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 ------- 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 ------- •'"* * ------- 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 4 4 6 8 8 9 13 16 18 . 20 21 . 22 . . 22 . 22 23 23 . 24 . 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 -S. ?nmeiit .!_ Protection . Room 1670 G06Q4 ------- 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) ------- 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) ------- 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) ------- 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 ------- 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 ------- 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 " ------- • 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- Section 2—Audit Resolution As required by the Inspector General Act, this section describes significant problems identified in previous semiannual reports which remain unresolved. Also, as required by the Supplemental Appropriations and Rescission Acts of 1980 and 1981, this section includes a summary of unresolved audit reports and a list of officials responsible for resolving audit findings over 6 months old. Overdue Audit Resolution EPA management and the Office of the Inspector General report overdue audit resolutions, as of March 31, 1989, at 38, an increase from the 29 reported at September 30, 1988 During the first half of fiscal 1989, the Office of Inspector General closed 953 audits and issued 793 new audit reports There are 365 audits remaining in the Agency followup system for resolution during the second six months of fiscal 1989 Of the audits closed, $308 million of questioned costs were sustained including $26 5 million to be recovered and $4 3 million in cost efficiencies In addition, cost recoveries in current and prior periods included $2 1 million in cash collections and at least $142 million in offsets against billings During the past year, EPA formed a task force to develop quality training materials and an approach to help all managers improve their management skills and the performance of their programs This effort was called "Strengthening the Audit Management Ability of EPA Managers " The task force produced several products which should strengthen managers' understanding of the importance of audits, enhance their ability to respond to audits, work with auditors, and resolve audits promptly and properly. Three of these products are - An Audit Handbook for EPA Managers This is a "how to" manual for all those who are involved in audits and the audit process - A Model Audit Management System that highlights organization and staffing for audit resolution, communication channels among offices, and tracking corrective action - A Videotaped Training Package to educate both appointed and career managers about their roles and responsibilities regarding audits and their resolution The task force is now ready to tram the EPA Audit Follow-up Coordinators (AFCs) from its Headquarters and Regional Offices on how to use the process as a positive management tool and to prepare them to tram their staffs. A two day training session is currently being scheduled for May The AFCs will receive a copy of the training videotape and sufficient copies of the audit handbook and model for distribution to their program managers EPA is currently developing an audit resolution and corrective action tracking system and are consulting the IG to ensure that their system will meet the requirements of the Inspector General Act Amendments of 1988 ------- Previously Reported Items—Corrective Actions Not Taken The Inspector General Act requires that each semiannual report identify unresolved audits Audit Grantee/Contractor Number discussed in previous reports Two hundred and three reports were discussed in all previous reports, 197 have been resolved. The six audit reports listed below had not been resolved as of March 31, 1989 Issue Date Status* 7100358 Ahso Water Mgmt Agency. CA 06/16/87 8100927 Program Review R-4 Removal Sites 09/26/88 8100958 Maui County, HI 8100966 NUS Field Investigations 8100468 Miami-Dade, FL 09/29/88 09/30/88 07/02/88 8100761 Moses Lake, WA 08/31/88 No Response In Headquarters OIG/Program Office for Final Resolution No Response Incomplete Response— In Process of Resolving IG In Agreement With 10/25/88 Proposed Final Determination Letter- Awaiting Final Determination Letter to Close Out In Headquarters OIG/Program Office for Final Resolution Action Officials for Audit Reports Outstanding More Than Six Months as of March 31, !989 Action Official EPA Aministration Assistant Administrator for Solid Waste and Emergency Response EPA CONTRACTS Director, Piocurement and Contracts Management Division EPA Grants Programs Director, Grants Administration Division Regional Administrator, Region 1 Regional Administrator, Region 4 Regional Administrator, Region 5 Regional Administrator, Region 9 Regional Administrator, Region 10 3 1 5 18 1 1 13 Total 38 17 17 •Incomplete audit responses open 90 days or more past report date will be handled as a nonresponse in accordance with EPA Directive 2750, "Management of EPA Audit Reports and Follow-up Actions" All of the reports under this category would be considered nonresponse "Awaiting an acceptable final determination letter The final determination letter submitted on March 30. 