management
• The HRC will complete a
study of who is leaving the
OIG—and why
In the two 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 in
our last report we observed that
many other offices were
developing compressed work
schedules of their own We are
pleased to report that nearly all
EPA Headquarters offices have
now either initiated compressed
work schedules or plan to
initiate such schedules in the
near future Preliminary surveys
throughout Headquarters are
showing a dramatic increase in
morale with no negative impact
on productivity or work quality
The OIG is proud to have been
the vanguard in this important
human resources movement
37
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Western Audit Chief Cited for
Excellence in Management
Truman R. "Ron" Beeler,
Divisional Inspector General for
Audit, Western Division, San
Francisco, received the Lee M
Thomas Award for Excellence in
Management from William K
Reilly, EPA Administrator, in a
ceremony March 21, 1989, at
Constitution Hall in Washington,
D.C. Beeler, one of 11
employees honored, was cited
for having issued 400 audit
reports in fiscal 1988, despite a
reorganization in the
geographically large division,
which covers Regions 8, 9, and
10. Western Division had a
record 84 percent of questioned
costs in external cost audits
sustained by the Agency during
the fiscal year This means that
the Division was responsible for
actual cost savings of $42
million
In addition to Beeler's award,
the staff of Western Division
was also recognized as the
most productive division within
the Office of Audit and for the
highest payoff from external
audits.
EPA Administrator William K. Reilly, left, presents award to
Truman R. Beeler, center, as Inspector General John C. Martin
looks on. (Photo by Steve Delaney)
38
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Section 5 — Delinquent Debts
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
Receivalbe 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 March 31, 1989, the
Claims Officer reported 27
accounts receivable valued at
$2,221,079 For this reporting
period, the Claims Officer
• terminated four debts totaling
$94,491 because of the debtors'
inability to pay,
• referred two debts totaling
$139,436 to the Department of
Justice,
• waived $22,907 of interest on
one debt because the interest
accrued while a regional office
resolved a substantive program
issue,
• compromised a $12,870 debt
for $2,000; and
• returned one debt for
$72,503 to the Financial
Management Division because
the grant appeals process had
not been completed
The OIG 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 October 1, 1988,
through February 28, 1989. (Due
to complications resulting from
the implementation of the
Integrated Financial
Management System, the
Financial Management Division
did not provide data for March
1989.) Although the figures
reflect the Agency's accounting
records as of February 28, 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
16,522,420
78,260
1,098,240
93,107
12,129,418
89,143,577
Subtotal
Interagency Agreements
Total
101,272,9951
2,991,8172
$104,264,812
'Agency records show that 55 percent of this amount is receivables which
are being appealed Collection actions are suspended until the appeals
process is complete
2This amount is for debts owed EPA by other agencies Although these
debts do not have an impact on the U S Treasury, they do impact the
Agency budget Approximately 47 percent of the total in this category is
over 90 days old
39
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Appendix — Audit Reports Issued
THE INSPECTOR GENERAL ACT REQUIRES THE IDENTIFICATION OF EACH AUDIT REPORT COMPLETED OR ISSUED BY THE DIG DURING THE REPORTING
PERIOD THE FOLLOWING LISTING CATEGORIZES AUDIT REPORTS BY TYPE AND REGION
Audit Control Number
Audit ee
Final Report Issued
Audit Control Number
Audit ee
Final Report Issued
1. INTERNAL & MANAGEMENT AUDITS
E1SH'7-02-0216-9100213 SUPERFUND RCRA SAFETY - REGION 2 3/15/89
TOTAL OF REGION 02 = 1
E1XMF8-05-0617-9100123 IMPREST FUND - REGION 5
E1H2D8-05-0293-9100164 NPDES PERMITS - REGION 5
E6AMP9-05-0138-9400017 WASTEFUL SPENDING - REGION 5
TOTAL OF REGION 05 = 3
E1 02*7-09-0110-9100215
RCRA CONSENT AGREEMENT/FINAL
ORDERS CONSOLIDATED REPORT
TOTAL OF REGION 09 = 1
El LMF9-11-0014-9100124
E1K8*8-11-0029-9100148
E1XM*8-11-0047-9100209
E1K6*8-11-0045-9100210
E1BMF9-11-0013-9100219
E1K2*8-11-0026-9100227
FMFIA FY 1988
GRAY MARKET VEHICLES
RCRA CONTRACT MONITORING
STATE AIR PLANS
CONSULTING SERVICES CONTRACTS
PM10 MONITORING PROGRAM
TOTAL OF HDQ - IAD AUDITS = 6
E1HWG9-13-0018-9400024 EPA MONITORING AT DEEPWATER
MUNICIPAL SLUDGE DUMP SITE
TOTAL OF HDQ - SR AUDITS = 1
E1NWF8-15-0021-9100025 NCC ADABAS ENVIRONMENT
SECURITY
E1NWF8-15-0021-9100192 PERMIT COMPLIANCE SYSTEM
TOTAL OF HDQ - ADP AUDITS = 2
TOTAL INTERNAL & MANAGEMENT AUDITS = 14
2. CONSTRUCTION GRANT AUDITS
P2CW6-01-0267-9100089
P2CW*8-01 -0089-9100228
S2CW7-01-0009-9100013
S2CW*8-01 -0218-9100039
S2CW7-01-0013-9100060
COLCHESTER CT
AUBURN SEWERAGE DISTRICT, ME
LANCASTER SEWER DISTRICT MA
BOSTON WATER &
NORTHBOROUGH MA
TOTAL OF REGION 01 = 5
P2CWV-02-0033-9100033 WATERTOWN NY
P2CW7-02-0075-9100037 RENSSELAER CO NY
P2CW7-02-0255-9100038 RENSSELAER CO NY
P2CW7-02-0114-9100088 NASSAU CO NY
P2CW7-02-0032-9100118 AMHERST NY
P2CW6-02-0206-9100119 NASSAU COUNTY NY
P2CW6-02-0056-9100146 RAMSEY NJ
P2CW8-02-0077-9100225 NASSAU CO - FORCE ACCOUNTS NY
TOTAL OF REGION 02 = 8
E2CW*8-03-0175-9100095 PHILADELPHIA CITY OF PA
E2AW*8-03-0200-9400005 PHILADELPHIA CITY OF PA
E2AW8-03-0338-9400008 MOUNT HOPE WV
P2CW*7-03-0079-9100007 ALBION BOROUGH MUN AUTH PA
P2CWV-03-0164-9100041 MONTGOMERY COUNTY PSD VA
P2CW7-03-0242-9100062 ROANOKE CITY OF VA
P2CW*7-03-0081-9100079 WINDSOR TWP AUTHORITY PA
P2CW7-03-0166-9100080 NORTHERN BLAIR SEWER PA
P2CW*7-03-0123-9100142 NEW CASTLE COUNTY/DPW DE
P2CW7-03-0143-9100143 BALTIMORE MAYOR & CTY COUN MD
P2CW*7-03-0109-9100144 DELAWARE CO REG WATER PA
P2CW8-03-0060-9100205 OXFORD BOROUGH OF PA
P2CW8-03-0095-9100222 WSSC MD
P2CW7-03-0207-9100224 MARSHALL TWP MUN AUTH PA
