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
Page
1
3
4
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6
8
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13
16
18
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21
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23
23
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. 27
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
29
32
33
34
34
35
36
36

39
40
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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

-------
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

-------
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

-------
 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

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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

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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

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Description  Of
Selected
Prosecutive
Actions
Below is a brief description of
some of the prosecutive actions
which occurred during the
reporting period Some of these
actions resulted from
investigations initiated before
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

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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

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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

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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

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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
28

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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
                                                                                                                29

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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
30

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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
                                                                                                                       31

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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

-------
            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
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Atlanta
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Audit  (404)347-3623 FTS 257-3623
Investigations  (404)347-3623
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Audit (FTS or 312) 353-2486
Investigations  (FTS or 312) 353-2507


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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

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                    REPORT:
                    FRAUD,
                    WASTE
                      OR
                    ABUSE
                    TO THE
                  INSPECTOR
                   GENERAL

                HOTLINE
      Information is Confidential
      Caller Can Be Anonymous
800-424-4000
or
202-382-4977
            &EPA
   U.S. Environmental Protection Agency • Office of the Inspector General
         401 M Street SW. • Washington, DC

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