1989 significantly differed from the proposed final detemination letter with which we were in agreement 'Incomplete audit responses open 90 days or more past report date wil handled as a nonresponse in accordance with EPA Directive 2750, "Management of EPA Audit Reports and Follow-up Actions " All of the reports under this category would be considered nonresponse be Resolution of Significant Audits from Prior Periods Audit Report Date 05/06/81 *] 1 2/28/87 04/07/88 06/20/88 06/02/87 *2 06/02/87 *2 01/29/88 09/1 3/88 09/04/84*3 06/07/88 09/08/88 09/26/88 08/30/88 Federal Share Questioned Number E2GWO-02-0092- 1000937 P2CW*6-02-0166- 8000382 P2CW5-02-0224 8000880 P2CWV-02-0017- 8100329 P2BW*4-03-0349- 7100265 P2BWM-03-0348- 7100266 P2 CW* 6-03-00 17- 8000535 N3GM*8-03-0322- 8100848 P2BW*3-04-0265- 4100499 P2CWP7-05-0046- 890001 1 S2CW6-09-0142- 8100828 S2CW6-09-0207- 8100931 P2CWV-1 0-0042- 8100748 Grantee WEST WINDSOR, NJ WESTERN MONMOUTH, UA, NJ READINGTON, NJ JEFFERSONVILLE, NY UPPER OCCOQUAN, VA UPPER OCCOQUAN, VA RICHMOND CITY, VA PHILADELPHIA, PA LEE COUNTY, FL NEORSD CLEVELAND, OH KINGS COUNTY, CA CSD - ORANGE CO, CA TWIN FALLS, ID Ineligible $ 493,050 549,615 352,029 577,122 349,861 822,518 438,664 1,012,595 1,105,756 69,215 16,798 7,770,805 1,053,550 Unsupported $ 4,066,022 720,003 239,371 11,728 3,705,795 573,960 706,019 -0- 11,203,347 711,653 459,555 93,275 -0- Cost to be Recovered Ineligible $ 394,367 472,866 352,029 7,556 445,154 500,669 438.664 1,012.595 970,174 67,451 16,798 7,146,238 897,649 Unsupported $ 3,795,088 205,196 42,435 577,122 -0- -0- 481,394 -0- -0- 688,969 459,555 -0- -0- 1*The litigation between the grantee and contractors in evaluation of the cause of the problems and submitting a proposed resolution caused a delay in final resolution However, EPA had to issue a letter of intent as a Final Determination of the results of the audit 2*The size of the two audits ($74M) and the number of findings and complexities of the issues required extra time for the preparation of a response to the reports, as well as, the review and evaluation of the response by the IG's office 3*This audit was held open pending results of final litigation of this audit 'Federal share questioned increased up to the amount of costs sustained for recovery in those cases where costs sustained for recover/ exceeded Federal share questioned and were the result of action taken on Federal share set aside 22 ------- The following is a summary of investigative activities during this reporting period. These include investigations of alleged criminal violations which may result in prosecution and conviction, investigations of alleged violations of Agency regulations and policies, and OIG personnel security investigations. The Office of Investigations tracks investigations in the following categories: preliminary and regular investigations, joint investigations with other agencies, and OIG background investigations. Summary Of Investigative Activity During this period, we closed 139 investigations At the same time, we continued to emphasize long-term, major-impact initiatives and improve the quality of investigative work Pending Investigations as of October 1, 1988 242 New Investigations Opened This Period 136 Investigations Closed This Period 139 Pending Investigations as of March 31, 1989 239 Prosecutive and Administrative Actions In this period, investigative efforts resulted in 27 indictments and 16 convictions Fines and recoveries, including those associated with civil actions, amounted to $580,137. Twenty-two administrative actions* were taken as a result of investigations Resignations/Terminations 2 Suspensions 2 Reprimands 4 Restitutions 7 Other 7 *Does not include suspensions and debarments resulting from Office of Investigations activities or actions resulting from reviews of personnel security investigations Profile of Pending Active Investigations by Type Construction 28% Procurement Fraud 21 88% TOTAL - 239 Profile of Pending Active Investigations by EPA Office Unit Enforcement & Compliance 1 4% External Affairs 2 8°/ Personnel Security 4 1 7% Administration 16 67% Multi Prog/Other 15 63% TOTAL - 239 23 ------- Description Of Selected Prosecutive Actions Below is a brief description of some of the prosecutive actions which occurred during the reporting period Some of these actions resulted from investigations initiated before October 1, 1988. Connecticut Asbestos Contractor