TOTAL OF REGION 03 = 14
E2CWL8-04-0080-9100134
E2CWM8-04-0137-9200005
E2CWN8-04-0042-9300003
P2CWN5-04-0306-9300011
P2CWN8-04-0189-9300021
P2CWN7-04-0130-9300029
P2CWN8-04-0060-9300031
S2CW*7-04-0222-9100015
S2CWN6-04-0302-9300030
FT MYERS FL
GREENVILLE WCRSA SC
ORANGE CO FL
KNOXVILLE TN
DURHAM NC
WINSTON SALEM CITY CO UTIL NC
PRINCETON KY
MOSHEIM TN
MILLINGTON TN
TOTAL OF REGION 04 = 9
D2DWL9-05-0020-9100001
D2DWL9-05-0026-9100036
E2CWM5-05-0277-9200001
E2CWM6-05-0019-9200002
E2CWM6-05-0261 -9200003
E2CWM5-05-0158-9200004
E2AWP9-05-0193-9400016
P2CWN6-05-0346-9300005
P2CWN6-05-0356-9300036
P2CWP6-05-0358-9400002
P2CWP6-05-0381 -9400009
P2CWP6-05-0022-9400013
P2CWP6-05-0179-9400019
P2CWP5-05-0166-9400020
P2CWP6-05-0220-9400021
GRANGER ENG FY 78/87 Ml
GREELEY & HANSEN FY 85 IL
ALBERT LEA MN
BRAINERD MN
FAIRVIEW PARK OH
ANTWERP OH
TUNNEL SAFETY (EWS) OH
MERRILLVILLE CD IN
BUTLER CO OH
PAINESVILLE OH
DELAVAN LAKE SD Wl
FT WAYNE IN
MARION IN
CALHOUN CO Ml
OAKLAND CO Ml
12/22/88
1 /20/89
3/13/89
3/17/89
3/31/89
10/20/88
2/1 5/89
12/13/88
3/31/89
10/13/88
10/26/88
11/15/88
10/26/88
10/26/88
10/26/88
12/13/88
12/21/88
12/21/88
1/10/89
3/29/89
12/29/88
12/13/88
10/24/88
11 /2S/88
2/1 5/89
3/14/89
3/16/89
10/18/88
3/16/89
10/4/88
10/26/88
10/14/88
10/21/88
10/25/88
11 /9/88
3 6/89
10/28/88
3/31/89
11/14/88
1/30/89
3/1/89
3/16/89
3/17/89
3/29/89
P2CWP6-05-0364-9400023 NEORSD CLEVELAND OH
P2CWP6-05-0111-9400026 PONTIAC M
TOTAL OF REGION 05 = 17
E2CWM7-06-0175-9100090 AMARILLO TX
E2CWM7-06-0084-9100165 ESPANOLA NM
P2CWN7-06-0102-9300019 RED RIVER NM
TOTAL OF REGION 06 = 3
E2CWM8-07-0039-9200006 OSCEOLA MO
P2CW6-07-0142-9300023 KANSAS CITY MO
TOTAL OF REGION 07 = 2
P2CW7-08-0016-9300007 DEVILS LAKE CITY OF ND
P2CW7-08-0060-9300009 COLORADO SPRINGS CITY OF CO
TOTAL OF REGION 08 = 2
E2AWP9-09-0048-9400018
E2AWP9-09-0065-9400025
P2CW6-09-0150-9300013
P2CWN9-09-0055-9300014
P2CW*8-09-0027-9300027
S2CW6-09-0055-9100004
S2CW7-09-0012-9100005
S2CW* 7-09-0017-9100006
S2CW5-09-0236-930001 5
S2CW* 7-09-0014-9300026
S2CW7-09-0246-9300033
S2CW8-09-0334-9300035
WEOTT EARLY WARNING CA
HOMELAND EARLY WARNING CA
PIMA COUNTY AZ
PI MA CO AZ
PIMA COUNTY WMD AZ
LOS ANGELES CITY OF CA
BEAUMONT CITY OF CA
SIMI VALLEY CSD CA
SANTA PAULA CITY OF CA
MCFARLAND CITY OF CA
VISTA SANITATION DIST
SACRAMENTO REGIONAL CSD CA
TOTAL OF REGION 09 = 1 2
P2BW7-10-0088-9100003 CH2M HILL INC OR
P2CW*6-10-0103-9300006 OKANOGAN CITY OF WA
P2CWN9-10-0111-9300018 SILVERTON OR
TOTAL OF REGION 10 = 3
TOTAL CONSTRUCTION GRANT AUDITS = 75
3. OTHER GRANT AUDITS
C3EW8-01-0401-9100016
C3HM H9-01 -0017-9500038
C3HM H9-01 -0019-9500055
C3H M H9-01 -0020-9500098
C3HMH9-01-0032-9500104
C3HMH9-01-0021-9500111
C3HMH9-01 -0035-9500127
C3HMH9-01-0033-95001 67
C3HMH9-01-0040-9500206
C3HM H9-01 -0056-9500243
C3HMH9-01-0078-9500274
C3HMH9-01-0082-9500277
C3HMH9-01-0081-9500286
C3HMH9-01-0091-9500287
C3HM H9-01 -0087-9500301
C3HM K9-01 -0088-9500329
C3HM K9-01 -0089-9500330
C3HMK9-01-0090-9500352
C3H M K9-01 -0092-9500367
C3H M K9-01 -0095-9500385
C3HMK9-01-0106-9500409
C3HMK9-01-0110-9500433
C3HMK9-01-0107-9500437
C3H M H9-01 -0083-9500475
C3HMK9-01-0119-9500476
C3HMK9-01-0114-9500480
N3HMH9-01-0027-9500058
N3HMH9-01-0028-9500059
N3HMH9-01-0026-9500072
N3HMH9-01 -0034-9500205
N3HMH9-01-0054-9500232
N3H M H9-01 -0077-9500276
N3H M K9-01 -0097-9500386
N3HMK9-01-0098-9500387
N3HMK9-01 -0099-9500388
N3HMK9-01-0100-9500392
N3HMK9-01-0104-9500434
N3H MH9-01 -0109-9500479
HILLSBOROUGH NH
FALMOUTH MA
ENFIELD NH
WINTHROP MA
ST ALBANS VT
WINTHROP MA
MERIDEN, CT
WHITMAN, MA
JAFFREY, NH
PROCTOR
CLAREMONT, NH
PORTLAND WATER DIST, ME
MATTABASSET DIST CT
WINCHESTER, CT
HANOVER, NH
SHELBURNE FIRE DIST NO 1, VT
MILFORD, CT
WALLINGFORD CT
SUFFIELD, CT
COVENTRY, CT
BERLIN, NH
YARMOUTH, MA
WOLCOTT, CT
MWRA, MA
STONEHAM, MA
HAMPTON, NH
PIONEER VALLEY PLAN COMM MA
ROCKINGHAM PLNG COM NH
INDIAN TOWNSHIP ME
BURLINGTON VT
BRIDGEPORT CT
BARNSTABLE, MA
MACHIAS, ME
STRAFFORD REG PLAN COMM, NH
WARWICK, Rl
WATERBURY, CT
COMMONWEALTH OF
MASSACHUSETTS
NANTUCKET, MA
TOTAL OF REGION 01 = 38
C3HMK9-02-0052-9500065
C3HMK9-02-0053-9500066
C3H M K9-02-0034-9500069
C3H M J9-02-0024-9500076
C3HMK9-02-0051-9500077
C3HMK9-02-0056-9500078
C3HMK9-02-0060-9500110
C3HMK9-02-0067-9500133
C3HMK9-02-0073-9500165
C3HMK9-02-007 4-9500166
C3H M K9-02-0080-9500198
C3HMK9-02-0076-9500199
C3HMK9-02-0078-9500200
MIDDLETON NY
HORNELL NY
LIBERTY NY
INTERSTATE SAN COMM NY
MIDDLETON NY
NO ARLINGTON-LYNDHURST JT NJ
CLARENCE NY
FRANKLINVILLE, NY
LOVE CANAL NY
GOWANDA, VILLAGE OF NY
CASTLETON ON HUDSON, NY
BERGEN, NY
BERGEN NY
3'30/89
3'31'89
12/13/88
1 23/89
1 '25/89
1/5/89
2/22/89
11/16/88
11/21/88
3,16/89
3/31/89
12/13/88
12,20/88
3/9/89
10/12/88
10/12/88
10/12/88
12/21/88
3/6/89
3/23/89
3/31/89
10/12/88
10/17/88
10/26/88
11/7/88
11 /7/88
11/14/88
11/17/88
12/1/88
12/15/88
12/30/88
1/17/89
1/17/89
1 n 8'89
1/18/89
1/20/89
1/31/89
1/31/89
2/7/89
2/9/89
2/1 5/89
2/23/89
3/2/89
3/3/89
3/22/89
3/22/89
3/23/89
10/26/88
10/26/88
10/28/88
12/15/88
12/23/88
1/17/89
2/1 5/89
2/16/89
2/16/89
2/16/89
3/2/89
3/23/89
10/28/88
10/28/88
10/28/88
10/28/88
10/28/88
10/31/88
11/14/88
11/21/88
11 /30/88
11/30/88
12/13/88
12/13/88
12/13/88
40
-------
Audit Control Number
Auditee
Final Report Issued
Audit Control Number
Auditee
Final Report Issued
C3HM K9-02-0082-9500201
C3HMK9-02-0084-9500224
C3HMK9-02-0086-9500225
C3HMK9-02-0088-9500226
C3HMK9-02-0090-9500233
C3HMK9-02-0092-9500235
C3HMK9-02-0094-9500239
C3H M K9-02-0096-9500240
C3HMK9-02-0098-9500265
C3H M K9-02-0100-9500266
C3HMK9-02-0102-9500267
C3HMK9-02-0117-9500283
C3HMK9-02-0139-9500285
C3HMK9-02-01 57-9500294
C3HMK9-02-0152-9500307
C3HMK9-02-0160-9500310
C3HMK9-02-0161-9500340
C3H M K9-02-0171 -9500368
C3HMK9-02-0173-9500369
C3HMK9-02-0188-9500389
C3HMK9-02-0190-9500391
C3HMK9-02-0191-9500396
C3HMK9-02-0199-9500399
C3HMK9-02-0203-9500423
C3HMK9-02-0206-9500449
C3HMK9-02-0207-9500450
D3 D M L9-02-0071 -9100092
D3EMN9-02-0068-9300024
D3EMN9-02-0069-9300025
N3H M K9-02-0032-9500067
N3HMJ9-02-0033-9500068
N3H M K9-02-0008-9500073
N3H M K9-02-0009-9500074
N3HMK9-02-0010-9500075
N3HMK9-02-0059-9500105
