D171

56c
United States
Environmental Protection
Agency
Office of the
inspector General (A109)
Washington DC 20460
                                    November 1990
           Office of the Inspector General
           Semiannual Report      350R90001
           to the Congress

           April 1,1990 Through
           September 30,1990
                                      fififWetf on Recycled Paper

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       The Environmental Protection Agency is increasingly
       being looked to for international leadership in
       environmental protection and pollution prevention.
With Earth Day 1990 now a part of history, the slogan "make
every day Earth Day" needs to become a reality, not only in the
United States but throughout the world. The hazards of envi-
ronmental pollution know no political or geographic
boundaries.
   The Office of Inspector General is playing a significant
role in helping the Agency achieve the credibility and
capacity for  international leadership  by working to reduce
the Agency's vulnerability to loss of  its scarce resources.
Our audits, investigations, and special reviews this six
month period identified several areas where, while progress
has been made, management attention is still needed. We
found continuing problems with the Chesapeake Bay cleanup
and with audit followup; enforcement in preventing oil spills;
keeping lead out of  drinking water, especially in schools;
safeguarding our waters from harmful discharges; and control-
ling pesticides. A special review found that Louisiana's
highly productive coastal wetlands are being lost due to
inadequate regulation of oil and gas activities. Also, we
assisted in suspending or debarring  more dishonest or non-
responsive persons  or firms than in  any previous period.
   Beginning in fiscal 1991 we will provide more comprehensive
coverage of  particular programs, functions and activities to
enhance the Agency's effectiveness. Our initial focus will be
on financial  management and contract management. Future work
will focus on pesticides, estuaries and the Superfund. As part
of this new approach, we will  be placing additional resources
into audits of Agency contracts. We  are also increasing the
number of engineers, scientists, and computer specialists on
our staff to improve  our ability to serve the Agency in areas
requiring special technical competency. Our investigative pro-
gram will emphasize the contract laboratory program and work  in
areas with known vulnerability. For the first time we will review
the operations of the Leaking Underground Storage Tanks Trust Fund.
   My staff and I are looking forward to helping Agency management
past its first  20 year milestone and into the future of international
achievement.
John C. Martin
Inspector General

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     Contents
                                                                         Page

     Executive Summary  	1
     Overview of EPA's Current Challenges	3
     Overview of Significant Trends In EPA of Concern to the OIG	4
     Profile of Activities and Results	5
     Establishment of the OIG in EPA-lts Role and Authority	6
     Organization and Staffing  	6
     Purpose and Requirements of the OIG Semiannual Report	6

     Section 1-Significant Problems, Abuses, and Recommendations	8
     Summary of Audit Activities and Results	8
     Agency Management  	9
     Construction Grants  	13
     Superfund Program	16
     Special and Prospective Reviews 	18

     Section 2-Audit Resolution	22
     Audit Followup	23
     Significant Management Decisions With Which IG Disagrees  	24
     Status of Management Decisions on IG Audit Reports	24
     Resolution of Significant Audits	24

     Section 3-Prosecutive Actions	28
     Summary of Investigative Activity	28
     Description of Selected Prosecutive Actions	29

     Section 4-Fraud Prevention and Resource  	32
     Management Improvements	32
     Review of Proposed Legislation and Regulations	32
     Suspension and Debarment Activities	34
     Employee and Public Awareness Activities	35
     Personnel Security Program	36
     President's  Council on Integrity and Efficiency 	37
     Committee on Integrity and Management Improvement	37
     Hotline Activities	38
     Professional and Organizational Development 	38

     Section 5-Delinquent Debts  	39

     Appendices
     Appendix-1 List of Audit Reports Issued 	40
     Appendix-2 Audit Reports Without Management Decision 	59
Ospreys nesting on Chesapeake
Bay. A followup audit of the
Bay cleanup program found
continuing deficiencies
(page 24) (photo by Steve
Delaney).

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A tranquil scene af the Kenilwoi
Aquatic Gardens, Washington,
DC (photo by Steve Delaney).

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      Executive  Summary
Section 1—
Significant Problems,
Abuses, and
Recommendations
1. Audit Spurs Rapid Action to
Tighten Controls Over Banned
Pesticides.

EPA still had not ensured that
emergency suspended and
cancelled (banned)  pesticide
holders safely controlled their
stocks and complied with
disposal rules (page 9).

2. Increased Efforts Needed to
Protect The Public Against
Lead in Drinking Water.

EPA and the states in Region 3
were not ensuring that school
children and the public were
adequately protected against
excessive  levels of lead in
drinking water (page 9).

3. Stronger Enforcement
Needed to Prevent Damage
from Oil Spills.

Over two years after the oil spills
at the Ashland Oil facility in
Pennsylvania and the Shell Oil
facility in California, aggressive
enforcement actions were not
always taken when violations of
EPA's Oil Pollution Prevention
regulations were disclosed (page
10).

4. Better Oversight and
Enforcement Needed in Region
6 Pesticide Control Program.

Region 6 oversight of state
pesticide programs did not
ensure that delegated states took
appropriate enforcement actions
against violators of pesticide
laws. Problems identified by EPA
in oversight reviews of state
pesticide programs were not
corrected timely.  Also, Region 6
was  not taking timely
enforcement actions, nor properly
tracking cases referred to states
(page 10).

5. Marine Discharge Waiver
Program in Region 2 Needs
Improvement.

Region 2 was not aggressively
administering the Clean  Water
Act Section 301 (h) marine
discharge waiver program to
protect the marine
environmentfrom the harmful
effects of sewage treatment
discharges in Puerto Rico and
the Virgin Islands (page 11).
6. EPA Headquarters
Frequently Misused Overtime.

Controls over authorizing,
recording and paying overtime
were weak in six EPA
Headquarters offices, raising
serious questions about the
condition of the entire
timekeeping system. Also,
offices violated EPA policy by
repeatedly using overtime,
sometimes clearly for non-
essential reasons.  As a result,
unnecessary overtime payments
may have  been  made to
employees (page 11).

7. Construction Grant
Obligations Overstated by $55
Million.

EPA's Regional  Offices did not
take timely action to deobligate
over $55 million of unneeded
construction grant funds (page
12).

8. EPA Did Not Test Internal
Controls.

Managers  were  not adequately
testing or documenting Agency
internal controls as  part of
reviews to identify and correct
weaknesses in their major
activities as required by the
Federal Managers' Financial
Integrity Act (FMFIA) (page 12).

9. Over $29  Million of
Questioned Costs Claimed by
Honolulu, Hawaii.

The City and County of Honolulu,
Hawaii, claimed  $17,655,814 of
ineligible construction,
engineering, and labor costs.  An
additional $9,085,152 of
unreasonable and $2,493,500 of
unnecessary costs were also
questioned (page 14).

10. Nearly $11 Million of
Bartlesville, Oklahoma, Project
Claim Are Ineligible or
Unsupported.

The City of Bartlesville,
Oklahoma, claimed  $10,933,043
of ineligible construction,
engineering,  and arbitration costs
(page  14).
 11. San Francisco Claims Over
 $3 Million of Costs Unrelated
 to EPA Grant.

 The City and County of San
 Francisco, California, claimed
 $3,381,272 of costs for
 improvements to the Great
 Highway and surrounding area
 that were not a part of the EPA
 grant.  An additional $497,876 of
 ineligible construction costs were
 questioned (page 14).

 12. Procurement and
 Accounting Weaknesses
 Result In $16 Million
 Questioned Costs.

All costs totaling $16,139,045
claimed by the Three Lakes
Water and Sanitation District,
Colorado, were questioned
because of procurement
problems and accounting system
deficiencies. Problems relating to
the project which were identified
in 1982 by an EPA  task force
prior to the project's completion
were not addressed by the
grantee or Region 8 (page 15).

13. Grantee Attempts  to Limit
Its Liability at EPA's Expense.

After reaching a settlement
agreement with a contractor, the
City of  Slidell, Louisiana, claimed
$672,578 of construction costs
even though it incurred only
$20,000.  An additional $375,117
of legal, construction, engineering
and administrative costs were
questioned (page 15).

14. Region 4 Inadequately
Managed "Removial"  Cleanups.

Region 4's inadequate
implementation and ineffective
management of "removial"
cleanup actions (1)  did not meet
"removial" goals to expedite
remedial cleanup and to delete
sites from EPA's  National
Priorities List (NPL) (delisting),
and (2) resulted in over $3.8
million  in potentially excessive
costs and obligations (page 17).

15. California Multi-Site
Agreement Lacks Effective
Controls.

The California State Water
Resources Control Board had not
established effective
management and financial
controls to protect the public

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health and accurately account for
the $2.9 million of costs under
the South Bay, California, Multi-
Site Cooperative Agreement
(page 17).

16. Guidance Needed for
Disposing of Wastes
Generated From Pre-Remedial
Site Inspections.

Contractors used poor judgement
and made mistakes in disposing
of wastes generated from pre-
remedial  site investigations
conducted for EPA (page 18).

17. Region 6 Action Needed to
Stop the Loss of Louisiana
Coastal Wetlands.

EPA Region  6 was not controlling
the negative  impacts of oil and
gas activities on Louisiana's
coastal wetlands (page 18).

18. Management Decisions In
Region 10 Were Questionable.

Region 10 management
decisions on environmental
issues were not consistent with
staff recommendations nor
supported by documentation in
the files (page 19).

19. $9 Million Grant Awarded
for an Oversized and
Unaffordable Wastewater
Treatment Facility.

Region 9 prematurely awarded a
$9 million grant for the first phase
of the Hilo, Hawaii, wastewater
treatment facility project (page
20).

20. $2.4  Million in Grants to
California County Should be
Annulled.

The Mariposa County Water
Agency, California, proposed
constructing wastewater
treatment facilities even though
the projects were not justified,
public support for the projects
was obtained using questionable
techniques, and the projects were
neither cost  effective nor
affordable (page 20).
21. EPA Improperly Awards
Two Grants for $10.7 Million.

EPA improperly awarded grants
to Sellersburg and West Terre
Haute, Indiana, because each
project's estimated costs
exceeded the maximum amount
allowed (page 21).