Indicted The United Painting Company, Inc., of Bethel, Connecticut, its president, James McGuire, and four employees, Jennifer Gaboardi, Christopher Gaboardi, Steven Kovacs, and Christopher Weldon, were indicted February 23, 1989, on charges of conspiring to defraud the Government with false claims and mail fraud Bethel, Connecticut, contracted with the United Painting Company on July 18, 1988, to remove asbestos from three schools in the Bethel School District. Under the specifications and instructions to bidders for this contract, it was required that the contractor comply with all Federal regulations governing asbestos removal in schools. This contract fell under the jurisdiction of EPA, which regulates the school asbestos removal program under the Asbestos Hazard Emergency Response Act (AHERA). Specifically, the indictment alleges that all six defendants conspired to defraud the Government by engaging in asbestos removal projects in violation of the regulations requiring all workers on such projects to have completed EPA approved training programs in asbestos removal The defendants also allegedly falsely certified that the employees on the project had completed the required courses This investigation was conducted jointly by the EPA Office of Inspector General and the United States Postal Inspection Service Convictions Mount in New York Bribery Episode Twenty-five asbestos removal contractors in the New York metropolitan area were arrested January 5, 1988, and charged with bribing an EPA inspector Subsequently, 25 contractors representing 19 companies were indicted, charged with bribing the inspector to (1) overlook violations of Federal rules and regulations regarding asbestos removal conducted by the defendants and (2) stay away from job sites being worked by their companies As of March 31, 1989, 16 contractors have pled guilty to the charges and 4 have been convicted after a trial. Fourteen contractors have been sentenced and fined a total of $535,000 and six and a half years imprisonment The arrest, indictments, and convictions are the result of a continuing investigation by the Department of Labor's Office of Labor Racketeering and the EPA Office of Inspector General EPA regulations require that specific work practices be used during demolition and renovation of structures involving asbestos to minimize the potential exposure of workers and the general public in the vicinity of the removal and disposal actions Contractor's Overcharging Uncovered EPA has recovered $23,682 in labor overcharges on a contract with a maior computer services corporation The investigation was initiated originally on several allegations directed at a subcontractor One allegation substantiated by an OIG investigation involved the billing by the subcontractor for two employees at the highest labor rate in the contract EPA had been billed, in turn, by the prime contractor for these excessive labor costs An OIG inquiry disclosed that the two employees did not meet the experience and education requirements of the highest labor rate. In January 1989, the Procurement and Contracts Management Division advised OIG that a fixed labor rate of $23 99 per hour had been agreed upon with the prime contractor in lieu of the $47 05 per hour rate which had been paid for the 1,027 hours which had been questioned The contract was subsequently modified to recover the funds due EPA. EPA Contractor Pleads Guilty To Being an Accessory to Theft of Government Property SCS Engineers, Inc , of Reston, Virginia, pled guilty in November 1988 to charges of accessory after the fact to theft of U S Government property As previously reported, Gary L Mitchell, a former staff engineer with SCS Engineers, pled guilty in June 1988 to removing confidential procurement information from an EPA facility during 1985, before and during the solicitation for a technical support contract valued at about $45 million The investigation was based on an allegation from a competitor that GCA Technology Division, Inc, of Bedford, Massachusetts, possessed a copy of their bid proposal At that time Mitchell was an SCS employee on an EPA project for the Office of Solid Waste Further investigation determined that SCS Engineers knew of Mitchell's offense after the fact and assisted Mitchell The information was taken to benefit SCS as a potential subcontractor to GCA, which subsequently received this information 24 ------- Illegal "Gray Market" Florida Importer Cars Sentenced We continue to work with Federal and State agencies investigating "gray market" auto dealers and emissions modifications and testing facilities who illegally sell, modify, or test imported cars that have been falsely certified to meet Federal standards Gray market auto dealers import cars to the United States, modify them to meet U S safety and EPA emission standards, and resell them for far less than U S franchised dealers The problem