N3 H M K9-02-0058-9500106
N3HMK9-02-0057-9500107
N3HMK9-02-0062-9500118
N3HMK9-02-0064-9500119
N3HMK9-02-0089-9500227
N3HMK9-02-0138-9500268
N3HMK9-02-0147-9500269
N3H M K9-02-0154-9500284
N3HMK9-02-0153-9500293
N3H M K9-02-0169-9500343
N3HMK9-02-0170-9500344
N3HMK9-02-0172-9500366
N3HMK9-02-0185-9500372
N3HMK9-02-0186-9500373
N3HMK9-02-0187-9500374
N3HMK9-02-0189-9500390
N3HMK9-02-0193-9500394
N3HMK9-02-0194-9500395
N3H M K9-02-0200-9500398
N3H M K9-02-0204-9500424
N3H M K9-02-0205-9500439
N3HMK9-02-0210-9500451
CASTLETON ON HUDSON NY
NEW BALTIMORE, NY
PORT HENRY, NY
WILSON, NY
CARMELTOWN OF NY
DELAWARE RIVER BASIN COMM NJ
WAWARSING, TOWN OF NY
WAWARSING TOWN OF NY
CATSKILL. NY
NEW WINDSOR, NY
ALEXANDER, NY
HIGHLANDS, NY
WEBSTER, NY
WHEATFIELD NY
HUDSON REG HEALTH COMM, NJ
FALLSBURG, NY
BINGHAMTON, NY
LEWISTON, NY
OCEAN, NJ
ROCKAWAY VALLEY REG SA, NJ
ATTICA, NY
HAMILTON, NY
HAMBURG, NY
BATAVIA, NY
PAWLING JT SEWER COMM, NY
TRI-MUNICIPAL SEWER COMM, NY
BURNS & ROE INDUSTRIAL NJ
ECOLOGY AND ENVIRONMENT, NY
ECOLOGY AND ENVIRONMENT, NY
ROME NY
CENT NY REG PLNG BD NY
MONROE CNTY NY
ERIE CNTY NY
CHEMUNG CNTY NY
ERIE & NIAGARA REG PLAN NY
YORKTOWN NY
FULTON NY
SARANAC LAKE NY
GLEN COVE, NY
WATERFORD NY
CHEMUNG CNTY NY
NORTH GREENBUSH, NY
HAMILTON, NJ
SCHAGHTICOKE, NY
LIBERTY, NY
NORTH GREENBUSH, NY
NORTH TONAWANDA, NY
ONONDAGA COUNTY NY
SUFFOLK COUNTY, NY
ERIE COUNTY, NY
PERU, NY
PR DEPT OF AGRICULTURE, PR
WESTCHESTER COUNTY, NY
ALBANY, NY
TICONDEROGA, NY
ONEIDA COUNTY, NY
MASSENA, NY
TOTAL OF REGION 02 = 70
C3HMK9-03-0022-9500028
C3H M K9-03-0024-9500030
C3HMK9-03-0043-9500081
C3HMK9-03-0048-9500122
C3HMK9-03-0049-9500123
C3HM J9-03-0047-9500126
C3HMK9-03-0061 -9500197
C3HM K9-03-0078-9500217
C3HMK9-03-0079-9500218
C3HMK9-03-0105-9500275
C3HMK9-03-0114-9500305
C3HMK9-03-0115-9500306
C3HMK9-03-0117-9500327
C3HMK9-03-0127-9500348
C3HMK9-03-0128-9500349
C3HMK9-03-0129-9500350
C3HMK9-03-0130-9500365
C3HMK9-03-0134-9500380
C3HMK9-03-0136-9500393
C3HMK9-03-0137-9500406
C3HMK9-03-0138-9500407
C3HMK9-03-0139-9500408
C3HMK9-03-0140-9500429
C3HMK9-03-0141-9500452
C3HMK9-03-0159-9500503
C3H M K9-03-0160-9500504
C3H M K9-03-0161 -9500505
N3HMJ9-03-0025-9500021
N3HMJ9-03-0026-9500022
N3HMK9-03-0027-9500023
N3HUJ9-03-0021 -9500027
N3HMK9-03-0023-9500029
N3HMK9-03-0042-9500080
N3HMK9-03-0045-9500117
N3HMK9-03-0056-9500140
N3H MK9-03-0059-9500192
N3HUK9-03-0060-9500193
N3H M K9-03-0071-9500214
N3H M J9-03-0080-9500219
N3H M J9-03-0086-9500237
12/13/88
12/22/88
12/22/88
12 22'88
12,28/88
1228/88
12/29/88
12,29'88
1 11 '89
1 11,89
1/11/89
1/18/89
1 18/89
1 '19/89
1/25/89
1/26/89
2/2,89
2/13/89
2,1 3/89
2,16/89
2,1 6/89
2,1 7/89
2/21/89
2 28/89
3,7'89
3'7/89
12 13/88
12,'13'88
12/13'88
10,28/88
10/28/88
10/28'88
10/28/88
10/28/88
11/9'88
11 /9/88
11/10/88
11,16/88
11' 16/88
12/22/88
1/11 ,'89
1,11 ,'89
1 18/89
1/19/89
2/6/89
2/6/89
2/9/89
2/14/89
2/14/89
2,14/89
2/16/89
2/16/89
2/16'89
2/21/89
2/28/89
3/6/89
3/7/89
N3H MJ9-03-0087-9500238
N3H M K9-03-0094-9500264
N3HMK9-03-0116-9500328
N3HMK9-03-0131 -9500378
N3H M K9-03-0135-9500381
N3HUK9-03-01 50-9500482
N3H MK9-03-0155-9500502
P3CS*8-03-0094-9100100
DELAWARE STATE OF FYE 6/87 DE
ABERDEEN TOWN OF FYE 6/88 MD
ALLEGHENY COUNTY CYE 12/87 PA
BERLIN, TOWN OF FYE 6/85 MD
HOWARD COUNTY FYE 6/87 MD
BALTIMORE, CITY OF MD
LEHIGH UNIVERSITY PA
SOMERSET COUNTY FYE 6/85 MD
ASTSWMO ALAPCO & STAPPA
TOTAL OF REGION 03 = 49
PRESTON COMM OF FYE 6/88 MD 10/18/88
EARL TOWNSHIP FYE 6/88 PA 10/18/88
SPRINGETTSBURY SEWER AUTH PA 11/1/88
HURLOCK MYR & COUN FYE 6/88 MD 11/16/88
MONTROSE MUNICIPAL AUTH PA 11/16/88
VA DEPT WASTE MGMT FYE 6/87 VA 11/17/88
SUSQUEHANNA RIVER FYE 6/88 PA 12/12/88
SOLANCO SCHOOL FYE 6/88 PA 12/20/88
DUPONT BOROUGH OF FYE 6/88 PA 12/20/88
GARRETT COUNTY FYE 6/86 MD 1,17/89
BRUNSWICK TOWN OF FYE 6/88 MD 1,25/89
LEESBURG TOWN OF FYE 6/88 VA 1,25/89
ST MARY CO METRO FYE 6/88 MD 1,30/89
SOUTH LONDONDERRY TWP PA 2/7/89
UPPER GWYNEDD-TOWAMENCIN PA 2/7/89
HAVRE DE GRACE CITY OF MD 2/7/89
DE RIVER BASIN FYE 6/88 DE 2/9/89
MILFORD, CITY OF FYE 6/88 DE 2/15/89
GARRETT COUNTY COMMISSION MD 2/16/89
N&S SHENANGO JOINT MUN 86 PA 2/22/89
HARBORCREEK TWP SEWER PA 2/22/89
GARRETT COUNTY COMMISSION MD 2/22/89
HAZLETON CITY AUTHORITY PA 3/1/89
EASTON UTILITIES COMMISSION MD 3/8/89
BUTLER TOWNSHIP CYE 12/87 PA 3/30/89
WASHINGTON SUB SANITARY MD 3/30/89
DOVER CITY OF DE 3/30/89
EPA COMMONWEALTH OF FYE 6/87 PA 10/18/88
PA COMMONWEALTH OF FYE 6/86 PA 10/18/88
CAPE CHARLES, TOWN FYE 6/87 VA 10/18/88
VA POLYTECHNIC FYE 6/87 VA 10/18/88
ERIE COUNTY FYE 12/85 PA 10/18/88
FREDERICK CO FYE 6/87 MD 11/1/88
WILMINGTON CITY OF FYE 6/87 DE 11/16/88
KENT CO LEVY COURT FYE 6/87 DE 11/23/88
RICHMOND CITY OF FYE 6/87 VA 12/9/88
DREXEL UNIVERSITY FYE/87 PA 12/9/88
WESTMINSTER CITY FYE 6/88 MD 12/19/88
VA-DEPT ARC & CONSMR 6/87 VA 12/20/88
VA DEPT EMERGENCY FYE 6/87 VA 12/29/88
C3HMK8-04-0413-9500010
C3HWK8-04-0431 -9500012
C3HWK8-04-0435-9500018
C3HWK8-04-0432-9500025
C3HWK8-04-0423-9500026
C3HWK9-04-0060-9500162
C3HWK9-04-0087-9500163
C3HWK9-04-0059-9500168
C3HWK9-04-0074-9500169
C3HWK9-04-0103-9500242
C3HWK9-04-0105-9500251
C3HWK9-04-0114-9500282
C3HWK9-04-0117-9500321
C3HWK9-04-0121-9500326
C3HWK9-04-0118-9500360
C3HWK9-04-0131-9500361
C3HWK9-04-0130-9500377
C3HWK9-04-0139-9500425
C3HWK9-04-0152-9500438
C3HWK9-04-01 51-9500461
C3H M K9-04-0153-9500462
C3HWK9-04-0154-9500463
C3HWK9-04-0165-9500481
C3HWK9-04-0168-9500512
E3BW*8-04-0333-9100170
H3AML9-04-0134-9100202
H3AML9-04-0135-9100206
N3HMK9-04-0022-9500084
N3H U K9-04-0050-9500109
N3HUJ9-04-0062-9500112
N3HWK9-04-0058-9500114
N3HUK9-04-0052-9500115
N3HWK9-04-0051-9500121
N3HPJ9-04-0063-9500124
N3HWK9-04-0061 -95001 25
N3H U K9-04-0067-9500139
N3H U K9-04-0068-9500144
N3HAK9-04-0070-9500161
N3HMJ9-04-0088-9500179
N3HMJ9-04-0090-9500180
N3HWK9-04-0073-9500181
N3HMK9-04-0089-9500182
N3HMJ9-04-0104-9500244
N3HWK9-04-0102-9500245
N3HUK9-04-0107-9500254
N3HUK9-Q4-0109-9500258
N3HWK9-04-0108-9500259
N3HMK9-04-0106-9500260
N3HSJ9-04-0119-9500317
N3HUJ9-04-0122-9500319
N3HWK9-04-0120-9500331
N3H WJ9-04-0144-9500410
N3HMK9-04-0141-9500411