Section  2—
Audit Resolution

At the beginning of the
semiannual period, there were
336 audit reports for which no
management decision had been
made. During the second half of
fiscal 1990, the Office of
Inspector General issued 891
new audit reports and closed
331.  At the end of the reporting
period, 300 audit reports
remained in the Agency followup
system for which no management
decision had been made.  Of the
300 audit reports, 64 reports
remained in the Agency followup
system for which no management
decision was made within six
months of issuance (page 22).
 In four followup audits conducted
this reporting period, the Office of
Inspector General found that
problems identified in previous
audits continued to exist (page
23).  Also, as required by the
1988 Inspector General Act
amendments, we are reporting for
the first time a significant
management decision with which
we disagree (page 24).
 Of the 331 audits closed, $32.6
million of questioned costs were
disallowed for recovery, and $7.6
million which recommended that
funds be put to  better use were
agreed to by EPA management.
In addition, cost recoveries in
current and prior periods included
$3.95 million in  cash collections,
and at least $ 31.2 million in
offsets against billings (page 22).
Section 3—
Prosecutive
Actions

During this semiannual reporting
period, our investigative efforts
resulted in 9 convictions and 14
indictments.  Also, this
semiannual period our
investigative work resulted in
$2,829,501  in fines and
recoveries (page 28).
 Another contractor was
convicted of bribing an EPA
asbestos inspector in New York
City; criminal complaints were
filed against a New Jersey
computer hacker for a failed
attempt to access EPA main
computers; two electrical
contractors  pled guilty to
racketeering charges, including
submitting fraudulent invoices on
EPA-funded projects; two
Pennsylvania firms and their
officers were charged with
violations of the Resource
Conservation and Recovery Act
and the Clean Water Act after a
criminal investigation by the EPA
OIG of another allegation
involving the Superfund program
found evidence of serious
environmental violations; two
North Carolina men were indicted
for allegedly filing false claims for
services never provided under an
EPA Emergency Response
Cleanup Service contract; a
laboratory official was charged
with providing bogus analyses to
EPA; and an EPA employee was
caught falsifying travel claims
(page 29).
Section 4—
Fraud Prevention an<
Resource
Management

Review of Proposed Legislati<
and Regulations

During this semiannual period
we reviewed 99 legislative an
regulatory items. The most
significant were an EPA direcl
on receivables and billings; th
Federal Civil Penalties Inflatioi
Adjustment Act of 1989; the H
Performance Computing Act c
1990; and an amendment to t
Ethics Reform Act (page 32).

Suspension and Debarment
Activities

We completed 110 cases duri
this reporting  period, resulting
39 debarments,   4 settlemen
agreements, 67 suspensions,
141 cases closed after
investigation.  Totals for fiscal
1990  were almost double that
the previous year. There were
235 active cases at the close i
this reporting  period (page 34)

Professional and Organization!
Development

Members of the Office of
Investigation received training i
Total Quality Management,
including an overview of the
scientific method of problem
solving known as PDCA (plan,
do, check and act). The trainir
was part of 453 approved
enrollments, a total of 1,284 da
of training and participation in
professional development
seminars and conferences.  Th
OIG FY 1991  course catalog,
providing training paths for eac
job classification and grade, ha
been  published (page 38).

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 lis section highlights some of
 3A's most significant challenges
 r restoring and protecting the
 jality of the air we breathe, the
 nd where we live, and the water
 e depend on.

 \ND

 ie principal sources of land
 aste are:

 Jnderground Storage Tanks.
 i estimated five to six million
 iderground storage tanks in use
  the United States contain
 itroleum products or hazardous
 lemicals.  Approximately two
 illion of these tanks may be
 aking  and are a source of land
 >ntamination that can contribute
  ground-water contamination.

 ndustrlal Hazardous Wastes.
 le chemical, petroleum, metals,
 id transportation industries are
 ajor producers of hazardous
 dustrial waste, such  as dioxin
 id benzene which are known
 ircinogens.

 Municipal Wastes. Municipal
  istes include household and
 >mmercial wastes, demolition
 aterials, and sewage sludge.
 Events and other harmful
 jusehold and commercial
 astes are generally so
 termingled with other materials
 at specific control of each is
 tually impossible.

 dining Wastes. A large volume
 all waste generated in the
 nited States is from mining coal,
 losphates, copper, iron,
 •anium, and other minerals and
 im ore processing and milling.
 unoff from these wastes
 creases the acidity of streams
 id pollutes them with toxic
 aterials.

 IR

 he Clean Air Act of 1970
 iquires EPA to set National
 mblent Air Quality Standards for
 ose pollutants, termed "criteria
ollutants," which pose the
reatest overall threat to air
uality:  ozone, carbon monoxide,
irborne particulates, sulfur
ioxide,  lead, and  nitrogen
xides.
        Major Laws Administered by EPA
     Statute                    Provisions
     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
     dean Air Act
     dean Water Act
     Safe Drinking
     Water Act
     Marine Protection,
     Research and Sanctuaries Act

     Asbestos School
     Hazard Abatement
     Act
     Asbestos Hazard
     Emergency
     Response Act
     Emergency
     Planning and
     Community
     Right-to-Know Act
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
for pesticide residues on food and
food products.

Authorizes EPA to identify 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.
The act also requires EPA to set
National Emission Standards for
Hazardous Air Pollutants.
Hazardous air pollutants  are
those that can contribute to an
increase in mortality or serious
illness.

A major thrust of the next decade
will be to address growing
national and  international
problems from acid deposition
and global warming.

•Acid deposition is now
recognized as a serious long-
term air pollution problem for
  many industrial nations. The
  process of acid deposition begins
  with emissions of sulfur dioxide
  (primarily from coal-burning
  power plants) and nitrogen oxides
  (primarily from motor vehicles
  and coal-burning power plants).
  These pollutants interact with
  sunlight and water vapor in the
  upper atmosphere to form acidic
  compounds.

  •Global Warming. Certain types
  of air pollutants are producing
  long-term and perhaps
irreversible changes to the global
atmosphere.  In the troposphere
(the lower 10 miles of
atmosphere), high levels of
carbon dioxide are producing an
overall warming of the global
temperatures. This "greenhouse
effect" may cause irreversible
changes to the climate and the
atmosphere's protection against
harmful ultraviolet radiation.
 WATER

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

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

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

 •Nonpolnt Sources. Nonpoint
 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
 nonpoint source of water
 pollution.

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

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   Overview of Significant Trends In  EPA  of Concern  to  the OIG
This section of our report
presents the Office of Inspector
General's perspective on
significant vulnerabilities facing
EPA. These items serve to
highlight the crosscutting
problems the OIG believes must
be addressed for the Agency to
conduct its programs and
operations in a more effective,
efficient, and economical
manner. These trends were
derived from an  overview of the
common or recurring conditions
identified by OIG audits,
investigations, and evaluations
over time.
ENFORCEMENT

In the last year Agency
management has worked
diligently to improve EPA's
enforcement program and make it
work. Effective enforcement of
environmental laws is the
foundation of the Agency's ability
to achieve compliance with its
mission.  Overall, policy has  been
strengthened and increased
emphasis has been placed on
maintaining appropriate
documentation to support Agency
actions. While each  of these
actions has served to strengthen
the overall situation, continued
efforts and attention are needed
to maximize the effectiveness of
EPA's enforcement program.
  During fiscal 1990, OIG audits
of EPA's water, pesticides, and
Superfund programs disclosed
continuing instances  of ineffective
enforcement.  OIG reports
repeatedly have shown weak and
untimely Federal and State
enforcement.  Cases were found
where EPA and the States did
not take appropriate  action
against unpermitted discharges.
In other cases, EPA  and the
States did not enforce consent
agreements to track enforcement
cases to ensure the adequacy of
corrective actions taken.
  In each of these instances
EPA management has committed
to initiating appropriate corrective
action. Top level Agency
management continues to focus
attention on this vital program.

SUPERFUND

Significant actions are needed to
improve the cleanup of Superfund
sites. During fiscal 1990, EPA
has focused its attention on
implementing the numerous
recommendations resulting from
the Administrator's
comprehensive review of the
Superfund program.  While
considerable progress has been
made, OIG audits and
investigations continue to show
that significant improvements are
stilt needed.
  OIG audits; continue to show a
pattern of repetitious studies of
the same problems, partial
remedies, and inadequate
involvement by community
representatives, responsible
parties and State officials.
Additionally, some contractors
have been placed in positions
where they, rather than EPA,
have made decisions regarding
the extent of cleanup actions to
be taken.
  EPA efforts to evaluate
innovative technology have been
seriously hindered by problems
locating  sites and issuing reports
on completed projects. High
demonstration costs and  lack of
Federal  funding assistance
discouraged  technology
developers from participating in
EPA's program.

INTERNAL CONTROLS AND
FINANCIAL MANAGEMENT

Overall, EPA continues to
struggle with basic internal
controls and  inaccuracies in its
financial management system.
While there has been
considerable activity devoted to
improving the Agency's overall
performance in these areas,
EPA's results have been less
than anticipated.
  A recent OIG review of the
Agency's FMFIA process showed
that only a few of the internal
control reviews reported by the
Agency  actually included any
tests of actual transactions.
Additionally, many EPA offices
had not performed any review  of
such Agency administrative
systems as time and attendance,
overtime, etc.
  In the financial management
area, OIG audits continued to
point out significant inaccuracies
in the Agency's systems. For
example many accounts
receivable were still not being
recorded on  EPA's financial
records. Invalid unliquidated
obligations were not being
identified and deobligated.
Controls over overtime were
weak or nonexistent.
  Although the Agency
responded positively to each
our reports, and has
undertaken positive steps to
correct the identified problen
the OIG intends to continue
performing frequent audits ir
these areas to determine wr
further steps are needed to
correct internal control and
financial management probk

AUDIT FOLLOWUP

Continued efforts are needei
improve and ensure  the acci
of the Agency's  audit followu
tracking system. A year ago,
reported that EPA managem
stopped tracking the correct!
action taken on GAO and Ol
findings while deciding what
improvements were needed
their audit followup system.
result EPA reported its audit
followup system as a major
weakness in its  FMFIA repor
the President.
  In the intervening year, EF
has acted to get its followup
system revised and in place
track corrective action.  In
working with the Agency to
ensure that the new  system
reliable, we found that initial
to the new system contained
significant inaccuracies.
Specifically we noted correct
actions had not been initiate*
some performance audits wr
had been closed out of the
Agency's tracking system. T
we recommended that EPA
implement a quality assuranc
system to ensure that the da
reported is accurate. At pres
we are working with  the Age
to make sure necessary
improvements are made to it
system. In the coming year
will perform additional review
various aspects of the syster

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     Profile  Of Activities  And  Results
Environmental Protection Agency
Office of Inspector General
Audit Operations
                              April 1,1990 to
                              September 30, 1990
Fiscal 1990
                                                                                                    April 1,1990 to
                                                                                                    September 30, 1990
                                                                     Fiscal 1990
$61 .2 Million
$45.6 Million
$45.2 Million
$32.0 Million
$29.3 Million
$22.2 Million
$127.9 Million
$92.9 Million
$84.0 Million
$60.4 Million
$41.6 Million
$31.9 Million
OIG MANAGED AUDITS:

Audits Performed by EPA, IPA and State

Questioned Costs
• Total Ineligible
• Federal Share Ineligible*
• Total Unsupported*
• Federal Share Unsupported*
• Total Unnecessary/Unreasonable*
• Federal Share Unnecessary/
   Unreasonable*
Recommended Efficiencies (Funds be Put to Better Use)
• Total Efficiencies*                  $53.7 Million     $71 .8 Million
• Federal Share Efficiencies*           $34.6 Million     $49.1 Million