concerning EPA is that many conversions of gray market cars do not meet emission standards (Please refer to a description of revisions in the EPA regulations on page 9) The OIG is concerned with modifiers and certifiers of gray market cars who submit or induce others to submit false statements to EPA claiming that such cars meet these standards Five examples of schemes to defraud the public follow North Carolina Trio Indicted Motorcars International (MCI), Gardner H Altman, Jr, Bernhardt Mueller, and Jerry L Blackmon were indicted February 14, 1989, on charges of conspiring to defraud, making false statements, false customs declarations, and forgery Altman and Mueller established MCI to import vehicles from Germany into the U S for resale Blackmon conducted the day-to-day operations of MCI A joint investigation by the EPA OIG and the U S Customs Service revealed that between November 1983 and May 1985, the defendants imported approximately 24 Mercedes Benz and Porsche cars into the United States for commercial sale by means of fraudulent practices and false invoices, declarations, and written statements Nikos Athanassopoulos was sentenced on February 10, 1989, to two years imprisonment, to be followed by a 5 year term of probation, for illegally importing gray market Mercedes Benz automobiles to the U S and making false statements to EPA regarding such automobiles Athanassopoulos was further ordered to pay restitution to the automobiles' purchasers, to whom Athanassopoulos had misrepresented the age of the vehicles Athanassopoulos had previously been indicted on May 11,1988, on charges of making false statements and false customs declarations in connection with the entry of gray market vehicles into the United States The case which was investigated jointly by the U S Customs Service and the EPA OIG, had uncovered that approximately 250 vehicles had been illegally imported into the United States through the Port of Jacksonville, Florida. Two Importers Indicted in Las Vegas Georgios I Gianakopoulos and Karl Leon Lerner, along with other unnamed individuals, were indicted in Las Vegas, Nevada, on October 12, 1988, on charges of conspiring to import foreign-made vehicles, generally Mercedes-Benzes, and then reselling them without modifying them to meet Federal emission and safety standards The vehicles were misrepresented to domestic buyers through phony documents identifying "strawman" importers The investigation leading to this indictment was conducted by the EPA OIG in cooperation with the U S Customs Service and the Department of Transportation OIG Dutch Importer Sentenced Harmon Westra of Vennep, Holland, was sentenced on January 9, 1989 to 3 years unsupervised probation, fined $2,500, and ordered to report to any probation office within the Judicial District of New Jersey anytime he enters the United States Westra had pled guilty to charges of illegally importing foreign vehicles through the Port of Newark, New Jersey Westra falsified import documents on several vehicles, including two Mercedes Benz automobiles, stating that other individuals were the owners of the cars when, in fact, Westra was the owner EPA regulations provide for a one-time exemption to an individual to import one car, 5 years and older, without complying with the Clean Air Act requiring modification of the vehicle's emission control system Georgia Supplier Continued Criminal Activity Alan Blane Grant of Douglasville, Georgia, was arrested on December 19, 1988, and charged with defrauding the Government at least through September 1988 on a contract with the U S Navy to furnish a van-mounted television sewer inspection system for use at naval bases in Hawaii According to the indictment. Grant conspired with others to disconnect the odometer and drive the sewer inspection van from Georgia to San Bruno, California, where the odometer was reconnected and the vehicle represented to the Navy as a new vehicle The indictment further alleges that other equipment required by the contract was missing when the vehicle was delivered to the Navy, despite Grant's certified contract compliance Grant is also charged with selling equipment that the Navy turned back to him for repair As reported previously, Grant pled guilty in November 1987 to defrauding the Government by providing underweight and defective grout used in EPA-funded sewer rehabilitation projects The judge enjoined Grant permanently and personally from future fraudulent conduct He also received a 5-year suspended sentence, with 6 months residence in a halfway house, and 200 hours of community service His company, Polymer Chemicals, Inc , was fined $10,000 The new indictment charges that Grant continued his fraudulent conduct throughout the period up until at least September 1988 If convicted on all counts, he could face penalties totalling 77 years in prison and a $250,000 fine The charges against Grant resulted