N3HUJ9-04-0142-9500412
N3HMJ9-04-0143-9500415
N3HAK9-04-0156-9500456
N3HWK9-04-0155-9500457
N3HUK9-04-0163-9500509
N3HUK9-04-0164-9500510
N3HUJ9-04-0166-9500511
TOTAL
C3HMK8-05-0603-9500003
C3HMJ8-05-0614-9500004
C3HMJ8-05-0611-9500005
C3HMJ8-05-0606-9500006
C3HMK8-05-0612-9500007
C3HMJ8-05-0613-9500008
C3HMJ8-05-0607-9500009
C3HMK8-05-0616-9500014
C3HMJ8-05-0609-9500015
C3HMK8-05-0618-9500036
C3HMJ8-05-0631 -9500037
C3H M J8-05-0639-9500039
C3HMJ8-05-0640-9500040
C3HMK8-05-0637-9500041
C3HMJ8-05-0638-9500042
C3HMJ8-05-0636-9500043
C3HMJ8-05-0621-9500044
C3HMJ8-05-0623-9500049
C3HMK8-05-0628-9500050
C3HMJ8-05-0629-9500051
C3HMK8-05-0633-9500052
C3HMJ9-05-0021-9500063
C3HMJ9-05-0022-9500071
C3HMK9-05-0024-9500085
C3HMK9-05-0027-9500086
C3HMJ9-05-0056-9500093
FT LAUDERDALE FL
JASPER UTIL BOARD AL
FOUNTAIN RUN WATER DIST KY
FOUNTAIN RUN WATER DIST KY
JACKSONVILLE, FL
COVINGTON GA
ANNISTON WWSB, AL
CARROLLTON GA
KISSIMMEE FL
WALTERBORO SC
ARAB AL
THOMASVILLE GA
LUDOWICI GA
OKEECHOBEE FL
MIDDLESBOROUGH KY
DALTON WATERTIGHT & SINK GA
ROCK HILL SC
LIBERTY, NC
GRAND STRAND WSA SC
CENTERTOWN KY
MONTGOMERY COUNTY AL
FLOWOOD MS
ALLIGATOR MS
JASPER, GA
R4 REVIEW 205G SC
RESEARCH TRIANGLE PARK NC
RESEARCH TRIANGLE INST NC
HUNTSVILLE AL
SOUTH ALABAMA UNIVERSITY, AL
EAST CAROLINA UNIVERSITY NC
CUMBERLAND COUNTY, NC
EMORY UNIVERSITY GA
ATLANTA REGIONAL COMMISSION GA
AL DEPT AGRICULTURE & IND AL
JACKSON MS
DUKE UNIVERSITY NC
KENTUCKY UNIVERSITY OF, KY
BUNCOMBE COUNTY NC
SC DEPT OF HEALTH & ENV SC
SC DEPT HEALTH & ENV CONT ,SC
PASCO COUNTY FL
PINELLAS COUNTY, FL
KENTUCKY, STATE OF KY
EASTERN BAND CHEROKEE IND TN
WESTERN KENTUCKY UNIV KY
WESTERN KENTUCKY UNIV KY
CRAVEN COUNTY NC
BROWARD COUNTY FL
SULLIVAN COUNTY TN
JACKSON STATE UNIVERSITY MS
WAYCROSS GA
RICHLAND COUNTY SC
MISSISSIPPI, STATE OF MS
NC UNIVERSITY. CHAPEL HILL, NC
FLORIDA STATE OF FL
KNOX COUNTY TN
LEITCHFIELD KY
SUMTER AREA TECHNICAL COLLE, SC
SUMTER AREA TECHNICAL COL, SC
MISSISSIPPI MEDICAL CTR , MS
OF REGION 04 = 60
ODIN FY 88 IL
VALPARAISO FY 87 IN
SOUTHWEST LSD FY 87 OH
ELWOOD FY 87 IN
WARREN LSD FY 87 OH
OTSECO LSD FY 87 OH
MICHIGAN CITY FY 87 IN
CALEDONIA FY 87 MN
LOUDON/PERRYVILLE VSD FY 87 OH
CUYAHOGA FALLS FY 87 OH
GREENCASTLE FY 87 IN
ASHTABULA ACSD FY 87 OH
WILLARD CSD FY 87 OH
OAKLAND FY 87 IN
MADISON LSD FY 87 OH
CANAL WINCHESTER FY 87 OH
SCHERERVILLE FY 87 IN
NAPPANEE FY 87 IN
BROWNSBURG FY 87 IN
PLYMOUTH FY 87 IN
ADDISON FY 88 IL
LAPORTE FY 87 IN
HOWLAND LSD FY 87 OH
BRIGHTON FY 88 MN
ELMHURSTFY88 IL
WILLOUGHBY FY 87 OH
10/12/88
10/13/88
10/13/88
10/18/88
10/18/88
11/30/88
11 ,'30/88
12/1 '88
12/1/88
12/30/88
1/9/89
1/18/89
1/27'89
1 '30/89
2/9/89
2/9/89
2/15/89
3/1 /89
3/3/89
3/10/89
3/10'89
3/10/89
3/23/89
3/31'89
1/26/89
3/3/89
3/7/89
11,' 2/88
11/10/88
11'16/88
11/16/88
11 /16/88
11/16/88
11/17/88
11/17/88
11/23/88
11/23/88
11 /30/88
12/5/88
12/5/88
12/5/88
12,' 5/88
1/3/89
1 /3/89
1 /9/89
1 '9/89
1 /9/89
1/9/89
1/26/89
1/26/89
1/31/89
2/23/89
2/23/89
2/23/89
2/24/89
3i 9/89
3/9/89
3/31/89
3/31/89
3/31/89
10/5/88
10/11/88
10/12/88
10/12/88
10/12/88
10/12/88
10/12/88
10/14/88
10/14/88
10/19/88
10/19/88
10/21/88
10/21/88
10/21/88
10/21/88
10/21/88
10/21/88
10/25/88
10/25/88
10/25/88
10/25/88
10/27/88
10/28/88
11/2/88
11 ,/2/88
11/3/88
41
-------
Audit Control Number
Auditee
Final Report Issued
Audit Control Number
Auditee
Final Report Issued
C3H M K9-05-0058-9500094
C3HMK9-05-0060-9500096
C3HMK9-05-0092-9500129
C3HMK9-05-0088-9500130
C3H M K9-05-0090-9500131
C3HMK9-05-0093-9500132
C3HMJ9-05-0094-9500136
C3HMK9-05-0096-9500137
C3HM K9-05-0098-9500138
C3HMK9-05-0100-9500152
C3HMK9-05-0101-9500153
C3HMK9-05-0107-9500157
C3HMK9-05-0103-9500158
C3HMK9-05-0108-9500159
C3HMK9-05-0110-9500160
C3HMK9-05-0122-9500172
C3HMK9-05-0113-9500174
C3HMK9-05-0117-9500176
C3HMJ9-05-0124-9500177
C3HMJ9-05-0123-9500183
C3HMJ9-05-0119-9500184
C3HMK9-05-0091-9500207
C3HMJ9-05-0120-9500208
C3HMK9-05-0121-9500209
C3H M K9-05-0059-9500210
C3HMK9-05-0118-9500212
C3HMK9-05-0109-9500222
C3H M K9-05-0133-9500223
C3H M K9-05-0136-9500228
C3H M K9-05-0134-9500229
C3HMK9-05-0139-9500236
C3H M K9-05-0140-9500241
C3HMK9-05-0160-9500255
C3 H M K9-05-0164-95002 56
C3H M K9-05-0135-9500270
C3HMJ9-05-0163-9500271
C3H M K9-05-0167-9500288
C3HM J9-05-0173-9500302
C3H M K9-05-0168-9500303
C3HMK9-05-0176-9500308
C3HMK9-05-0179-9500309
C3HMK9-05-0182-9500345
C3HMJ9-05-0185-9500346
C3HMK9-05-0181-9500351
C3HMK9-05-0183-9500353
C3HMJ9-05-0195-9500364
C3H M K9-05-0194-9500414
C3HM K9-05-0166-9500417
C3HMK9-05-0169-9500418
C3HMK9-05-0208-9500426
C3HMJ9-05-0210-9500427
C3HMK9-05-0211-9500428
C3H M K9-05-0212-9500435
C3HMJ9-05-0214-9500436
C3HMJ9-05-0223-9500443
C3HMJ9-05-0220-9500444
C3HMJ9-05-0229-9500446
C3HMJ9-05-0231 -9500447
C3HMJ9-05-0230-9500448
C3HMJ9-05-0226-9500466
C3HMJ9-05-0239-9500473
C3HMJ9-05-0240-9500478
C3HMK9-05-0241-9500483
C3HMJ9-05-0244-9500485
N3H MJ8-05-0222-9500002
N3H M K8-05-0562-9500033
N3HMJ8-05-0425-9500034
N3HMJ8-05-0549-9500035
N3HMJ8-05-0619-9500053
N3HMJ8-05-0600-9500061
N3H M K8-05-0497-9500062
N3H M K8-05-0565-9500070
N3HMJ8-05-0620-9500171
N3HMK8-05-0108-9500173
N3HMK9-05-0028-9500175
N3HMJ8-05-0641-9500185
N3HMJ8-05-0153-9500231
N3H MJ9-05-0055-9500234
N3H M K9-05-0099-9500246
N3HMK9-05-0159-9500273
N3H M K9-05-0155-9500289
N3HMK9-05-0156-9500299
N3HMK9-05-0157-9500300
N3HMK8-05-0598-9500335
N3HMJ9-05-0174-9500336
N3HMK9-05-0186-9500347
N3HMK9-05-0105-9500357
N3H M K8-05-0604-9500358
N3HMJ9-05-0171-9500359
N3HMK9-05-0089-9500397
N3HMK7-05-0755-9500441
N3HMJ9-05-0219-9500442
N3HMJ9-05-0221-9500445
N3HMK9-05-0191 -9500453
N3HMK9-05-0158-9500454
N3H M K9-05-0218-9500455
N3H M K9-05-0192-9500458
N3H M K9-05-0236-9500472
N3HMJ8-05-0627-9500474
BARBERTONFY870H 11/3/88
THORN CREEK SD FY 88 IL 11,4/88
CAIRO FY 88 IL 11/18/88
BERRIEN CO FY 86 Ml 11/18/88
OTTAWA CO FY 87 Ml 11/18/88
SAG IN AW CO FY 87 Ml 11/18/88
CARMEL FY 87 IN 11/22/88
FLUSHING FY 87 Ml 11/22/88
SALINE FY 88 Ml 11/23/88
HOMEWOOD FY 88 IL 11/28/88
SALEM FY 88 IL 11/28/88
ROCKFORD SD FY 86 IL 11/29/88
IMLAY CITY FY 88 Ml 11/29/88
LORAINFY860H 11/30/88
PEKIN FY 88 IL 11/30/88
FARMER CITY FY 88 IL 12/2/88