Costs Disallowed to be Recovered
• Federal Share Ineligible             $26.0 Million     $56.4 Million
• Federal Share Unsupported          $ 3.3 Million     $1 1 .2 Million
• Federal Share Unnecessary/         $  .7 Million     $ 1.5 Million
Unreasonable (costs which
EPA management agrees are
unallowable and is  committed
to recover or offset against
future payments)

Costs Disallowed as Cost Efficiency
• Federal Share Recommended        $ 3.6 Million     $19.7 Million
Efficiencies (funds made
available by EPA management's
commitment to implement
recommendations in OIG
performance or preaward audits)

OTHER AUDITS:

Audits Performed by Another Federal Agency or
Single Audit Act audits

Questioned Costs
• Total Ineligible                     $ 4.0 Million     $ 7.5 Million
• Federal Share Ineligible*            $ 3.8 Million     $ 7.3 Million
• Total Unsupported*                 $1.1 Million     $ 6.7 Million
• Federal Share Unsupported*         $1.1 Million     $ 6.7 Million
• Total Unnecessary/Unreasonable*    $ 0.0 Million     $ 0.0 Million
• Federal Share Unnecessary/         $ 0.0 Million     $ 0.0 Million
Unreasonable*
Recommended Efficiencies (Funds be Put to Better Use)
• Total Efficiencies*                   $87.8 Million   $112.9 Million
• Federal Share Efficiencies*           $87.8 Million   $112.9 Million
                 Costs Disallowed as Cost Efficiency
                 • Federal Share Recommended          $ 4.1 Million     $99.6 Million
                 Efficiencies (funds made available
                 by EPA management's commitment to
                 implement recommendations in OIG
                 performance or preaward audits)

                 AGENCY RECOVERIES:

                 Recoveries from Audit Resolutions       $35.1 Million     $56.8 Million
                 of Current and Prior Periods (cash
                 collections or offsets to future
                 payments)**

                 REPORTS ISSUED:

                 OIG MANAGED AUDITS:
                 • EPA Audits Performed by the OIG            58          101
                 • EPA Audits Performed by Independent        45          132
                 Public Accountants
                 • EPA Audits Performed by State Auditors      20           35

                 OTHER AUDITS:
                 • EPA Audits Performed by Another           255          413
                 Federal Agency
                 • Single Audit Act Audits                    513         1247

                 TOTAL REPORTS ISSUED                  89~T         T928
                 Audit Reports Resolved (agreement by        331          671
                 Agency officials to take satisfactory
                 corrective action)

                 Investigative Operations

                 • Fines and Recoveries (including civil)    $2,829,501     $3,805,579
                 • Investigations Opened                     144         242
                 • Investigations Closed                      148         251
                 • Indictments of Persons or Rrms              14          17
                 • Convictions of Persons or Rrms               9          13
                 • Administrative Actions Taken Against          6          23
                 EPA Employees

                 Fraud Detection and Prevention Operations

                 • Debarments, Suspensions, Voluntary        110         140
                 Exclusions, and Settlement Agreements
                 (actions to deny persons or firms from
                 participating in  EPA programs or
                 operations because of misconduct or
                 poor performance)
                 • Hotline Complaints Received                20          47
                 • Hotline Complaints Processed  and Closed     27          43
                 • Proposed Legislative and Regulatory
                 Items Reviewed
                 • Personnel Security Investigations            317
                 Adjudicated
                                                                                                                       725
Costs Disallowed to be Recovered
• Federal Share Ineligible              $ 1.8 Million     $ 3.9 Million
• Federal Share Unsupported           $  .7 Million     $ 0.9 Million
• Federal Share Unnecessary/          $ 0.0 Million     $ 0.0 Million
Unreasonable (costs which EPA
management agrees are unallowable
and is committed to recover or offset
against future payments)

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

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

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The Inspector General Act of
1978 (Public Law 95-452), as
amended, created Offices of
Inspector General to consolidate
existing investigative and audit
resources in independent
organizations headed by
Inspectors General.
  EPA established its Office of
Inspector General (OIG) in
January  1980.  As an agency
with a massive public works
budget, EPA is vulnerable to
various kinds of financial abuses.
The OIG's role is to review EPA's
financial  transactions, program
operations, and administrative
activities; investigate allegations
or evidence of possible criminal
and civil  violations; and promote
economic, efficient, and effective
Agency operations. The OIG is
aiso 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
andinvestigations,
  •  Issue subpoenas for evidence
and information,
  •  Obtain access to any
materials in  the Agency,
  •  Report serious or flagrant
problems to Congress,
  •  Select and appoint OIG
employees,
  •  Fill Senior Executive Service
positions,
  •  Administer oaths, and
  •  Enter into contracts.

  The Inspector General is
appointed by, and  can be
removed only by, 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.
                    Nationally, there are seven
                  Divisional Inspectors General for
                  Audit and five Divisional
                  Inspectors General for
                  Investigations who direct staffs of
                  auditors and investigators and
                  who report to the appropriate
                  Assistant Inspector General in
                  Headquarters.

                  Purpose And
                  Requirements Of The
                  Office  Of Inspector
                  General Semiannual
                  Report
                  The Inspector General Act of
                  1978 (Public Law 95-452), as
                  amended, requires the Inspector
                  General to keep the Administrator
                  and Congress fully and currently
                  informed of problems and
                  deficiencies in the Agency's
                  operations and to recommend
                  corrective action.  The IG Act
                  further specifies that semiannual
                  reports will be provided to the
                  Administrator by each April 30
                  and October 31, and to Congress
                  30 days later.  The Administrator
                  may transmit comments to
                  Congress along with the report,
                  but may not change any part of
                  the report.
                   The  specific reporting
                  requirements prescribed in the
                  Inspector General Act of 1978, as
                  amended, are listed below.  The
                  Inspector General Act
                  Amendments of 1988 require
                  more detailed statistics on the
                  status of audit reports, their
recommendations and monetary
results. Also included are
additional requirements resulting
from Senate Report 96-829 on
                the Supplemental Appropriati
                and Rescission Act of 1980
                (Public Law 96-304).
 Source
                               Section and P
 Inspector General Act, as amended

 Section 4(a)(2),     Review of Legislation and          4
                 Regulations

 Section 5(a)(1),     Significant Problems, Abuses,       1
                 and Deficiencies
 Section 5(a)(2),     Recommendations with Respect     1
                 to Significant Problems, Abuses,
                 and Deficiencies

 Section 5(a)(3),     Prior Significant               Appendix 2
                 Recommendations on Which
                 Corrective Action Has Not Been
                 Completed

 Section 5(a)(4),     Matters Referred to  Prosecutive     3
                 Authorities

 Section 5(a)(5),     Summary of Instances  Where       *
                 Information Was Refused

 Section 5(a)(6),     List of Audit Reports          Appendix 1

 Section 5(a)(7),     Summary of Significant Reports      1

Section 5(a)(8),     Statistical Table - Questioned        2
                 Costs

 Section 5(a)(9),     Statistical Table -                  2
                 Recommendations That Funds
                 Be Put To Better Use

 Section 5(a)(10),    Summary of Previous Reports,   Appendix 2
                 No Management Decisions, an
                 Explanation of the Reasons Such
                 Management Decision  Has Not
                 Been Made, and a Statement
                 Concerning the Desired
                 Timetable for Achieving a
                 Management Decision  on Each
                 Such Report

 Section 5(a)(111.    Description And Explanation of   Appendix 2
                 Revised Management Decisions

Section 5(a)(12),    Management Decisions With         2
                 Which The Inspector General Is
                 In Disagreement

Senate Report 96-829
Senate Report,     Resolution of Audits                2
Page 11,
Senate Report,
Page 12,
Delinquent Debts
Staffing Distribution—Fiscal
1990 Ceiling
 Office
Staff & Support  Operations & Field   Total
Inspector General
Audit
Investigations
Management
Total
5
29
6
28
68
-
183
60
-
243
5
212
66
28
311
 *There were no instances where information or assistance
 requested by the Inspector General was refused during this
 reporting period. Accordingly, we have nothing to report under
 section 5(a)(5) of the Inspector General Act of 1978, as amendec

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

                                          Anna Hopkins Virbick
        Office of Audit
        Kenneth A. Konz
        Assistant  Inspector General
        James O. Rauch
        Deputy
            Operations Staff
            Elissa R. Karpf
            Director
Office Of Investigations
John E. Barden
Assistant Inspector General
Daniel S. Sweeney
Deputy
            Technical Assistance Staff
            Gordon Milbourn
            Director
Office of Management
John C. Jones
Assistant  Inspector General
                                     Technical Assessment and
                                     Fraud Prevention Division
                                     Vacant
                                     Director
                                      Administrative and
                                      Management Services
                                      Division
                                      Michael J. Binder
                                      Director
            Planning and Resources
            Management Staff
            Edward Gekosky
            Director
       Divisional Inspectors General
                                               Region 5
                                               Anthony C. Carrollo, Audit

                                               Region 5, 7, & 8
                                               Alex Falcon, Investigations
Region 9 & 10
Truman R. Beeler,
Audit

H. Brooks Griffin
Investigations
                        Region 7 & 8
                        Nikki Tinsley, Audit
                                                             Region 4 & 6
                                                             Mary Boyer, Audit
                                                             James F, Johnson,
                                                             Investigations
                                              Region 1 & 2
                                              Paul McKechnie, Audit
                                              Robert M. Byrnes,
                                              Investigations

                                              Region 3
                                              Paul R. Gandolfo, Audit
                                              Martin Squitieri
                                              Investigations

                                              Headquarters
                                              Kenneth Hockman,
                                              Internal Audit

                                              Francis C. Kiley
                                              Washington Field Office
                                              Investigations

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   Section   1—Significant Problems, Abuses,  And Recommendations
As required by sections 5(aX1)
and (2) of the Inspector General
Act of 1978, as amended, this
section identifies significant
problems, abuses, and
deficiencies relating to the
Agency's programs and
operations along with recom-
mendations for the current
period. The findings described
in this section resulted from
audits and reviews performed by
or for the Office of Audit and
reviews conducted by the Office
of Investigations.  Because these
represent some of our most
significant findings, they should
not be considered representative
of the overall adequacy of EPA
management Audit findings are
open to further review but are
the final position of the Office of
Inspector General. This section
is divided into five areas:
Summary of Audit Activities and
Results, Agency Management,
Construction Grants, Super-fund,
and Special and Prospective
Reviews.
Summary of
Audit Activities
and Results
Questioned Cost and Recommended Efficiencies by Type of Report

  160
                                                                                           Non-fed Rec Eft.
                                   Construction
                       Others
Superfund
Int / Mgt
                                                                                           Fed Share Ree Efl.
                                                                                           Non-Fed Quest.