from a joint investigation by agents of the Defense Criminal Investigative Service and of the EPA OIG Sewage Plant False Test Results Lead to Indictment John G Mason of Raleigh, N C , the contract operator for five wastewater treatment plants in Wake County, N C , was indicted in January 1989 and charged with submitting false lab test results on effluent from the plants The information, submitted to the North Carolina Department of Natural Resources and Community Development, made it appear that the plants complied with the limits of a permit issued under the National Pollutant Discharge Elimination System (NPDES) The Clean Water Act provides that no pollutants may be discharged into navigable waters of the United States except under conditions stated in an NPDES permit The North Carolina Department of Natural Resources and Community Development administers the NPDES permit program in North Carolina as EPA's agent 25 ------- Impersonator of Federal Officer Sentenced Alejandnno Ramos was convicted in December 1988 of mail fraud, impersonation of a Federal officer, and improper use of Government seals in a scheme to defraud Water Wise, Inc., of Leesburg, Florida, a supplier of water purification equipment and supplies, and the Federal Government Ramos was sentenced to 14 months in prison, 24 months probation, and required to pay $1,077 restitution Doing business as National Environmental Protection Service of Lafayette, Louisiana, Ramos mailed an order to purchase some water distillation equipment from Water Wise for delivery on open account, in so doing, he represented himself as an agent of EPA Later he told Water Wise that he would provide a General Services Administration purchase order number authorizing payment for the products by the U S Government Based on these false representations, Water Wise shipped equipment and accessories valued at $1,077 to Ramos In addition, Ramos further communicated with Water Wise using a personal business card and stationery bearing the seal of EPA Former Police Officer Sentenced for Fraud on EPA Project Donna Amato, a former New Haven, Connecticut, police officer, was sentenced on January 31, 1989, after being convicted of making false claims for pay for traffic control work not actually performed on an EPA-funded sewage treatment improvement project in New Haven Amato received a one-year suspended sentence and was fined $1,000 She was also ordered to perform 500 hours of community service over the 2 years of probation Two other New Haven police officers previously pled guilty to similar charges The cases resulted from an investigation by the EPA DIG and the Internal Affairs Division of the New Haven Police Department Consulting Engineer on EPA Study Convicted of Fraud Samar Chatterjee, president of Universal Engineering Services, Inc , and AES Engineers, Inc , was sentenced on February 6, 1989, after being convicted of conspiracy, mail fraud, and making false statements in connection with consulting work he did on the EPA-funded South Stickney Sanitary District, Burbank, Illinois, sewer rehabilitation study Chatterjee was sentenced to jail for 4 years, placed on probation for 5 years, and ordered to pay $110,000 in restitution to EPA and another $110,000 to the South Stickney Sanitary District Chatterjee had been charged with submitting false testing data concerning sanitary sewer connections, flow gauging, manhole inspections, and sewer survey reports to EPA and the Metropolitan Sewer District of Greater Chicago In addition, Chatterjee received EPA grant funds of over $200,000 for work that he allegedly did not perform Chatterjee's case resulted from a 3-year investigation into allegations of financial fraud in the South Stickney Sanitary District The investigation was conducted jointly by the EPA OIG, the EPA Office of Enforcement and Compliance Monitoring, and the FBI Description Of Selected Prosecutive And Administrative Actions Concerning EPA Employees The OIG investigates and reports information, allegations, and indications of possible wrongdoing or misconduct by EPA employees and persons or firms acting in an official capacity directly with EPA or through its grantees. In addition, the Senate Report of the Supplemental Appropriations and Rescission Act of 1980 states that appropriate administrative action is expected to be taken in cases where employees have acted improperly Selected administrative actions taken against EPA employees as a result of OIG investigations are shown below 26 ------- Former Region 4 Employee Charged with Theft A 9-year employee in Region 4 has been charged with theft of four EPA-owned calculators valued at $260. She subsequently pawned the machines. The employee was removed from her position in February Further investigation revealed that she had been arrested by local law enforcement officers in December 1988 for alleged possession of narcotics and in March 1989 