MT CLEMENS FY 88 Ml 12/2/88
WORTH FY 88 IL 12/5/88
CHESTERTON FY 87 IN 12/5/88
PLAINFIELD FY 87 IN 12/6/88
CLARKSVILLE FY 87 IN 12/6/88
DECATUR SD FY 88 IL 12/16/88
BRAZIL FY 87 IN 12/16/88
WAMACFY88IL 12/16/88
NEORSDFY870H 12/16/88
KENT CO FY 87 Ml 12/16/88
SAGINAW TWP FY 88 Ml 12/21/88
VIRGINIA FY 87 MN 12/21/88
BEMENTFY88IL 12/22/88
GENESEO FY88 IL 12/22/88
ELYRIA FY 87 OH 12/28/88
DEKALB SD FY 88 IL 12/29/88
CLEVELAND CSD FY 87 OH 1/9/89
ROCKY RIVER FY 87 OH 1/9/89
KEWANEE FY88 IL 1/13/89
RICHMOND FY87 IN 1/13/89
MSD CHICAGO FY 87 IL 1/19/89
FALL CREEK BSD FY 87 IN 1/20/89
RICHMOND FY 88 Ml 1/20/89
MENAHGA FY 87 MN 1/25/89
GREENVILLE FY 87 OH 1/25/89
MOKENA FY 88 IL 2/7/89
ASHLEY FY 87 IN 2/7/89
ROCKY RIVER FY 87 OH 2/7/89
LOWELL FY 88 Ml 2/7/89
FT BRANCH FY 86/87 IN 2/9/89
RACINE FY 87 Wl 2/23/89
AKRON FY 87 OH 2/24/89
KALAMAZOO FY 87 Ml 2/27/89
GAYLORD FY 87 MN 3/1/89
ALLEN CO RSD FY 87 IN 3/1/89
GLENWOOD FY 87 MN 3/1/89
CLEAR LAKE FY 87 Wl 3/3/89
FLORA FY 86/87/88 IN 3/3/89
BRINGHURST RSD FY 86/87 IN 3/6/89
CYNTHIANA FY 87 IN 3/6/89
PAD LI FY 87 IN 3/7/89
SIDNEY CSD FY 88 OH 3/7/89
SYLVAN IA CSD FY 88 OH 3/7/89
MANSFIELD FY 87 OH 3/15/89
ETNA GREEN FY 87 IN 3/22/89
DANVILLE FY 86/87 IN 3/22/89
W CHICAGO FY 88 IL 3/23/89
WINGATE FY 86/87 IN 3/23/89
MONTGOMERY CO FY 85 OH 10/5/88
DETROIT FY 87 Ml 10/19/88
PURDUE U FY 87 IN 10/19/88
RICHMOND FY 86 IN 10/19/88
ALEXANDRIA FY 87 IN 10/25/88
WASHINGTON CO FY 86 MN 10/27/88
DELAWARE FY 87 OH 10/27/88
SIU CARBONDALE FY 86/87 IL 10/28/88
WASHINGTON CO FY 87 MN 12/2/88
BLACKDUCK FY 86 MN 12/2/88
EAU CLAIRE FY 87 Wl 12/5/88
MUNCIEFY87IN 12/6/88
E CHICAGO FY 86 IN 12/22/88
SIDNEY FY 86 OH 12/28/88
MT PROSPECT FY 88 IL 1/5/89
MOLINEFY88IL 1/17/89
DANE CO RPC FY 84/85 Wl 1/19/89
DANE CO RPC FY 86 Wl 1/19/89
DANE CO RPC FY 87 Wl 1/19/89
HAMILTON FY 85 OH 2/1/89
BLOOMINGTON FY 87 IN 2/1/89
MARQUETTE CO FY 87 Ml 2/7/89
CARBONDALE FY 88 IL 2/8/89
DUPAGE CO FY 87 IL 2/8/89
GARY FY 87 IN 2/8/89
WHITE EARTH RESERV FY 87 MN 2/17/89
DE PERE FY 86 Wl 3/ 6/89
MICHIGAN DOA FY 85/86 Ml 3/3/89
INDIANA ST U FY 88 IN 3/7/89
M AGO MB CO FY 87 Ml 3/8/89
OAKLAND CO FY 87 Ml 3/8/89
WASHTENAW CO FY 86 Ml 3/8/89
CHICAGO FY 87 IL 3/9/89
WARREN FY 87 OH 3/20/89
PORTAGE FY 87 IN 3/22/89
N3HMJ9-05-0213-9500477 TELL CITY FY 87 IN
N3HMK8-05-0378-9500506 MOLINE FY 87 IN
N3HMJ9-05-0196-9500507 DAYTON FY 87 OH
N3HMJ9-05-0235-9500508 INDIANA BOH FY 87 IN
TOTAL OF REGION 05 = 129
C3HMK9-06-0015-9500001
C3HMK8-06-0250-9500011
C3H M K8-06-0260-9500020
C3HWK8-06-0255-9500024
C3HMK9-06-0020-9500045
C3H M K9-06-002 5-9500054
C3HMK9-06-0029-9500056
C3HMK9-06-0026-9500057
C3HMK9-06-0024-9500060
C3HWK9-06-0019-9500083
C3HWK9-06-0060-9500095
C3HMK9-06-0036-9500097
C3HMK9-06-0045-9500134
C3HWK9-06-0261 -9500156
C3HWK9-06-0056-9500247
C3HWK9-06-0063-9500298
C3HWK9-06-0065-9500304
C3HWK9-06-0059-9500318
C3HWK9-06-0064-9500333
C3HWK9-06-0071 -9500334
C3HWK9-06-0076-9500370
C3HWK9-06-0078-9500375
C3HWK9-0 6-0083-9500465
C3HWK9-06-0088-9500495
D3CAL9-06-0062-9100173
D3AAL9-06-0075-9100184
D3AG L9-06-0041 -9100188
D3AH L9-06-0040-9100189
N3HWK9-06-0039-9500116
N3HWK9-06-0044-9500143
N3HWK9-06-0038-9500145
N3HWK9-06-0049-9500252
N3H M K9-06-0050-9500253
N3HWK9-06-0087-9500494
SAN MARCOS TX
SAN ANTONIO, TX
NORMAN, OK
CLAREMORE OK
KENNER LA
TEXARKANA TX
JOAQUIN TX
TEXARKANA TX
SHERIDAN WATER & SEWER AR
KENNER LA
CISCO TX
NORTH LITTLE ROCK, AR
ARKANSAS DEPT OF POLLUTION AR
CALERA OK
FARWELL TX
ROCKPORT TX
WILLS POINT TX
NORMAN OK
EDINBURGTX
CRESCENT PUBLIC WORK AUTHOR, OK
GARLAND TX
EL PASO WCID NO 4 TX
EL PASO PSB TX
ORANGE COUNTY WCID NO 2 TX
SOUTHWEST RESEARCH INSTITUT TX
RADIAN CORPORATION TX
RADIAN CORPORATION TX
JOHN ZINK COMPANY ESD, OK
BEAUMONT TX
FARMERVILLE LA
BATON ROUGE E BATON PARISH LA
LOWER RIO GRANDE VAL DEV CO, TX
SPRINGDALE AR
FORT WORTH TX
TOTAL OF REGION 06 = 34
C3HM K9-07-0015-9500013
C3HMK9-07-0016-9500016
C3HMK9-07-0018-9500032
C3HMK9-07-0019-9500046
C3HWK9-07-0027-9500087
C3HWK9-07-0029-9500099
C3HMK9-07-0028-9500108
C3HMK9-07-0033-9500120
C3HMK9-07-0037-9500135
C3H M K9-07-0038-9500154
C3HWK9-07-0046-9500186
C3HWK9-07-0047-9500202
C3HWK9-07-0048-9500203
C3HWK9-07-0049-9500204
C3HWK9-07-0056-9500296
C3HWK9-07-0055-9500297
C3HWK9-07-0060-9500311
C3HWK9-07-0057-9500332
C3HWK9-07-0065-9500341
C3HWK9-07-0066-9500342
C3HWK9-07-0063-9500362
C3HWK9-07-0068-9500363
C3HWK9-07-0069-9500371
C3HWK9-07-0064-9500376
C3HWK9-07-0070-9500416
C3HWK9-07-0074-9500459
C3HWK9-07-0075-9500460
D3AG L9-07-0050-9100191
N3HUJ9-07-0030-9500113
N3HAK9-07-0031-9500141
N3HWK9-07-0032-9500142
N3HUJ9-07-0036-9500164
N3HWK9-07-0041 -9500170
N3HWK9-07-0040-9500178
N3H PK9-07-0042-9500220
N3HMJ9-07-0073-9500464
REPUBLIC MO
REPUBLIC MO
GREENFIELD MO
OSAGE BEACH MO
BONNETERRE MO
CAMERON MO
CEDAR RAPIDS IA
AURORA MO
BONNER SPRINGS KS
ARKANSAS CITY KS
DECORAH IA
ELKHART KS
FOREST CITY IA
FREDERICKTOWN Ml
CREIGHTON NE
CREIGHTON NB
RICHMOND MO
CHILLICOTHE MO
STORM LAKE IA
STORM LAKE IA
CENTRALIA MO
BEATRICE BOARD PUBLIC WORKS, NB
BRANSON MO
CENTRALIA MO
CENTER MO
O'FALLON MO
O'FALLON MO
DPRA INCORPORATED KS
KIRKWOOD COMM COLLEGE IA
LINN COUNTY IA
CABOOL MO
EASTERN IOWA COMM COLLEGE IA
COLUMBIA MO
BOYDEN IA
MO DEPT OF AGRICULTURE MO
MISSOURI,STATE OF MO
TOTAL OF REGION 07 = 36
3/22/89
3/30/89
3/30/89
3/30/89
10/4/88
10/13/88
10/13/88
10/18/88
10/24/88
10/26/88
10/26/88
10/26/88
10/27/88
11/2/88
11/3/88
11 /4/88
11/21/88
11/29/88
1/5/89
1/19/89
1 /24/S9
1/26/89
1/31/89
1/31/89
2/13/89
2/14/89
3/14/89
3/29/89
2/7/89
2/10/89
11/17/88
11 /16/88
11'16/88
11 /23/8S
11 /23/8S
1/9/89
1/9/89
3/29/89
10/14/88
10/14/88
10/19/88
10/24/88
11/1/88
11/7/88
11 /10/88
11 /16/88
11/21/88
11729/88
12/8/88
12/14/88
12/14/88
12/15/88
1/19/89
1/19/89
1726/89
1/31/89
2/2/89
2/2/89
2/9/89
2/9/89
2/13/89
2/15/89
2/24/89
3/9/89
3/10/89
1/3/89
11/16/88
11/23/88
11/23/88
11730/88
12/1/88
127 5/88
12/21/88
3710/89
C3HMJ9-08-0012-9500211
C3HMJ9-08-0013-9500213
C3HMK9-08-0015-9500221
C3HMK9-08-0023-9500281
C3HMK9-08-0025-9500292
C3HMK9-08-0032-9500320
C3H M K9-08-0033-950032 5
C3HMK9-08-0034-9500337
C3H M K9-08-0040-9500382
C3HMK9-08-0041-9500401