                                                                                           Federal Quest.
           Areas of Effort by Staff Days
                                                  Source of Reports
                                  Performance
                                  4,869   30.7%
                                                         EPA
                                                         58    6.5%
                                                          IPA's
                                                          45    5.1%
                                                                                               State Auditors
                                                                                               20    2 2%
                 Total-  15,581
                                                                              Total Reports - 891

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Agency
Management
 The Inspector General Act
 requires the OIG to Initiate
 reviews and other activities to
 promote economy and efficiency
 and to detect and prevent fraud,
 waste, and mismanagement in
 EPA programs and operations.
 Internal and management audits
 and reviews are conducted to
 accomplish these objectives
 largely by evaluating the
 economy, efficiency, and
 effectiveness of operations.
  The following are the most
 significant internal and
 management audit and review
 findings and recommendations:
Improperly stored pesticides
(photo by OIG staff).
Audit Spurs Rapid
Action To Tighten
Controls  Over
Banned Pesticides
Problem

EPA still had not ensured that
emergency suspended and
cancelled (banned) pesticide
holders safely controlled their
stocks and complied with
disposal rules.

Background

After hearings in 1986 and 1987,
the House Government
Operations Committee
recommended that EPA develop
a policy for holders to properly
store and report banned
pesticides. The Committee found
that thousands of gallons of a
pesticide had leaked into the
environment; neither EPA nor
companies storing the banned
pesticide had acted  to prevent
this leakage; and emergency
planners and fire officials were
unaware of banned  pesticides in
their communities.

We Found That

• EPA still had not monitored and
periodically inspected most
banned pesticide storage
locations to determine whether
the pesticide was safely stored
nor always required holders to
overpack corroding  or leaking
containers to prevent spills. For
example, neither EPA nor State
pesticide officials  inspected a
Goldsboro, North Carolina,
warehouse where 31,875 gallons
of a banned pesticide, Dinoseb,
corroded its containers and
leaked. A similar example was
also found in Bakersfield,
California. North Carolina
officials were unaware that the
pesticide was in the state
because EPA had not provided
them a current Dinoseb holders
list.

• EPA had not established a
procedure to inform emergency
planners and fire  officials
regarding banned pesticide
storage locations and pesticide
handling in an emergency.
Consequently, emergency
 planners and fire officials would
 not be ready to deal with
 potential emergencies involving
 banned pesticides.

 • Regions and States could not
 fully identify and inspect all
 known banned pesticide storage
 locations because EPA had not
 fully developed procedures to
 match Headquarters, regional,
 and state records.

 • EPA had not investigated cases
 where EPA pesticide contractor
 records suggested questionable
 holder disposal actions.

 We Recommended That

 The Assistant Administrator for
 Pesticides and Toxic Substances:

 • implement a plan to monitor
 and periodically inspect banned
 pesticide storage locations until
 holders properly dispose of their
 stocks;

 • Alert emergency planners and
 fire officials of banned pesticide
 storage locations and handling
 procedures;

 • Reconcile EPA and State
 records to ensure that EPA has a
 current listing of all known
 banned pesticide locations and
 quantities;

 • Establish procedures to have
 EPA pesticide contractor
 information referred to
 enforcement officials.

 What Action Was Taken

 EPA acted promptly on all the
 Issues we raised during the audit
 During our review, EPA issued a
 banned pesticide strategy to its
 regions and the States requiring
 them to monitor and inspect
 storage locations.  EPA also
 implemented a plan to have
 emergency planners and fire
 officials receive its banned
 pesticide storage location list.  In
 addition, EPA took initiatives to
 better account for the banned
 pesticide quantities and storage
 locations.
  The audit report (0100486) was
issued to the Assistant
Administrator for Pesticides and
 Toxic Substances on September
28, 1990. A response to the
audit report is due December 27,
 1990.
 Increased Efforts
 Needed To  Protect
 The Public  Against
 Lead In Drinking
 Water


 Problem

 EPA and the states in Region 3
 were not ensuring that school
 children and the public were
 adequately protected against
 excessive levels of lead in
 drinking water.

 Background

 Medical research has shown that
 lead can be harmful to human
 health even at low exposure
 levels, potentially resulting in
 serious damage to the brain,
 kidneys, nervous system, and red
 blood cells. EPA estimates that
 every year over 250,000 children
 are exposed to lead in drinking
 water at a level high enough to
 impair their intellectual and
 physical development. The 1986
 amendments to the Safe Drinking
Water Act (SDWA) banned the
 use of lead materials in new
 plumbing and in plumbing repairs
and required water suppliers to
 notify the public about lead in
their drinking water. In 1988, the
Lead Contamination Control Act
(LCCA), required EPA, states,
the Consumer Product Safety
Commission (CPSC), and
schools and day care centers to
safeguard children  from the
hazards of lead in drinking water.
Lead in drinking water can be
particularly harmful to children
(photo by Steve Delaney).

-------
We Found That

• States in Region 3 had not
developed adequate programs to
assist schools and day care
centers deal with lead
contamination in their drinking
water. While some of the
schools did  limited, improper, or
no testing, many schools testing
found that their water contained
unacceptable levels of lead.

• EPA was a year late in
publishing the required initial list
of imminently hazardous water
coolers with lead-lined tanks or
lead parts.

• EPA did not pursue the States'
lack of enforcement concerning
the public notification and lead
ban requirements of the SDWA.
States did not ensure that all
public water systems notified their
customers of the dangers of lead
in their drinking water, and did
not adequately enforce the
prohibition on the use of lead
pipes, solder, and flux in
plumbing providing water for
human consumption.

• Laboratories were
inappropriately advising schools
that the drinking water was safe
when, in fact, it was not because
laboratories did not always
receive or comply with new EPA
criteria on acceptable levels of
lead in schools' drinking water.

We Recommended That

The Assistant Administrator for
Water:

• Prepare model plans and
perform additional outreach to
assist states with their lead in
drinking water programs.

• Establish  procedures for issuing
timely revisions to the EPA list of
Drinking Water Coolers That Are
Not Lead Free.

•  Execute an Interagency
Agreement with the CPSC
defining each agency's
responsibilities under the LCCA.

•  Develop an enforcement
strategy for States to effectively
implement the lead ban. Also,
the Agency should provide
guidance to the Regions
requesting States to report lead
ban enforcement actions to
Regional offices.
• Request states to inform their
certified laboratories of EPA's
recommended action for samples
exceeding 20 parts per billion of
lead in drinking water.

What Action Was Taken

Prior to the issuance of our draft
report, EPA promptly took
corrective action on our finding
concerning confusion over
acceptable limits of lead in
drinking water from school
fountains.  The Office of Drinking
Water developed an Alert for
Laboratory Directors requesting
their assistance in notifying
school administrators that EPA
recommends they take remedial
action whenever leads levels
exceed 20 ppb at one of their
drinking water outlets.  The audit
report (0100508) was issued to
the Assistant Administrator for
Water on September 28, 1990.  A
response is due December 27,
1990.

Stronger
Enforcement
Needed To  Prevent
Damage From  Oil
Spills


Problem

Over  two years after the oil
spills at the Ashland Oil facility
in Pennsylvania and the Shell
Oil facility in California,
aggressive enforcement
actions were not always taken
when violations of EPA's Oil
Pollution Prevention
regulations were disclosed.

Background

EPA's Oil Pollution Prevention
regulations implement the oil spill
prevention and removal
provisions of the Clean Water
Act. These regulations require
the owners and operators of
certain oil storage facilities to
prepare Spill Prevention Control
and Countermeasure (SPCC)
plans outlining measures to
prevent spills and contain those
that do occur before they reach
navigable waters.  EPA's  regional
offices administer an inspection
program to ensure that facilities
comply with the regulations.
  In January 1988, about  1 million
gallons of diesel fuel and
gasoline spilled into the
Monongahela River when an
aboveground storage tank
collapsed at the Ashland Oil
facility near Pittsburgh.  During
April 1988, 400,000 gallons of
crude oil drained into a marsh
near San Francisco Bay from an
aboveground tank at a Shell Oil
Company facility.  These and
other spills had adverse impacts
on the environment and were
costly to clean up.

We Found That

Although the Agency has initiated
some corrective measures as a
result of past reviews, more
action is clearly needed. While
Regions 5 and 6 had effective
SPCC enforcement programs, we
found that effective enforcement
action was not always taken by
Regions 3 and 4 against facilities
that violated EPA's Oil Pollution
Prevention regulations. The
enforcement actions taken by
Regions 3 and 4 did not ensure
that violating facilities eventually
achieved compliance with the
Agency's regulations.
  For example, an inspection
performed at a Pennsylvania
facility by Region 3 in 1986
disclosed that this facility did not
have an SPCC plan. In
September 1986, a Notice of
Violation was issued and a
$3,000 penalty assessed.
However, there was no evidence
that the facility responded to the
Notice of Violation or paid the
penalty. On March 7, 1989, more
than 10,000 gallons of diesel fuel
spilled from an aboveground tank
at this same facility, which still did
not have a spill prevention plan.

We Recommended That

The Assistant Administrator for
Solid Waste and Emergency
Response provide oversight to
ensure each region performs
adequate enforcement when
inspections  disclose violations
and appropriate action is taken to
correct deficiencies.
What Action Was Taken

The audit report (0100491) was
issued to the Assistant
Administrator for Solid Waste and
Emergency Response on
September 24, 1990.  A response
to the audit report is due
December 23,  1990.
Better Oversight
And Enforcement
Needed In Region
Pesticide  Control
Program
Problem

EPA Region 6 oversight of
state pesticide programs did
not ensure that delegated
states took appropriate
enforcement actions against
violators of pesticide laws.
Problems identified by EPA i
oversight reviews of state
pesticide programs were not
corrected timely. Also, Regi
6 was not taking timely
enforcement actions, nor
properly tracking cases
referred to states.

Background

Under the Federal Insecticide,
Fungicide, and Rodenticide Ac
(FIFRA), the states have prims
pesticide enforcement
responsibility and EPA has
responsibility for oversight of tf
states' enforcement programs.
EPA ensures that state progra
are effective in meeting the
requirements of FIFRA by
performing mid-year and year-
end program evaluations. A si
has 90 days to correct any
deficiencies, or EPA may resci
all or part of the program
delegated to the state. If state
do not initiate timely enforcemt
actions, then EPA may do so.

We Found That

Region 6 was not consistently
and accurately reporting overs!
results, nor was the Region
requiring timely state actions tc
correct problems identified.  Ah
Region 6 did not properly tracl>
significant cases referred to
states for enforcement, nor did
make sure states took
appropriate or timely action.  Ir
two of the three states reviews
enforcement actions against
FIFRA violators were either tax
weak or too late. One state hi
not established administrative
penalty authority under its stati
laws, which hindered

-------
 mforcement actions. The other
 tate was not timely because it
 onsidered all inspections as
 ases even though no
 mforcement action was needed.
 Vithout effective oversight,
 'iolators are more likely to repeat
 iffenses, further exposing the
 iublic and the environment to the
 iffects of harmful pesticides.