for alleged numerous bad check offenses The investigation was a joint effort by EPA OIG and General Services Administration OIG Bus Pass Money Taken by Region 6 Employee In November 1988 a Region 6 employee was sentenced to 3 years probation, 100 hours of community service, and was directed to enter a mental health program for keeping $8,000 due the Dallas Area Rapid Transit (DART) system for bus passes sold to EPA employees. For over 8 months, the employee received bus passes worth approximately $71,500 from DART for resale to EPA employees The unsold passes (but no money) were returned to DART in March 1988, a month after the employee's resignation from EPA The Assistant U S Attorney asked that restitution of the stolen money be part of the sentence, but the judge declined because the employee did not have any money This investigation was a joint effort by EPA OIG and the Department of Transportation OIG Employee Reprimanded for False Statements A Region 9 employee was reprimanded for knowingly submitting falsified income statements to obtain Housing Assistance Payments from the Department of Housing and Urban Development (HUD) The employee had provided false income and employment information to EPA employees, which was subsequently provided to HUD, so she could obtain payments The reprimand followed the employee's guilty plea and sentence to 5 years probation and full restitution to HUD Civil And Administrative Actions To Recover EPA Funds Investigations and audits of the Office of Inspector General provide the basis for civil and administrative actions to recover funds fraudulently obtained from EPA Through the Inspector General Division of the Office of General Counsel, the OIG uses a variety of tools to obtain restitution. These include cooperative efforts with the Department of Justice in filing civil suits under the False Claims Act, as amended, and other authorities; working with grantees using their own civil litigation authorities, invoking the restitution provisions of the Victim and Witness Protection Act during criminal sentencing; using the Agency's authority to administratively offset future payments and to collect debts; and negotiating voluntary settlements providing for restitution in the context of suspension and debarment actions. The tools available for recovering funds fraudulently obtained from the Agency have been enhanced by the enactment of the Program Fraud Civil Remedies Act That statute provides an administrative remedy for smaller false claims and false statements in connection with claims Through the Inspector General Division, the OIG provided leadership in the mteragency effort to develop model regulations to implement the act. EPA published its final rule implementing the act in April 1988, in 53 Federal Register 75782 (codified at 40 C F R 27) With these regulations in place, we are now prepared to bring cases to EPA's administrative law judges for adjudication and recovery Civil and administrative actions to recover funds usually extend over several semiannual reporting periods. What follows is a brief description of the progress being made on several such matters 27 ------- EPA Wins $84,000 from Superfund Defrauders On January 13, 1989, a Federal judge in Michigan ordered a corporation and three of its owner/officers to pay the United States $84,362 in a Superfund fraud case The order was a response to a Department of Justice complaint, filed on behalf of EPA, seeking approximately $500,000 under the False Claims Act, as amended The amount represented treble damages and civil penalties for false claims submitted to EPA under a contract. An investigation by the OIG, initiated as a result of an audit, demonstrated that the Enmanco Corporation and three of its owner/officers, James Barnum, Gary Domanski, and Daniel Toy, had submitted false payroll costs, manifests, and invoices during the 1982-83 Superfund cleanup of the Liquid Disposal, Inc , hazardous waste site During the investigation, haulers admitted driving only half-full trucks that Enmanco had manifested as full, and a waste disposal firm admitted paying Enmanco a $25,041 kickback for receiving its business The defendants pleaded guilty to one count of conspiring to defraud the Government with respect to claims and paid criminal penalties, served jail time, and made restitution of $32,181 under the Victim and Witness Protection Act Appeal Denied in Atlanta Area Claim The Government's position in a case to recover damages for bidngging has been strengthened by a recent court decision upholding the defendants' convictions EPA filed a complaint on April 13, 1988, against Paxson Electric Company, Dynalectric Company, Fischbach & Moore, Inc., G W Walther Ewalt, and Wesley C Paxson, Sr, for triple damages and civil penalties under the False Claims Act, as amended, and for damages under common law The United States seeks to recover its damages, estimated