C3H M K9-08-0044-9500404
C3H M K9-08-0055-9500514
C3H M K9-08-0056-9500515
N3H M K9-08-0001-9500082
N3HMJ9-08-0003-9500088
N3HUJ9-08-0002-9500090
N3H M K9-08-0004-9500092
N3HMJ9-08-0007-9500101
N3HUJ9-08-0006-9500102
N3H M K9-08-0005-9500103
HITCHCOCK CITY OF SD 12/16/88
FAULKTON CITY OF SD 12/16/88
MINOT CITY OF ND 12721/88
GILLETTE CITY OF WY 1/17/89
THOMPSON FALLS, TOWN OF MT 1/19/89
ANACONDA DEER LODGE COUNTY MT 1727/89
CHEYENNE CITY OF WY 1/27/89
LIBBY CITY OF MT 2/1/89
NEWCASTLE, CITY OF WY 2715/89
HAVRE CITY OF MT 2/21/89
CASPER CITY OF WY 2/21/89
OAK CREEK TOWN OF CO 3/31/89
ABERDEEN CITY OF SD 3/31/89
FARGO, CITY OF ND 11/1/88
NORTH DAKOTA PARKS & RFC DP ND 11/3/88
UNIVERSITY OF UTAH UT 11/3/88
ASSINIBOINE & SIOUX TRIBES MT 11/3/88
NORTH DAKOTA ST WATER COMM ND 11/7/88
UTAH VALLEY COMMNTY COLLEGE UT 11/7/88
ROSEBUD SIOUX TRIBE SD 11/7/88
42
-------
Audit Control Number
Auditee
Final Report Issued
Audit Control Number
Auditee
Final Report Issued
N3H M K9-08-0008-9500146
N3H U K9-08-0009-9500147
N3HMK9-08-0010-9500188
N3HMK9-08-0011-9500189
N3H M K9-08-0014-9500216
N3HMK9-0 8-0021 -9500261
N3H M K9-08-0022-9500272
N3H M K9-08-0024-9500291
N3HUK9-08-0029-9500312
N3H M K9-08-0030-9500313
N3H M K9-08-0031 -9500314
N3HMK9-08-0039-9500355
N3H M K9-08-0038-9500356
N3H M K9-08-0042-9500402
N3HMK9-08-0054-9500513
TOTAL
C3H M K9-09-0049-9500148
C3HMK9-09-0071-9500263
C3HMK9-09-0082-9500354
C3HMK9-09-0093-9500400
C3H M K9-09-0102-9500432
C3HMK9-09-0126-9500501
N3H M J9-09-0023-9500047
N3H M J9-09-0022-9500048
N3HMJ9-09-0024-9500089
N3H M K9-09-0025-9500091
N3H M K9-09-0026-9500100
N3H M J9-09-0036-9500128
N3HMJ9-09-0050-9500149
N3HMK9-09-0052-9500190
N3HMK9-09-0053-9500191
N3HMK9-09-0054-9500194
N3HMK9-09-0056-9500215
N3HMK9-09-0067-9500248
N3HMK9-09-0068-9500249
N3HMK9-09-0070-9500262
N3HMK9-09-0074-9500278
N3HMK9-09-0075-9500279
N3HMK9-09-0076-9500295
N3HMK9-09-0077-9500315
N3HMK9-09-0079-9500322
N3H M K9-09-0094-9500405
N3HMK9-09-0095-9500419
N3H M K9-09-0096-9500420
N3HM K9-09-0097-9500421
N3HMK9-09-0099-9500430
N3HMK9-09-0100-9500431
N3HMK9-09-0106-9500467
N3HMK9-09-0107-9500468
N3H M K9-09-0108-9500469
N3H M K9-09-0109-9500470
N3HMK9-09-0113-9500486
N3HMK9-09-0114-9500487
N3HMK9-09-0115-9500488
N3HMK9-09-0116-9500489
N3HMK9-09-0117-9500490
N3HMK9-09-0118-9500491
N3HMK9-09-0119-9500492
N3H M K9-09-0120-9500496
N3H M K9-09-0122-9500497
N3HMK9-09-0123-9500498
N3HMK9-09-0124-9500499
N3HMK9-09-0125-9500500
N3HMK9-09-0127-9500516
OGLALA SIOUX TRIBE SD
METROPOLITAN STATE COLLEGE CO
SIOUX FALLS CITY OF SD
BOULDER CITY OF CO
DELTA CITY OF CO
CONF SALISH & KOOTENAI TRIB MT
PUEBLO CITY OF CO
SOUTH DAKOTA STATE OF SD
CASPER COLLEGE WY
NORTH DAKOTA DEPT OF AGRIC ND
NORTH DAKOTA DEPT OF HEALTH ND
MONTANA STATE OF MT
GRAND FORKS CITY OF ND
LOWER BRULE SIOUX TRIBE SD
OGLALA SIOUX TRIBE SD
OF REGION 08 = 35
PINETOP LAKESIDE SANI DIST AZ
SHOW LOW, CITY OF AZ
PACIFICA CITY OF CA
ELKO CITY OF NV
HONOLULU CITY AND COUNTY OF HI
CARSON CITY CITY OF NV
ARIZONA DEPT OF HEALTH SVCS AZ
AMADOR COUNTY OF AZ
MARICOPA, COUNTY OF AZ
PRESCOTT CITY OF AZ
INTER-TRIBAL COUNCIL OF AZ
PIMA COUNTY OF AZ
NEVADA STATE OF NV
SOUTH LAKE TAHOE CITY OF CA
OAKLAND, CITY OF CA
SANTA BARBARA COUNTY OF CA
MESA CITY OF AZ
LIVE OAK CITY OF CA
PHOENIX CITY OF AZ
GILA RIVER INDIAN COMM AZ
MORO BAY CITY OF CA
NEWMAN CITY OF CA
SAN CARLOS APACHE TRIBE AZ
FORT MOJAVE INDIAN TRIBE CA
COLORADO RIVER INDIAN TRIBES AZ
SANTA ROSA CITY OF CA
GALT CITY OF CA
EMERYVILLE CITY OF CA
QUECHAN INDIAN TRIBE AZ
HAWAII, COUNTY OF HI
SANTA ROSA CITY OF CA
AMADOR COUNTY OF CA
GRASS VALLEY CITY OF CA
PLYMOUTH CITY OF CA
MANTECA CITY OF CA
MAUI COUNTY OF HI
KINGS COUNTY OF CA
MODOC COUNTY OF CA
DEL NORTE COUNTY OF CA
MODESTO CITY OF CA
FERNDALE CITY OF CA
MONTEREY COUNTY OF CA
LAKE COUNTY OF CA
SANTA CRUZ COUNTY OF CA
SANTA CRUZ COUNTY OF CA
SCOTTS VALLEY CITY OF CA
CORONA, CITY OF CA
GERBER-LAS FLORES COM SV Dl CA
TOTAL OF REGION 09 = 48
C3HMK9-10-0109-9500196
C3HM K9-10-0112-9500250
C3HMK9-10-0113-9500280
C3HMK9-10-0117-9500338
C3HMK9-10-0118-9500339
C3HMK9-10-0121-9500383
C3HM K9-10-0122-9500384
C3HM K9-10-0123-9500413
C3HM K9-10-0124-9500422
C3H M K9-10-0126-9500440
C3HMK9-10-0127-9500471
C3HMK9-10-0130-9500517
C3HMK9-10-0131-9500518
N3HM K9-10-0105-9500150
N3HMJ9-10-0106-9500151
N3HMJ9-10-0108-9500195
N3HMK9-10-0114-9500316
N3HMK9-10-0115-9500323
N3HMK9-10-0116-9500324
N3HMK9-10-0128-9500493
N3HMK9-10-0129-9500519
TOTAL
E3BML8-11-0054-9100152
LANE REGIONAL AIR POLL AUTH OR
DRAIN CITY OF
BEAR CREEK VALLEY SANI AUTH OR
GRESHAM CITY OF OR
METRO WASTEWATER MGMT COMM
OR
CHELAN CITY OF WA
NEWBERG CITY OF OR
COEUR D'ALENE CITY OF ID
SEASIDE CITY OF OR
NEW MEADOWS CITY OF ID
ALASKA DEPT OF ENVIRON CONS AK
ELBE WATER & SEWER DISTRICT WA
TANGENT CITY OF OR
JUNEAU CITY BOROUGH OF AK
OREGON STATE OF OR
PIERCE COUNTY OF WASHINGTON
TACOMA CITY OF WA
OLYMPIA CITY OF WA
SEATTLE CITY OF WA
EUGENE CITY OF OR
IDAHO ST DEPT OF HLTH & WEL ID
OF REGION 10 = 21
A COOP AGREEMENT - STATE
CONTROLLER
TOTAL OF HDQ - IAD AUDITS = 1
TOTAL OTHER GRANT AUDITS = 521
11/25/88
11/25/88
12/9/88
12/9/88
12/19/88
1 /9/89
1/13/89
1/19/89
1/26/89
1/26/89
1/26/89
2/7/89
2/7/89
2/21/89
3/31/89
11/25/88
1 /9/89
2/7/89
2/21/89
3/2/89
3/29/89
10/24/88
10/24/88
11/3/88
11 /3/88
11/7/88
11/17/88
11/25/88
12/9/88
12/9/88
12/9/88
12/19/88
1/6/89
1/6/89
1/9/89
1/17/89
1/17/89
1/19/89
1/26/89
1/27/89
2/21/89
2/27/89
2/27/89
2/27/89
3/1/89
3/2/89
3/15/89
3/15/89
3/15/89
3/15/89
3/28/89
3/28/89
3/28/89
3/28/89
3/28/89
3/28/89
3/28/89
3/29/89
3/29/89
3/29/89
3/29/89
3/29/89
3/31/89
12/9/88
1/6/89
1/17/89
2/1/89
2/1/89
2/1 5/89
2/1 5/89
2/23/89
2/27/89
3/6/89
3/15/89
3/31/89
3/31/89
11/25/88
11/25/88
12/9/88
1/26/89
1/27/89
1/27/89
3/28/89
3/31/89
1/11/89
5. SUPERFUND GRANT AUDITS
P5CG*7-02-0083-9100221 NYSDEC - LOVE CANAL NY 3/23/89
P5BG*7-02-0084-9100226 NJDEP - BURNT FLY BOG NJ 3/29/89
TOTAL OF REGION 02 = 2
E5CGN8-04-0329-9300028 SC DHEC BLUFF ROAD. SC 3/13/89
P5CG*8-04-0092-9100014 TENN PA/SI COOP AGREEMENT 10/18/88
TOTAL OF REGION 04 = 2
P5CGN8-06-0122-9300022 ARKANSAS COOPERATIVE AGREEMENT 2/22/89