 /e Recommended That

 'he Regional Administrator,
 legion 6:

 > Work actively with the states
 vhich do not have administrative
 enalty authority so that they may
 ibtain it;

 • Establish a time standard for
 recessing FIFRA cases referred
 om states and procedures to
 msure that these standards are
 let;

 > Conduct comprehensive mid-
 •ear and year-end evaluations of
 itate FIFRA programs;

 • Negotiate corrective action
 ilans with states for any
 eficiencies identified during
 valuations; and,

 • Track and monitor significant
 :IFRA referrals to states, and
 vhere necessary, take over
 mforcement of cases when the
 tates do not take timely action.

 Vhat Action Was Taken

 'he audit report (0100470) was
 ssued to the Regional
 \dministrator, Region 6, on
 September 5,  1990. A response
 o the audit report Is due
 December 4, 1990.

 Jlarine  Discharge
 Waiver Program In
 Region 2 Needs
 mprovement


 'roblem

Region 2 was not aggressively
administering the Clean Water
Act Section 301 (h) marine
discharge waiver program to
protect the marine environment
from the harmful effects of
sewage treatment discharges
in Puerto Rico and the Virgin
Islands.
Background

The Federal Water Pollution
Control Act Amendments of 1972
required that all publicly-owned
treatment works (POTWs)
achieve minimum effluent limits of
secondary wastewater treatment
by July 1,1977. However in
1977, Congress added Section
301 (h) to the Clean Water Act to
provide case-by-case
modifications (waivers) of
secondary treatment
requirements for POTWs
discharging into marine
environments if there would be
no decrease in ambient water
quality or adverse impact on
marine biota.
We Found That

Region 2 generally resolved New
York and New Jersey waiver
applications, but did not act
timely on those submitted by
Puerto Rico and the Virgin
Islands. The Region made only
one final determination on 14
Puerto Rico and Virgin Islands
applications originally submitted
in 1979 (four were subsequently
withdrawn).
  Although aware of most Puerto
Rico and Virgin Islands POTW
performance shortcomings, the
Region had not denied
applications despite making
numerous threats to do so.
Facilities have continued to
discharge less than secondary-
treated wastewater into the ocean
for over 10 years,  potentially
affecting the marine environment
and human health. The Region
may have been reluctant to issue
final denials in view of the
precarious financial condition of
some Puerto Rico  and Virgin
Islands POTWs.

We Recommended That

The Regional Administrator,
Region 2, develop and
implement:

• Guidelines with specific
timeframes for review and
determinations of pending
applications and data
submissions;

• Procedures to effectively
monitor applicants' compliance
with interim effluent limits; and
• Procedures to ensure timely
conversions of tentative
approvals to final approvals.

What Action Was Taken

The audit report (0100482) was
issued to the Regional
Administrator, Region 2, on
September 18, 1990.  A response
to the audit report is due
December 17, 1990.


EPA  Headquarters
Frequently Misused
Overtime


Problem

Controls over authorizing,
recording and paying overtime
were weak in six EPA
Headquarters offices, raising
serious questions about the
condition of the entire
timekeeping system.  Also,
offices violated EPA policy by
repeatedly using overtime,
sometimes clearly for non-
essential work.  As a result,
unnecessary overtime
payments may have been made
to employees.

Background

Under EPA's policy, occasional or
irregular overtime can be used to
avoid a  serious backlog of work,
during a special workload peak or
emergency, or to meet a special
project deadline.

We Found That

Most of the offices reviewed had
violated EPA policy by using
overtime continually during fiscal
years 1988 and 1989.
Frequently, it was the same
employees working overtime,
sometimes in substantial
amounts, week after week.  Also,
some offices used overtime to
perform normal workday tasks,
such as answering telephones
and  receiving training. Many
employees both worked overtime
and  took paid annual leave in the
same pay period; sometimes this
occurred for  months at a time.
  Fifty-three percent of non-
emergency justifications we
 reviewed were approved after the
 overtime was worked.  Thirty-
 eight percent of the reviewed
 overtime justifications had critical
 information changed, such as
 increasing the number of
 authorized hours or the dates or
 persons, apparently after the
 hours were worked.  For
 timecards that showed overtime
 hours, 14 percent were not
 accurate, 20 percent had been
 altered or changed improperly;
 and 7 percent had not been
 properly approved. Generally,
 finance personnel did not identify
 these problem timecards and
 have them corrected. In addition,
 none of the supervisors were
 post-verifying overtime claims in
 the manner required, and none of
 the offices had an adequate
 separation of timekeeping duties.
  While the existence and degree
 of seriousness of each of these
 individual conditions varied from
 office to office, their totality
 created an overall weakness in
 controls. As a result, employees
 may have been paid incorrectly
 or inappropriately, and the
 potential for abuses and waste
 was increased.

 We Recommended That

 The Assistant Administrator for
 Administration and Resources
 Management:

 • Require senior managers to
 reevaluate their timekeeping
 internal controls and immediately
 correct weaknesses;

 • Make presentations to
 Headquarters supervisors and
 managers regarding  their
 responsibilities in, and the
 internal controls over, the
 timekeeping process;

 • Develop a pay administration
 presentation to be included in the
 Agency training courses given to
 all supervisors; and

 • Revise the pay administration
 guidelines to ensures that
 information  presented is accurate,
 useful, and  current.

 What Action Was Taken

 The final report (0100419) was
 Issued to the Assistant
Administrator for Administration
and Resources Management on
August 1, 1990. On August 29,
                                                                                                                       11

-------
1990, the Assistant Administrator
advised Agency top managers of
the problems disclosed by our
report and provided us a plan
that identifies actions already
taken or planned in response to
our findings and
recommendations. A response to
the report is due October 30,
1990.
Construction Grant
Obligations
Overstated By $55
Million
 100
                Amt Review
                Amt Req Oeoblig
Problem

EPA's Regional offices did not
take timely action to deobligate
over $55 million of unneeded
construction grant funds.

Background

Title II of the Federal Water
Pollution Control Act (the Clean
Water Act), as amended,
authorizes EPA to award
construction grants for
wastewater treatment projects.
Since 1972, the Agency has
awarded over $45 billion for this
purpose.

We Found That

Over $55 million of the $143
million of unliquidated
construction grant obligations we
reviewed in  Regions 2,  3, 5 and 9
were invalid and should have
been deobligated. Most of these
obligations were invalid because
the work had been completed
and the grantee had submitted a
final claim which was less than
the grant amount.  The excess
funding remained idle an average
of 34 months. Over 70 percent
of the funds needing to be
deobligated were in Region 2.
That Region waited until final
project closeout, before
deobligating unneeded funds
instead of when projects were
complete and the final claims
were submitted. This practice
was not consistent with Agency
guidance. In 1982, EPA's
Administrator urged the Regions
to deobligate funds for projects
when the final claim was less
than the grant amount.  When
Regions do not deobligate
unneeded construction grant
funds they are depriving other
projects of badly needed funds
and the public of improved water
quality that these projects would
bring.

We Recommended That

The Assistant Administrator for
Administration and Resources
Management and the Assistant
Administrator for Water request
that all Regional Administrators
direct their staffs to review
administratively completed grants
in their regions and deobligate
unneeded funds, and notify the
Assistant Administrators of
actions taken. We also
recommended the Regional
Administrators be requested to
perform an internal control review
or an alternative internal control
review in accordance with the
Federal Managers' Financial
Integrity Act during fiscal  1991 to
confirm whether funds are being
deobligated in accordance with
Agency policy.

What Action Was Taken

The audit report (0100523) was
issued to the Assistant
Administrators for Water and
Administration and Resources
Management on September 27,
1990.  A  response to the audit
report is due December 26, 1990.
Before the issuance of the final
report, Region 2 initiated
corrective actions and
deobligated $10.5 million of
unneeded construction grant
funds.
EPA Did Not Test
Internal Controls
September 25, 1990, that act
were being taken to address
each of the recommendation.
Problem

Managers were not adequately
testing or documenting Agency
internal controls as part of
reviews to identify and correct
weaknesses in their major
activities as required by the
Federal Managers' Financial
Integrity Act (FMFIA).

We Found That

Of the 36 FMFIA control reviews
reported by Agency managers in
the four offices we reviewed, 29
had not tested controls.  These
reviews were not effective in
identifying and correcting internal
control weaknesses and provided
Agency managers with limited
information to judge the
effectiveness of controls in (1)
detecting potential fraud, abuse,
waste, and mismanagement and
(2) increasing the efficiency and
effectiveness of Agency
operations and programs.
Further, the Agency had
overstated the thoroughness of
the internal control review
process in its fiscal 1989 FMFIA
assurance letter to the President
of the United States.
  In addition, Agency managers
had not documented all major
activities and organizational
controls, limiting the usefulness of
documentation  in identifying
areas where additional controls
were needed.

We Recommended That

The Assistant Administrator for
Administration and Resources
Management:

• provide additional guidance on
control reviews and internal
control documentation; and

• evaluate control  reviews and
internal control documentation
prepared by managers to ensure
they meet FMFIA objectives.

What Action Was Taken

The audit report (0100357)  was
issued to the Assistant
Administrator for Administration
and Resources Management on
June 22, 1990.  The Assistant
Administrator responded on

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 Construction
 Grants
EPA's wastewater treatment
works construction grants
program is the largest single
program the Agency administers.
Under the provisions of Public
Law 92-500, as amended, the
Agency is authorized to make
grants covering 55 percent and,
in some Instances, up to 85
percent of the eligible costs of
constructing wastewater
treatment  facilities.  During fiscal
year 1990, $1 billion was
obligated on 228 new awards and
1,141 increases to existing
grants.  As of September 30,
1990, there were a total of 1,408
active construction grants,
representing $7.7 billion in
Federal obligations.
  Amendments to the
construction grants program are
covered in Title II of the Water
Quality Act of 1987.  Section 212
creates a new Title VI in the
Clean Water Act, which
addresses the process of phasing
out the construction grants
program by providing incentives
for development of alternative
funding mechanisms by the
States.  The new Title VI charges
EPA with developing and
implementing a program to
provide grants to capitalize State
revolving funds for financing
wastewater projects.
  During this semiannual period,
$1.4 billion was awarded on 8
new capitalization grants and  41
existing grants.  As of September
30,  1990, EPA had obligated $2.8
billion to 50 States and Puerto
Rico under the State Revolving
Fund program.
                                                                                                                         13

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Over $29  Million Of
Questioned Costs
Claimed By
Honolulu, Hawaii
Millions of Dollars
               Non-Federal
Problem

The City and County of
Honolulu, Hawaii, claimed
$17,655,814 of ineligible
construction, engineering, and
labor costs. An additional
$9,085,152 of unreasonable
and $2,493,500 of unnecessary
costs were also questioned.