at $1.3 million, which may be tripled under the Act, plus up to $10,000 in civil penalties for each false claim submitted These defendants were previously indicted for, among other things, conspiracy to rig the bids on the electrical portion of the EPA-funded Snapfmger Creek Wastewater Treatment Plant in DeKalb County, Georgia Fischbach & Moore pled guilty to the charges. The remaining defendants were tried and convicted They then appealed to the 11th Circuit Court of Appeals, which recently affirmed the convictions EPA Seeks to Debar Acquitted Contractor A Federal judge in Philadelphia has authorized EPA to proceed with a debarment action against a contractor although the contractor has been acquitted of charges on which the debarment was based EPA's action against B E S Environmental Specialists, Inc , and its founder, Richard Baranowski, is apparently the first time that a civilian Federal agency has initiated debarment proceedings in the wake of an acquittal. B E S. and Baranowksi were acquitted in I987 of defrauding EPA on a Superfund contract for cleaning up the Brown's Battery site near Lancaster, Pennsylvania Nevertheless, the Office of Inspector General maintained that the transcript of the criminal case showed that B E.S had defrauded EPA On September 29, I988, EPA initiated the debarment action, raising three allegations First, the Agency charged that B E S and Baranowski had defrauded EPA on the Brown's Battery project, citing the record from the criminal trial Second, it alleged that Baranowksi had given an EPA on-scene coordinator gratuities free construction work on his home and an expense-paid Canadian vacation. Finally, EPA charged that B E S had refused to submit to an audit, breaching its contracts In light of the evidence of overcharges from the criminal trial, the Office of Audit had sought to audit several B E S projects When B E S. resisted, the Inspector General subpoenaed B E S ' cost records B E S asked for a preliminary injunction against both the debarment action and the subpoena in Federal district court in Philadelphia On November 23, I988, Judge Marvin Katz denied B E S ' motion. He found that the failure of the Government to prove its criminal case beyond a reasonable doubt did not preclude EPA from seeking a debarment under a standard based on preponderance of the evidence He also ruled that EPA's debarment procedures satisfy all due-process requirements The court ordered B E S. to produce the subpoenaed documents within 15 days. EPA held an administrative debarment hearing in early February 1989. A decision is expected soon In the meantime, B E S has been suspended from receiving EPA contracts 28 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- Mailing Addresses and Telephone Numbers • OIG HOTLINE (800) 424-4000 or (202) 382-4977 Headquarters Office of Inspector General 401 M Street, SW (A109) Washington, DC 20460 (FTS or 202) 382-3137 Atlanta Office of Inspector General 1375 Peachtree Street, NE Suite 276 Atlanta, GA 30309 Audit (404)347-3623 FTS 257-3623 Investigations (404)347-3623 FTS 257-3623 Boston Office of Inspector General John F Kennedy Federal Building Room 1911 Boston, MA 02203 Audit- (617) 535-3160 FTS 835-3160 Investigations (617) 565-3928 FTS 565-3928 Sacramento Office of Inspector General 801 I Street, Room 466 Sacramento, CA95814 Audit (916) 551-1076 FTS 460-1076 San Francisco Office of Inspector General 2II Mam Street Room 220 San Francisco, CA 94105 Audit (415) 974-7084 FTS 454-7084 Investigations (415)974-8151 FTS 454-8151 Seattle Office of Inspector General 111 3rd Avenue, Suite 350 Seattle, WA98101 Investigations (206) 442-1273 FTS 399-1273 Chicago Office of Inspector General 10 West Jackson Boulevard 4th Floor Chicago, IL 60604 Audit (FTS or 312) 353-2486 Investigations (FTS or 312) 353-2507 Dallas Office of Inspector General 445 Ross Avenue, Suite 1200 Dallas, Texas 75202-2733 Audit (214) 255-6621 FTS 255-6621 Investigations (214)655-6610 FTS 255-6610 Denver Office of Inspector General 999 18th Street, Suite 500 Denver, CO 80205-2405 Audit (303) 294-7520 FTS 564-7520 New York Office of Inspector General 90 Church Street, Room 802 New York, NY 10007 Audit (FTS or 212) 264-5730 Investigations (FTS or 212) 264-0399 Philadelphia Office of Inspector General 841 Chestnut Street, 10th Floor Philadelphia, PA 19107 Audit (FTS or 215) 597-0497 Investigations (FTS or 215) 597-9421 Research Triangle Park, NC Office of Inspector General EPA Administration Building Alexander Drive, Room 113 Research Triangle Park, NC 27711 Audit (919) 541-1028 FTS 629-1028 „ Asency ,' ^ucrrv 8-c'^Room 1670 L. .,01-0, IL 60604 ------- REPORT: FRAUD, WASTE OR ABUSE TO THE INSPECTOR GENERAL HOTLINE Information is Confidential Caller Can Be Anonymous 800-424-4000 or 202-382-4977 &EPA U.S. Environmental Protection Agency • Office of the Inspector General 401 M Street SW. • Washington, DC ------- |