TOTAL OF REGION 06 = 1
P5BGN7-07-0089-9100021 MISSOURI DNR ELLISVILLE SITE 10/19/88
TOTAL OF REGION 07 = 1
E5AG*8-08-0019-9100034 LIDGERWOOD ND 10/26/88
TOTAL OF REGION 08 = 1
M5BFL9-11-0011-9100050 SF IAG-CORPS OF ENG FY87 11/9/88
M5BFL9-11-0010-9100051 SF IAG-NOAA-FISCAL 84-86 11/10/88
M5BFL9-11-0020-9100096 SF IAG-JUSTICE FY 87 12/12/88
M5BFL9-11-0022-9100168 SF IAG-ENERGY FY 87 1/24/89
TOTAL OF HDQ - IAD AUDITS = 4
TOTAL SUPERFUND GRANT AUDITS = 11
8. OTHER CONTRACT AUDITS
D8CML9-01-0029-9100070
D8AML9-01 -0036-9100097
DSD M L9-01 -0041 -9100098
D8DML9-01-0038-9100102
D8AM L9-01 -0050-9100104
D8AML9-01-0047-9100121
D8AM L9-01 -0049-9100122
D8AML9-01 -0037-9100125
D8AML9-01 -0046-9100126
D8AML9-01 -0347-9100127
D8AM L9-01 -0044-9100129
D8AML9-01 -0048-9100135
D8AML9-01 -0043-9100137
D8AML9-01-0051-9100138
D8AML9-01 -0042-9100140
D8AM L9-01 -0080-9100162
D8AM L9-01 -0079-9100163
D8AML9-01 -0093-9100194
D8AML9-01 -0096-9100195
D8CML9-01-0105-9100204
D8AML9-01-0108-9100220
ARTHUR D LITTLE, MA
MANOMET BIRD OBSERV MA
FOSTER-MILLER, MA
FAY SPOFFARD & THORNDYKE MA
TEMPLE BARKER SLOANE MA
THE CADMUS GROUP MA
ALLIANCE TECHNOLOGY DIV MA
APPLIED SCIENCE ASSOC Rl
ALLIANCE TECH MA
TRC ENVIRONMENTAL CONSULT CT
EASTERN RESEARCH GRP MA
ARTHUR D LITTLE MA
EASTERN RESEARCH GROUP MA
COM FEDERAL PROG CORP VA
EASTERN RESEARCH GRP MA
WILLIAMS WORKS, Ml
WILLIAMS WORKS, Ml
ARTHUR D LITTLE, CAMBRIDGE, MA
METCALF EDDY - WAKEFLD, MA
MAGUIRE INC R
ALLIANCE TECHNOLOGY CORP , MA
TOTAL OF REGION 01 = 21
D8AWL9-02-0198-9100193 YEC INC, NY
D8APL9-02-0201-9100196 SYRACUSE RESEARCH CORP, NY
D8APL9-02-0202-9100197 SYRACUSE RESEARCH CORP, NY
M8AML9-02-0072-9100091 ENVIRESPONSE INC, NJ
TOTAL OF REGION 02 = 4
D8AM L9-03-0028-9100017
D8AM L9-03-0029-9100018
D8DML9-03-0031-9100019
D8DML9-03-0032-9100020
D8AM L9-03-0036-9100028
D8AML9-03-0035-9100029
D8AM L9-03-0039-9100040
D8AM L9-03-0040-9100043
D8AM L9-03-0041 -9100044
D8DML9-03-0044-9100063
D8DML9-03-0046-9100064
D8DM L9-03-0051 -9100067
D8AM L9-03-0052-9100068
D8AM L9-03-0053-9100069
D8CML9-03-0062-9100081
D8AML9-03-0064-9100082
D8DML9-03-0065-9100083
D8DML9-03-0066-9100084
D8DML9-03-0067-9100085
D8AM L9-03-0068-9100086
D8AM L9-03-0069-9100087
D8AML9-03-0072-9100103
D8AM L9-03-0073-9100105
D8DM L9-03-0074-9100106
D8DML9-03-0075-9100107
D8DML9-03-0076-9100108
D8AML9-03-0077-9100109
D8B M L9-03-0082-9100130
D8AML9-03-0083-9100131
D8AM L9-03-0084-9100132
D8AM L9-03-0085-9100133
D8AM L9-03-0095-9100149
D8DML9-03-0096-9100150
D8DML9-03-0097-9100151
D8AM L9-03-0098-9100153
D8AML9-03-0099-9100154
D8AML9-03-0100-9100155
D8AML9-03-0101-9100156
D8AML9-03-0102-9100157
D8AML9-03-0103-9100160
D8AML9-03-0104-9100161
DYNAMAC CORPORATION PA
WASHINGTON CONSULTING GP DC
SOBOTKA AND COMPANY DC
NATIONAL GOVERNORS ASSOC DC
PROSPECT ASSOCIATES INC MD
WALCOFF & ASSOCIATES INC VA
ROY F WESTON INC PA
E H PECAN & ASSOCIATES VA
TECHNICAL RESOURCES INC MD
ROY F WESTON INC PA
ENERGY & ENVIRONMENTAL ANAL VA
AMERICAN MGMT SYSTEMS VA
AMERICAN SCIENTIFIC INTER VA
BIONETICS CORPORATION VA
FAIRFAX OPPORTUNITY UNLIM VA
JACK FAUCETT ASSOC INC MD
LABAT-ANDERSON INC VA
AMERICAN MGMT SYSTEMS INC VA
IMR SYSTEMS CORPORATION VA
MAR INCORPORATED MD
ICF TECHNOLOGY INC VA
TECHNICAL RESOURCES INC PA
INTERNATIONAL SCIENCE/TECH VA
WASHINGTON CONSULTING GR DC
JELLINEK SCHWARTZ CONNOLLY DC
MIRANDA ASSOCIATES DC
ENERGETICS INCORPORATED MD
AMERICAN MGMT SYSTEMS VA
HARRIS GROUP INC VA
PEER CONSULTANTS PC MD
C C JOHNSON & MALHOTRA MD
ICF INCORPORATED VA
AMERICAN MGMT SYSTEMS INC VA
AMERICAN MGMT SYSTEMS INC VA
AMERICAN MGMT SYSTEMS INC VA
WADE MILLER ASSOCIATES INC VA
DYNAMAC CORPORATION MD
CLEMENT ASSOCIATES INC VA
CLEMENT ASSOCIATES INC VA
DYNAMAC CORPORATION MD
POLICY PLANNING & EVAL INC VA
11/21/88
12/15/88
12/15/88
12/20/88
12/20/88
12/22/88
12/22/88
12/27/88
12/27/88
12/27/88
12/27/88
12/29/88
12/29/88
12/30/88
12/30/88
1/19/89
1/19/89
2/22/89
2/22/89
3/3/89
3/22/89
2/17/89
2/24/89
2/24/89
12/13/88
10/18/88
10/18/88
10/18/88
10/18/88
10/24/88
10/24/88
10/27/88
11/1/88
11/1/88
11/16/88
11/16/88
11/17/88
11/17/88
11/17/88
12/12/88
12/12/88
12/12/88
12/12/88
12/12/88
12/12/88
12/12/88
12/20/88
12/20/88
12/20/88
12/20/88
12/20/88
12/20/88
12/29/88
12/29/88
12/29/88
12/29/88
1/11/89
1/11/89
1/11/89
1/11/89
1/11/89
1 /11 /89
1/11/89
1/11/89
1/17/89
1/17/89
43
-------
Audit Control Number
Auditee
Final Report Issued
Audit Control Number
Auditee
Final Report Issued
D8AML9-03-0108-9100166 AMERICAN MGMT SYSTEMS !NC VA
D8AML9-03-0 109-9 100 167 VERSAR INCORPORATED VA
D8AML9-03-0122-9100174 EA ENGINEERING SCIENCE TECH MD
D8AML9-03-01 23-91 001 76 GENERAL SCIENCE CORP MD
D8AML9-03-0124-9100177 MITCHELL SYSTEMS CORP DC
D8DML9-03-01 25-91 001 78 ROY F WESTON INC PA
D8BML9-03-0126-9100179 COMPUTER NETWORK CORP DC
D8DML9-03-01 42-91 00207 MAXIMA CORPORATION MD
D8 AM L9-03-0 146-9 1002 11 DYNAMAC CORPORATION MD
D8AML9-03-01 47-91 0021 2 PROGRAM RESOURCES INC MD
D8 AM L9-03-0 149-9 1002 14 BOOZ ALLEN & HAMILTON INC MD
D8AML9-03-01 54-91 00223 DYNAMAC CORPORATION MD
D8AMN9-03-0030-9300002 NUS CORPORATION MD
D8AMN9-03-0038-9300004 NUS CORPORATION MD
D8BMN9-03-0054-9300008 ROY F WESTON INC PA
D8BMN9-03-0055-9300010 ROY F WESTON INC PA
D8AMN9-03-0063-9300012 SOBOTKA & COMPANY INC DC
P8DTM-03-01 91 -9300020 CENTER FOR PUBLIC MGMT MD
TOTAL OF REGION 03 = 59
D8AML9-04-001 9-9 100022 ENV SCI & ENGR FL
D8AML9-04-0020-91 00023 NSI TECHNOLOGY NC
D8AML9-04-002 1-9 100024 RESEARCH & EVAL ASSOC NC
D8AML9-04-0026-9 100048 BATTELLE OCEAN SCIENCES AL
D8AML9-04-0054-91 00054 RESEARCH TRIANGLE INST , NC
D8AML9-04-0056-9100055 RESEARCH TRIANGLE INST , NC
D8AML9-04-0053-9100057 SYSTEMS RSCH & DEV , NC
D8AML9-04-0030-9100058 RESEARCH & EVAL ASSOC NC
D8AML9-04-0086-9100075 KILKELLY ENV ASSOCIATES NC
D8CML9-04-0078-91001 10 SYSTEMS RESEARCH & DEV NC
D8AML9-04-0085-9100111 ENVIRONMENTAL SCI & ENG FL
D8CML9-04-0082-9100112 SYSTEMS RESEARCH & DEV NC
D8CML9-04-0079-9100113 SYSTEMS RESEARCH & DEV NC
D8CML9-04-0081-9100114 SYSTEMS RESEARCH & DEV NC
D8CML9-04-0084-9100115 SYSTEMS RESEARCH & DEV NC
D8CML9-04-0080-9100116 SYSTEMS RESEARCH & DEV NC
D8CML9-04-0083-9100117 SYSTEMS RESEARCH & DEV NC