We Found That

EPA awarded thirteen grants
totaling $54,208,201 to the City
and County of Honolulu, Hawaii,
to fulfill multiple objectives,
including the construction of
wastewater treatment facilities
and collector systems. We
questioned $17,655,814 of the
grantee's final claim as ineligible,
including:

• $8,861,055 of construction
costs for equipment items that
were not used or had been
abandoned by the grantee;

• $4,626,365 of change orders
for equipment modification work
necessitated by the grantee's
operation and maintenance
problems after construction;

• $1,121,528 of design and
installation costs associated with
emergency power generators
determined to be unnecessary
and outside the scope of the
approved project; and

• $932,730 of administrative and
force account labor costs,
because the grantee's labor
charging procedures did not
adequately identify whether
employees worked on eligible or
ineligible tasks.
We also questioned, as
unreasonable, $8,533,513 for
underutilized facilities that were
operating at less than 75 percent
of their design capacity and
$551,639 for a planning grant
which was never completed and
for which design and construction
grants had never been awarded.
The grantee also claimed
$2,493,500 of unnecessary costs
incurred for equipment items that
were not in service.

We Recommended That

The Regional Administrator,
Region 9, not participate in the
Federal share of the ineligible
costs ($13,241,859), determine
the eligibility of the Federal share
of unreasonable costs
($6,813,865) and unnecessary
costs ($1,870,125), and recover
the applicable amount from the
grantee.

What Action Was Taken

Three audit reports (0300090,
0300091, and 0300092) were
issued to the Regional
Administrator,  Region 9 on
September 19, 1990. A final
response is due December 18,
1990.
                               Nearly  $11 Million
                               Of Bartlesville,
                               Oklahoma, Project
                               Claims Are
                               Ineligible Or
                               Unsupported
                               Millions of Dollars
 ^m Federal       Non-federalf    |


 Problem

 The City of Bartlesville,
 Oklahoma, claimed $10,933,043
 of ineligible construction,
 engineering, and arbitration
 costs.
We Found That

EPA awarded six grants totalling
$13,044,311 to the City of
Bartlesville, Oklahoma, to assist
in planning, designing and
constructing a wastewater
treatment plant, collection and
interceptor lines, lift stations,
force mains and relief sewers.
We questioned $10,933,043 of
the grantee's final claim as
ineligible, including:

• $10,157,450 of construction
and engineering costs related to
the construction of larger
facilities and replacement of
major system  components. The
1976 facilities plan provided for a
smaller facility and rehabilitation
of system components. As a
result, project costs increased
from $3.2 million to $9.7 million.
The grantee did not revise the
original facilities plan  or
demonstrate that the  new plant
was cost-effective;

• $591,573 of architectural
engineering fees incurred prior to
facilities plan approval;

• $101,320 of engineering costs
incurred because the grantee
failed to use the engineer
involved with the construction
phase as the engineer for startup
operations; and

• $82,700 of construction costs
not paid to the contractor, and
arbitration expenses incurred
before grant approval.

We also questioned $41,742  of
inadequately supported force
account engineering costs.

We Recommended That

The Regional  Administrator,
Region 6, not participate in the
Federal share of ineligible costs
($8,199,782); determine the
eligibility of the Federal share of
unsupported costs ($31,307); and
recover the applicable amount
from the grantee.

What Action Was Taken

The audit report (0300055) was
issued to the Regional
Administrator, Region 6, on May
11, 1990. A response to the
audit report due on August 9,
1990, had not been received as
of October 26, 1990.
San  Francisco
Claims Over  $3
Million  Of Costs
Unrelated To EPA
Grant
                                                                                            San Francisco, CA
Millions of Dollars

^^^1 Federal      Non-Federal |


Problem
The City and County of San
Francisco (CCSF), California,
claimed $3,381,272 of costs I
improvements to the Great
Highway and surrounding ar
that were not a part of the El
grant. An additional $497,87
of ineligible construction cos
were questioned.

We Found That

EPA awarded a grant and
amendments to CCSF for the
construction  of the Westside
Storage and Treatment Facilitie
including the repair and
replacement of the northbound
lanes of the  Great Highway wh
were destroyed during
construction of the undergroum
consolidation sewer. Of the
$4,587,536 claimed for the
Highway Project, we questione
                                                                                           Extensive land-scaping improve
                                                                                           ments were improperly claimed
                                                                                           as part of an EPA grant (photo
                                                                                           OIG staff).
14

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3,381,272 for replacement of the Problem
outhbound lanes which were not
amaged by construction, plus
le following improvements to
atisfy the goals of the California
loastal Commission and National
'ark Service:
 Rehabilitating three public
 istrooms;
 Constructing paved pedestrian

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Super-fund
Program
• Examination of a sample of
agreements with States carrying
out response actions; and
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
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 Inspector General a
number of specific
responsibilities. Mandatory
annual audit areas include:

• Audit of all payments,
obligations, reimbursements, or
other uses of the Fund;

• Audit of Superfund claims;
                              to submit an annual report to the
                              Congress regarding the required
                              Superfund audit work, containing
                              such recommendations as the
                              Inspector General deems
                              appropriate.  The third annual
                              report, covering fiscal 1989, was
                              issued on September 28, 1990.
                                In addition, the EPA
                              Administrator is required to
The Inspector General is required submit a detailed annual report to
• Examination of remedial
investigations and feasibility
studies prepared for remedial
actions.
the Congress on January 1 i
each year on the progress
achieved in Implementing
CERCLA during the precedii
fiscal year.  The OIG is requ
to review this report for
reasonableness and accurat
and the Agency is required t
attach the result of the OIG
review to the Agency's annu
report.

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 Region 4
 nadequately
 Managed
 'Removal"
 Cleanups
 'roblem

 Region 4's inadequate
 mplementation and ineffective
 lanagement of "removial"
 :leanup actions (1) did not
 leet "removial" goals to
 expedite remedial cleanup and
 o delete sites from EPA's
 National Priorities List (NPL)
 delisting), and (2) resulted in
 >ver $3.8 million in potentially
 ixcessive costs and
 >bligations.

 Background

 "he Superfund program includes
 wo broad categories of response
 o the release, or threat of
 elease, of hazardous substances
 rom abandoned hazardous
 vaste sites. Short-term removal
 ctions address the release or
 ireat of releases requiring  an
 ixpedited response. Longer-
 erm, more permanent remedial
 ictions are taken to stop or
 ubstantially reduce the release
 Dr threat of release of hazardous
 iubstances that are not
 mmediately life threatening.
  Region 4 ambitiously initiated a
 }ilot "removial" cleanup approach
 which used removal authorities to
 ixpedite remedial actions and
 si PL site delisting at less cost
 han projected for remedial
 cleanups.  Eight NPL sites
 tcheduled for remedial actions  in
 iscal 1988 were selected for
 "removial" cleanup.

 Ne Found That

After two years and $15 million in
obligations, of which $8.7 million
had been expended, only 3 of the
8 sites had been partially cleaned
and none had been delisted.
Region 4's inadequate
implementation and management
of the "removial" cleanups
prolonged cleanup actions;
permitted deficient site
characterizations; allowed
unsupported changes to cleanup
levels and remedies; and resulted
in potentially unnecessary,
inappropriate, or excessive
cleanup actions involving over
$3.8 million in Superfund costs
and unpaid obligations.
  Inadequate delineation of
"removial" authorities and
responsibilities between removal
and remedial staffs, insufficient
oversight of "removial" cleanup
actions, and omission or
inadequate completion of key
remedial requirements, including
State Superfund Contracts,
contributed to program
deficiencies. In addition, the
Region created potential conflicts
of interest by having the same
contractors (1) characterize
contamination and clean up the
sites, and  (2) design and
construct treatment systems.
  Many of the sites Region 4
selected for "removial" cleanup
did not comply with EPA
guidance for selection of
"removial" sites. Selections were
based more on quick
accomplishment of Regional
goals than on public and
environmental threats.

We Recommended That

The Regional Administrator,
Region 4:

• Promulgate formal procedures
for "removial" approach to
facilitate coordination between
removal and remedial staffs and
establish better controls over
"removial" cleanup actions.

• Hold Superfund  program
managers strictly accountable for
compliance with established
procedures and controls to
ensure program integrity and
maintenance of the public trust.

• Adequately determine the type
and extent of contamination
before selecting future NPL sites
for "removial" cleanups.

• Establish controls to ensure
that all key removal and remedial
requirements are properly
completed and that selected
remedies and cleanup levels are
changed only when thoroughly
justified.

• Establish controls to preclude
assignment of tasks to
contractors that create potential
or apparent conflict of interest
situations and conflict with
Agency directives.

What Action Was Taken

The audit report (0100519) was
issued to the Regional
Administrator, Region 4, on
September 27, 1990.  A response
to the audit report is due
December 26,  1990.
California Multi-
site Agreement
Lacks Effective
Controls

Problem

The California State Water
Resources Control Board
(SWRCB) had not established
effective management and
financial controls to protect the
public health and accurately
account for the $2.9 million of
costs under the South Bay,
California, Multi-Site
Cooperative Agreement

Background

Since 1981,  91 of 100
contamination problems identified
in the San Francisco area were
located in South Bay. SWRCB
was responsible for overall
management of an agreement
with EPA to address ground
water contamination in  the South
Bay.

We Found That

SWRCB had not provided the
guidance, staffing or training
necessary to perform effective
site inspections and take
aggressive enforcement actions
to comply with Federal
regulations and the agreement.
For example, SWRCB site
inspectors performed limited on-
site inspections, relying on
reports submitted by potentially
responsible parties, and did not
conduct on-site follow-up
inspections to ensure previously
reported deficiencies were
corrected. The resulting
potentially health-threatening
conditions were observed at three
South Bay sites:
• potentially toxic soil was placed
in open containers across the
street from a residential
neighborhood.

• toxic water flowed into a canal
in a residential district exceeding
maximum contamination levels
for public safety.

• contaminated water leaked
from a tower onto the ground,
threatening the release of
airborne pollutants and return of
the water to the groundwater
tables where it was first
extracted.

SWRCB's financial system did
not provide for accurate, current,
and detailed accounting of costs
nor documentation supporting the
allocation of funds.  We
questioned all $2,903,899 of
costs claimed at the time of audit.

We Recommended That

The Regional Administrator,
Region 9, require the SWRCB to
develop an effective hazardous
waste site inspection program for
the South Bay Multi-Site
Cooperative Agreement which
includes the development of
inspection guidelines, devotion of
sufficient staff, and a mandatory
training program; disallow the
$2,903,899 of ineligible costs
questioned and recover the
amounts previously paid  to the
SWRCB; and suspend all
payments under the cooperative
agreement until the SWRCB has
corrected its financial
management deficiencies.

What Action Was Taken

The audit report (0300098) was
issued to the Regional
Administrator, Region 9, on
September 28, 1990. A response
is due December 27, 1990.
                                                                                                                        17

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Guidance  Needed
For Disposing Of
Wastes Generated
From  Pre-Remedial
SITE  Inspections

Problem

Contractors used poor
judgment and made mistakes
in disposing of wastes
generated from  pre-remedial
site investigations conducted
for EPA.

Background

Under the Agency's Superfund
Pre-Remedial Program EPA
contractors evaluate suspected
uncontrolled hazardous
substance release sites. The
contractors' staff often visit sites
and take samples which are sent
to laboratories that are
responsible for their proper
disposal after analysis.  In the
process of taking samples,
equipment and clothing can be
contaminated and existing waste
disturbed.

We Found That

EPA had no specific formal
guidance for disposing of wastes
stemming from pre-remedial site
investigations. In one instance,
in July 1989, three employees  of
a Region 5 contractor discarded
their disposable protective gear
(Tyvek suits, boots, and gloves)
and testing materials in a
garbage container in  a public
park. Two teenage park
employees found bags containing
the waste. Concerned that toxics
could be present, the park district
notified the fire and police
department.  The Champaign-
Urbana Hazardous Materials
Team was called to the scene
and treated the incident as a
hazardous waste release. The
contractor employees were
charged with, but not convicted
of, violating an Illinois garbage
disposal statute.  Later testing
determined that the material was
not hazardous, and the contractor
disposed of it.
  In January 1990, in Region 9,
an EPA contractor in another
instance arranged for a waste
disposal subcontractor to pick up
two drums of waste labelled
"hazardous." The subcontractor
unloaded the drums on the
roadside after being locked
outside the facility when the
facility representative refused to
sign the manifest as the waste
generator. About two hours later,
at the contractor's direction, the
subcontractor moved the drums
inside the gate by lifting them
over the fence.  The contractor
arranged for the drums to be
picked up the next day. No
public incident was created, but
for an estimated hour or two, two
drums marked "hazardous" were
left on a roadside.

What Action Was Taken

The special report (0400044) was
issued to the Assistant
Administrator for Solid Waste and
Emergency Response on
September 28, 1990. Before the
issuance of the  final report, EPA
initiated corrective actions.  The
Agency drafted guidance on
investigative-derived waste, and
distributed it on  July 11, 1990, for
comment.  Final guidance is
scheduled to be issued by the
end of October  1990 as a part of
an Agency directive.
 Special And
 Prospective
 Reviews
This section in our semiannual
report describes significant and
potential findings,  deficiencies,
and recommendations which
have been identified through
evaluations, analyses, 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.
Region 6 Action
Needed  To Stop
The Loss Of
Louisiana Coastal
Wetlands


Problem

EPA Region 6 was not
controlling the negative
impacts of oil and gas
activities on Louisiana's
coastal wetlands.

We Found That

Region 6 failed to issue any
National Pollutant Discharge
Elimination System (NPDES)
general permits for oil and ga
discharges into coastal  Louisi
wetlands, even though the
Federal Water Pollution Contr
Act (Clean Water Act) require
the Agency to issue these
permits more than 15 years a
According to Region 6's
permitting schedule, another <
years will pass before all oil a
gas general permits are issue
Further, the Region had not
initiated wetlands enforcement
actions for unpermitted  dredge
and fill activities.
  Region  6 did not visit  propos
oil and gas dredge and fill site
coastal Louisiana wetlands as
part of its review process, nor
does it regularly attend  schedi
permit review meetings. Furth
                                                                          ...ii
  18

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    the Region has neither denied
    nor elevated to a higher authority
    any proposed oil and gas dredge
    and fill permits in coastal
    Louisiana.

    We Recommended That

    • Region 6 develop responsible
    timetables and dedicate adequate
    resources so that it can issue
    general permits for all oil and gas
    discharges into wetlands.

    • Region 6 make regular site
    visits and regularly attend
    Geologic Review and other
    meetings relating to possible oil
    and gas dredge and fill activities
    to carry out its permit review
    responsibilities.

    • Region 6 take stronger and
    more responsible actions, to
    include elevating or denying oil
    and gas coastal Louisiana
    permits when necessary and
    establishing an enforcement
    presence in coastal Louisiana.

    What Action Was Taken

    The Special Review Report
    (0400018) was issued to the
    Assistant Administrator for Water
    and the Regional Administrator,
    Region 6, on June 14, 1990. A
    response due on September 14,
    1990, had not been received as
    of October 29,  1990.
Management
Decisions In  Region
10 Were
Questionable
Problem

Region 10 management
decisions on environmental
issues were not consistent
with staff recommendations
nor supported by
documentation in the files.

Background

This special review was the result
of allegations that questionable
decisions were being made by
Region 10 on various
environmental issues.

We Found That

Region 10 management
decisions were questionable in all
but one of the 11 allegation issue
areas. Adequate records were
not maintained to document the
basis of  regional decisions
related to such key areas as
permitting, environmental
assessments or impact
statements, and enforcement
actions.  Additionally, a climate of
distrust and divisiveness had
developed between Regional staff
and their management.

We Recommended That

The Deputy Administrator require
the Acting Regional Administrator
to:

• Review and reconsider as
appropriate the 10  environmental
decisions that were found to be
questionable.

• Assure that the basis for all
major environmental decisions
and enforcement actions are
appropriately documented and
that staff comments are retained.

• Take immediate steps to foster
open communications and
teamwork within the Region.
What Action Was Taken

The special review report
(0400015) was issued to the
Deputy Administrator on May 3,
1990. He directed the Acting
Regional Administrator (ARA) to
address the issues raised by the
report.  The ARA's response of
June 13,  1990, satisfactorily
responded to all of our
recommendations.
y\\ and gas activities have had a
larmful effect on Louisiana's
wastal wetlands (photo by OIG
;taff).
                                                                                                                      19

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Construction Grant
Early Warning System
This 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 ofmunicipat
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, a
process which takes 2 to 10
years to complete.
  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 have been 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.
$9 Million Grant
Awarded  For An
Oversized And
Unaffordable
Wastewater
Treatment Facility

Problem

Region 9 prematurely awarded
a $9 million grant for the first
phase of the Hilo, Hawaii,
wastewater treatment facility
project

Background

Region 9 awarded the County of
Hawaii a $9 million grant to
construct a pump station,
secondary treatment facilities,
and access road and utilities.
This construction is  the first
phase of a multi-phased project
to construct a new wastewater
treatment facility and remove the
old one.  Because the County
failed  to construct interceptor and
collection systems, the old plant
never operated at more than 56
percent of its design capacity.
Region 9 agreed to  comply with
the  recommendations of a prior
audit to correct an under
utilization problem by including
special conditions in the Hilo
grant  agreement.

We Found That

Region 9 prematurely awarded
the  grant because:

• grant conditions were not
adequate to ensure that collection
systems would be constructed;

• a draft financial plan indicated
that the County may not be able
to afford the project;

• the  proposed facility will exceed
the needs of the sewer area by
34 percent;

• facility utilization will be
adversely affected by the
continued use of cesspools in 95
percent of the County; and

• the County's sewer ordinance
did not include enforcement
mechanisms to require
assessable residences to connect
to the system.
We Recommended That

The Regional Administrator,
Region 9:

• Reexamine the County's
financial capability, and require
the County to adequately develop
and annually review its user
charge system.

• Reevaluate the County's need
for a wastewater treatment
system of the planned size;
and require the County to revise
its priorities for construction of its
collection system to provide for
transporting the  largest volumes
first.

• Instruct the Hawaii Department
of Health and the County to
adopt a sewer use ordinance
which is enforceable without
exceptions, and  eliminate the use
of cesspools.

What Action Was Taken

The report (0400043) was issued
to the Regional Administrator,
Region 9, on September 27,
1990. A response to the review
is due December 1, 1990.
$2.4 Million In
Grants To California
County Should  Be
Annulled

Problem

The Mariposa County Water
Agency, California, proposed
constructing wastewater
treatment facilities even
though the projects were not
justified, public support for the
projects was  obtained using
questionable  techniques, and
the projects were neither cost-
effective nor affordable.
We Found That

Region 9 awarded the Maripos
County Water Agency (County)
three grants totaling $2,368,22(
for the construction of wastewa
treatment facilities in the
communities of Hornitos, Bear
Valley, and Mt. Bullion. Total
estimated project costs have
escalated to $6,548,600, a 52
percent increase since the grar
were awarded.
  The projects were not
adequately justified. A 1987
engineering study concluded th
sufficient data did not exist to lii
well water contamination to sep
failures in Hornitos and Bear
Valley and that contamination
problems in Mt. Bullion were
caused by improper constructio
and inadequate maintenance ol
water wells and septic systems
After we communicated our
findings, the State Water
Resources Control Board
(SWRCB) initiated an in-depth
study of the three grants.  Draft
results on SWRCB's follow-up
well sampling study, dated July
1990, concluded that a
community-wide problem
attributable to septic tanks did n
exist.  It further concluded that
the water wells with
contamination problems could b
traced to improper well
construction, and seals.  The
SWRCB draft study results
confirmed our conclusion that tr
justification for the grants to the
communities of Hornitos, Bear
Valley, and Mt. Bullion was
misrepresented.
  In addition, public support for
the projects was obtained by
using questionable techniques
which may have intimidated mai
of the community's residents to
support the project. For exampl
some Hornitos residents
perceived that they were
threatened with the destruction i
their homes if they did not
support the project.
  Further, we noted that the
projects are not cost-effective.
The estimated projects' costs
exceed the SWRCB guidelines
for a high cost project by 700
percent. The cost of the project
also exceeded the total assesse
valuation of the communities by

-------
as much as 123 percent. This
condition also raises a question
whether the community residents
will be able to afford the project.

We Recommended That

The Regional Administrator,
Region 9, annul the three grants
awarded to the county.

What Action Was Taken

The report (0400025) was issued
to the Regional Administrator,
Region 9, on July 31, 1990. On
October 10, 1990, Region 9
notified the grantee that the
grants would be terminated.
The OIG questioned whether
residents could afford the cost of
the project (photo by OIG staff).
                                                              EPA  Improperly
                                                              Awards Two Grants
                                                              For $10.7 Million
Problem

EPA improperly awarded
grants to Sellersburg and West
Terre Haute, Indiana, because
each grantee's estimated costs
exceeded the maximum
amount allowed.