D8AML9-04-0100-9100145 TRACOR MARINE FL
D8AML9-04-0101-9100147 NSI TEHCNOLOGY SVCS CORP NC
D8AML9-04-01 27-91 001 75 EDWARD E CLARK ENG SCI FL
D8AML9-04-0027-9100186 BARRY A VITTOR ASSOC AL
D8AML9-04-0138-9100198 EDWARD E CLARK ENG SCI FL
D8AML9-04-0 136-9 100201 ENTROPY ENVIRONMENTALISTS NC
D8AML9-04-0137-9100203 ENTROPY ENVIRONMENTALISTS NC
H8AML9-04-0055-91 00056 RESEARCH TRIANGLE INST , NC
H8AML9-04-0140-9100199 RESEARCH TRIANGLE PARK NC
H8APL9-04-01 32-91 00200 RESEARCH TRIANGLE PARK NC
TOTAL OF REGION 04 = 27
D8 AM P9-05-0 170-9400007 FOXX & CO CINCINNATI OH
D8EMP9-05-02 17-94000 10 LIMNO-TECH Ml
H8CWL9-05-0023-91 00035 CINCINNATI U OF OH
M8EML9-05-0062-91 00026 PEI ASSOC OH
P8DML7-05-0693-9100002 PEI ASSOC FY 84 OH
P8BML7-05-0692-91 00045 PEI ASSOC FY 84 OH
P8DML7-05-0389-9100061 PEI ASSOC FY 83 OH
P8BML7-05-0388-91 00071 PEI ASSOC FY 83 OH
P8DML7-05-0695-9100073 PEI ASSOC FY 82 OH
P8BML7-05-0694-91 00077 PEI ASSOC FY 82 OH
TOTAL OF REGION 05 = 10
D8BML9-07-0045-9100182 MIDWEST RESEARCH MO
D8BAL9-07-0051-9100183 MIDWEST RESEARCH INSTITUTE MO
D8BAL9-07-0039-9100190 MIDWEST RESEARCH INSTITUTE MO
D8BHL9-07-0082-91 0021 7 MIDWEST RESEARCH INSTITUTE MO
TOTAL OF REGION 07 = 4
PiQr*\A/i Q no nnRO QinnoiK k'AN/lAKl QPIFMPFQ PORP PO
uouvVLy-uo'UUoz-y I uuz f o I\MIVIMIN O^ILINL-LO t^unr \^\u
TOTAL OF REGION 08 = 1
noriMi Q no nni/i Qinnnnci ROPKWFI 1 IMTI CORP PA
L/OLJ[VlLy-Uy~vU 1 4--y 1 UUUUy nu\_.r\vvr_Li_ IINIL >^wnr ^M
D8BML9-09-001 7-91 00011 AIR POLLUTION TECHNOLOGY IN CA
D8AML9-09-002 1-9 100030 SCIENCE APPLIC INTL INC CA
D8DML9-09-001 9-91 00031 ENGINEERING SCIENCE INC CA
D8 AM L9-09-005 1-9 100074 S-CUBED, DIV OF MAXWELL LAB CA
D8AML9-09-0058-9100120 ROBERT D NIEHAUS INC CA
D8AWL9-09-0073-9100158 SCIENCE APPLC INTL CORP CA
D8AWL9-09-0072-9100159 WESTER SERVICES, INC VA
D8AML9-09-0078-9100171 TETRA TECH INC CA
D8AML9-09-0080-9100172 TETRA-TECH INC CA
D8CML9-09-0085-9100185 SCIENCE APPLICATIONS INTL CA
nftAMi Q no nnQ9 Qinmfi7 I FF A^snriATF^ PA
L/oHIVILy-Uy'UUy Z-3 I UU I O/ LCL MOOW^lMldO v^M
D8CML9-09-01 05-91 00208 SRI INTERNATIONAL CA
D8CML9-09-0112-9100218 SRI INTERNATIONAL CA
D8BWN9-09-001 3-9300001 BROWN & CALDWELL, CA
D8BMN9-09-0059-9300016 ROCKWELL INTL CORP CA
D8AMN9-09-0062-9300017 ENGINEERING - SCIENCE INC VA
D8EMP9-09-0060-940001 1 ROCKWELL INTL CORP CA
D8EMP9-09-008 1-94000 12 TETRA-TECH INC CA
D8EMP9-09-0101-9400015 ROCKWELL INTL CA
D8EMP9-09-01 2 1-9400022 ROCKWELL INTL CORP CA
TOTAL OF REGION 09 = 21
P8AT*8-1 0-0097-91 00072 GAIA NORTHWEST INC WA
P8AT*8-1 0-0091 -91 00076 TEAM SUPPORT SERVICES OR
P8AT*8 10-0092-9100078 PTI ENVIRONMENTAL SERVICES WA
TOTAL OF REGION 10 = 3
1/24/89
1/24/89
2/7/89
2/7/89
2/7/89
2/7/89
2/7/89
3/8/89
3/1 3/89
3/13/89
3/1 5/89
3/28/89
10/18/88
10/26/88
11/17/88
11/23/88
12/12/88
2/1/89
10/19/88
1 0/20/88
10/20/88
11/2/88
11/10/88
11/10/88
11/10/88
11/10/88
12/1/88
12/21/88
12/21/88
12/21/88
12/21/88
12/21/88
12/21/88
12/21/88
12/21/88
1/10/89
1/10/89
2/7/89
11/2/88
2/27/89
3/3/89
3/3/89
11/10/88
2/27/89
3/3/89
1/18/89
2/1 3/89
1 0/26/88
10/21/88
1 0/5/88
11/1/88
11/15/88
11/21/88
11/28/88
1 2/2/88
1 2/6/88
1/3/89
1 1 /29/S8
Q/On/QQ
o//u/oy
T/9n/c>Q
o/zu/oy
1 0/14/88
10/14/88
10/24/88
1 0/24/88
11/29/88
12/21/88
1/13/89
1/13/89
1/26/89
2/1/89
2/1 3/89
2/1 4/89
3/9/89
3/21/89
10/1 4/88
12/21/88
12/29/88
12/21/88
2/1/89
3/2/89
3/29/89
11/21/88
12/1/88
1 2/5/88
9. SUPERFUND CONTRACT AUDITS
D9AML9-0 1-0030-9 100049 ECOLOGY ENV INC
D9AML9-01-0039-9100099 ALLIANCE TECH CORP, MA
TOTAL OF REGION 01 = 2
D9AGL9-02-0065-9 100065 GIBBS & HILL, NY
D9AGL9-02-0070-91 00093 HOLT AND ROSS, NY
D9AGL9-02-0066-91 00094 MALCOLM PIRNIE, NY
TOTAL OF REGION 02 = 3
D9AGL9-04-0029-9100047 BLACK & VEATCH TN
D9AGL9-04-0028-91 00052 JAMMAL & ASSOC FL
D9AGL9-04-0057-91 00053 COM FEDERAL PROG CORP FL
D9AGL9-04-0092-9100101 ENGINEERING DESIGN & GEOSCI TN
P9ATL8-04-0359-9100128 COLEMAN EVANS WOOD PRES FL
P9AGP9-04-00 18-9400004 SIRRINE ENVIRONMENTAL SC
P9AFP9-04-0025-9400006 DOBBS CORPORATION GA
P9AGP9-04-0024-9400014 S&ME INC GA
TOTAL OF REGION 04 = 8
D9AGP9-05-01 12-9400003 LIFE SYSTEMS INC FY 89 OH
P9BHL8-05-041 8-91 00229 MAECORP IN FY 87 IL
TOTAL OF REGION 05 = 2
D9AKL9-06-0014-9100180 RADIAN CORPORATION TX
TOTAL OF REGION 06 = 1
D9AHL9-07-0021-9100181 BLACK & VEATCH MO
P9AT*8-07 -0206-91 00046 TERRACON CONSULTANTS IA
TOTAL OF REGION 07 = 2
D9AGL9-09-00 16-9 1000 10 LSA ASSOCIATES INC CA
D9AGL9-09-0020-91 00027 BECHTEL ENVIRONMENTAL INC TN
D9AGL9-09-0027-91 00059 IT CORPORATION TN
D9AKL9-09-0035-91 00066 KAISER ENGINEERS, INC CA
TOTAL OF REGION 09 = 4
TOTAL SUPERFUND CONTRACT AUDITS = 22
TOTAL AUDITS = 793
DATE DUE
11/7/88
12/15/88
11/16/88
1 2/1 3/88
12/13/88
1 1 /2/88
11/10/88
11/1 0/88
12/20/88
1 2/27/88
1/12/89
1/17/89
3/2/89
11/18/88
3/31/89
1 0/4/88
1 0/28/88
11/2/88
10/14/88
1 0/24/88
11/14/88
11/16/88
The LibrarvStorfi *A7_nmy
TOTAL OTHER CONTRACT AUDITS = 150
44
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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, SW (A109)
Washington, DC 20460
(FTS or 202) 382-3137
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
Boston
Office of Inspector General
John F Kennedy Federal Building Room 1911
Boston, MA 02203
Audit- (617) 535-3160 FTS 835-3160
Investigations (617) 565-3928
FTS 565-3928
Sacramento
Office of Inspector General
801 I Street, Room 466
Sacramento, CA95814
Audit (916) 551-1076 FTS 460-1076
San Francisco
Office of Inspector General
2II Mam Street
Room 220
San Francisco, CA 94105
Audit (415) 974-7084 FTS 454-7084
Investigations (415)974-8151 FTS 454-8151
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
445 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, 10th 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
„
Asency
,' ^ucrrv 8-c'^Room 1670
L. .,01-0, IL 60604
-------
REPORT:
FRAUD,
WASTE
OR
ABUSE
TO THE
INSPECTOR
GENERAL
HOTLINE
Information is Confidential
Caller Can Be Anonymous
800-424-4000
or
202-382-4977
&EPA
U.S. Environmental Protection Agency • Office of the Inspector General
401 M Street SW. • Washington, DC
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