We Found That

On September 29, 1989, Region
5 awarded  both Sellersburg and
West Terre Haute Step
2(design)+3(construction) grants
to design and construct a
wastewater treatment facility and
sewer collection system.
According to the Clean Water
Act, a Step 2+3 grant may only
be awarded If the total estimated
cost of the  treatment works is
less than $8 million.  EPA's
implementing regulation states
that these grants may only be
awarded if the total Step 3
building costs are less than $8
million.
  Region 5 interpreted "total Step
3 building cost" to mean only the
allowable portion of actual
construction (i.e., the sum of the
allowable portions of prime
contracts and subcontracts).
This figure was less than $8
million for each facility.  However,
neither the  Clean Water Act nor
the regulations limit the cost
consideration for eligibility to only
"allowable" costs. Both refer to
"total" costs. Further, the Clean
Water Act refers to the total
estimated cost of the treatment
works, not only the actual
building costs.
  Therefore, under EPA
regulations, grant eligibility must
be based on all costs directly
associated  with Step 3 which
consists of  building and related
services. These costs include
legal and administrative costs,
project inspection and other
construction-related engineering
fees, as well as construction
contracts and subcontracts.  For
the Sellersburg project, the total
costs directly associated with
Step 3 were $11.1 million. The
total costs directly associated
with Step 3 of the West Terre
Haute project were $11.3 million.
We Recommended That

The Regional Administrator,
Region 5, annul the grant award
($5,463,260 Federal share) to
Sellersburg and the grant award
($5,275,325 Federal share) to
West Terre Haute.

What Action Was Taken

The report on Sellersburg
(0400020) was issued to the
Regional Administrator on June
14, 1990.  The report on West
Terre Haute (0400045) was
issued to the Regional
Administrator on September 28,
1990.  In his responses, the
Regional Administrator disagreed
with the reports' conclusbns and
stated that the grants had been
awarded in accordance with EPA
policy. Resolution of the reports
is under review by EPA
Headquarters offices.
                                                                                                                        21

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As required by the Inspector
General Act, as amended, this
section describes significant
problems identified in previous
semiannual reports which
remain unresolved.  Also, as
required  by the Supplemental
Appropriations and Rescission
Acts of 1980 and 1981, this
section includes a summary of
unresolved audit reports and a
list of officials responsible for
resolving audit findings over 6
months old.
EPA Office Of Inspector General Status Report On Perpetual Inventory Of Audits In
Resolution Process For The Semiannual Period Ending September 30,1990
                                                        Dollar Values (in thousands)
Number
Report Issuance
Questioned Recommended
Costs Efficiencies
Audit Resolution
Costs Sustained
To Be As
Recovered Efficienci
A. For which no management
   decision has been made by
   the commencement of the
   reporting period*               336         175,910

 B. Which were issued during
   the reporting period            891         104,794

 C. Which were issued during
   the reporting period that
   required no resolution          596             618

   Subtotals (A + B - C)           631         280,086

 D. For which a management
   decision was made during
   the reporting period            331          58,475

 E. For which no management
   decision has been made by
   the end of the reporting
   period                        300         221,610

   Reports for which no
   management decision was
   made within six months
   of issuance                    64         118,086
 29,850


122,395



  1,310

150,935



 31,642





119,294




  8,486
                                                                                                           32,566
                                 *Arry difference in number of reports and amounts of questioned costs or recommended efficiencies between this
                                 report and our previous semiannual report results from corrections made to data in our audit tracking system
 22

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Audit Followup

The Inspector General Act
Amendments of 1988 have
focused increased attention on
Agency responses to the findings
of the Inspectors General.
Agency management is now
required to report semiannually,
in a separate report to Congress,
the corrective actions taken in
response to the IG's audits. The
Office of Inspector General will
also review the Agency's followup
actions. Below are summaries of
several of these reviews.
EPA's Audit
Followup Program
for Performance
Audits Still Needs
Improvement


In response to a
recommendation in our
September 1989 special review
on audit followup, the Agency
reported the lack of audit
followup as a material
weakness in its 1989 Federal
Managers' Financial Integrity
Act (FMFIA) report to Congress
and the President  It also
developed and implemented a
new Management Audit
Tracking System (MATS).

 In our followup review of this
new system, we found
misinformation provided by Audit
Followup Coordinators and
entered into MATS has resulted
in errors and omissions in the
new system's data base and in
the first EPA Management's
Semiannual Report to Congress
on Audits.  Corrective action
plans for performance audit
recommendations have not been
consistently tracked by the
Agency. As a result, audits have
been closed out in MATS without
assurance that corrective action
has, in fact, been taken.  Failure
to report these still open actions
in the MATS data base has
resulted in the Agency having
under-reported incomplete
corrective actions over one year
old in its first EPA Management's
Semiannual Report to the
Congress on Audits.
 The deficiencies pointed out in
our followup report (0400029)
were not detected by Audit
Followup coordinators in the field
or by the Agency Audit Followup
Coordinator.  EPA has not
developed a quality assurance
program for audit followup to
ensure that data supporting the
new automated system is
complete, correct, and current.
The Agency has taken some
positive steps to resolve these
problems since our followup
report was issued.
Improvements Still
Needed in Office of
Mobile Sources
Enforcement
Program

EPA's Office of Mobile Sources
(QMS) is responsible for
enforcing the  provisions  of the
Clean Air Act  that are designed
to reduce air pollution from
motor vehicles. The four main
types of violations that OMS
pursues are (1) emissions
equipment tampering, (2) fuel
switching, (3)  lead phasedown
and (4) volatility of gasoline
and alcohol blends. A
September 1986 audit showed
that OMS needed to improve
its procedures for establishing,
mitigating, and controlling
cash penalties and other
settlement conditions used to
enforce the Clean Air Act

  Our followup  report (0400034)
found that EPA has taken  steps
to implement some of our
recommendations. For example,
OMS has improved case file
documentation and controls over
penalty collections. Despite this
progress, some problems
previously identified still exist. We
found that OMS settled cases
during fiscal years 1986 through
1989 with proposed penalties
totaling $74.3 million for only
$12.8 million. In most of these
cases, OMS also accepted public
education projects as part  of the
settlement, but it had not
developed criteria for the amount
of credit and the types of projects
to accept. Additionally, OMS did
not always settle cases timely.  In
19 percent of the cases that had
not been settled as of March 14,
1990, over 1 year had passed
since the Notice of Violation was
issued.
  Although management agreed
with our findings and some of our
recommendations were
implemented, OMS still does not
have assurance that:

• Its penalty policies are in
accordance with overall EPA
policy, and that cases are  settled
in accordance  with EPA
guidelines;
• Cases are settled timely, and
cases that cannot be settled are
referred to the Department of
Justice; and

• Appropriate types of public
education projects are accepted
and appropriate amounts of credit
are given.
OMS generally concurred with
the recommendations and has
either completed or agreed to
complete the actions
recommended.
                                                                                        More Needs To Be
                                                                                        Done To  Recover
                                                                                        Superfund Cleanup
                                                                                        Costs

                                                                                        Our consolidated September
                                                                                        1986 audit showed that EPA
                                                                                        was not always aggressively
                                                                                        pursuing the recovery of
                                                                                        Superfund cleanup costs from
                                                                                        potentially responsible parties
                                                                                        (PRP).  Specifically, the report
                                                                                        found that EPA was not:  (1)
                                                                                        pursuing all cost recovery
                                                                                        actions under  $200,000; (2)
                                                                                        identifying and filing against all
                                                                                        bankrupt PRP's; (3) completing
                                                                                        all negotiations within the
                                                                                        required timeframes; (4) filing
                                                                                        all cost recovery action before
                                                                                        expiration of the statute of
                                                                                        limitations; and (5) using a
                                                                                        comprehensive management
                                                                                        information system to support
                                                                                        and consolidate  cost recovery
                                                                                        actions.

                                                                                         Our followup report (0400036)
                                                                                        found that while EPA has initiated
                                                                                        some positive actions, our
                                                                                        findings and recommendations
                                                                                        still have not been adequately
                                                                                        addressed 4 years after issuance
                                                                                        of our original report. A
                                                                                        consistent approach for pursuing
                                                                                        cost recovery actions under
                                                                                        $200,000 is still needed, including
                                                                                        more use of alternative  dispute
                                                                                        resolution techniques and
                                                                                        establishment of a cost  recovery
                                                                                        unit in each region. EPA should
                                                                                        also track information on sites
                                                                                        with bankrupt PRPs and require
                                                                                        that the regions identify EPA as
                                                                                        an "official creditor" in all demand
                                                                                        letters sent to PRPs.  In addition,
                                                                                        EPA should require that regions
                                                                                        monitor and complete
                                                                                                                 23

-------
negotiations within timeframes
established by Agency guidance.
Headquarters should follow up
with the regions to ensure that
they were addressing sites where
the statute of limitations is about
to expire. Lastly, EPA should
include all bankruptcy and all
other cost recovery actions in the
Superfund's management
reporting system (CERCLIS), so
that management can use this
enforcement information to
actively monitor regional program
actions and  results.
Chesapeake Bay
Deficiencies Not
Corrected
Almost four years after the first
of two audit reports on the
Chesapeake Bay Program was
issued, EPA Region 3 had not
resolved many of the
deficiencies disclosed in those
reports. The first audit report,
issued in September 1986,
focused on the grants and
contracts awarded during the
research and planning phase
of the Chesapeake Bay
Program. The second audit
report, issued in July 1988,
concentrated on the grants
awarded during the
implementation phase of the
program. The reports evaluated
procedures for administering
grants and contracts valued at
about $50 million. During
February 1990, we completed a
followup review of the
corrective actions taken by
Region 3 as a result of these
audits.

  Our follow-up report (0400028),
issued to the Regional
Administrator, Region 3, found
that the corrective actions taken
were neither effective nor
completed timely. The action
plan submitted in response to the
first audit required  Region 3 to
determine the status of 29 grants
and contracts and to close out
those that were not ongoing.  We
found that 6 projects were
ongoing and Region 3 had
properly completed or closed only
one of the remaining  23 grants
and contracts.  Region 3 could
not locate  the official files for 14
of these 23 projects.  Additionally,
the corrective actions proposed
as a result of the second
Chesapeake Bay audit were also
not completed. Our review
showed that:
• Region 3 has not reduced the
fund under Pennsylvania's Letter
of Credit to the minimum amount
needed. The state has received
$970,000 in excess Federal
funds.

• As of June 30,1989,
Pennsylvania had a combined
shortage of $1.4 million in state
matching funds.  The state
expended $4.2 million of Federal
funds, while providing only $2.8
million in matching funds.

• Maryland has not instituted
standardized contracts for the
procurement of best management
practices (i.e., specific methods
that prevent or reduce water
pollution) by farmers.

• At the time of our original
review, 87 work products required
by the grants and contracts were
not completed.  We found that 56
percent of these work products
were still missing or not
complete.

After we issued our followup
report,  Region 3 took action to
correct the deficiencies and
reduced the excessive Federal
funds retained by Pennsylvania.
The shortage of State matching
funds was resolved and
significant progress was made in
obtaining overdue work products.
Significant
Management
Decisions On Audi
ReportsWith Whicl
IG Disagrees
The Inspector General Act
Amendments of 1988 require
that the IG's semiannual rep*
include information on any
significant management
decisions with which the IG !
in disagreement Summarize
below is the first such decisi
reported as required by the
amendments.
                                                                                         Wetlands along the shore of
                                                                                         Chesapeake Bay (photo by Stev
                                                                                         Delaney).
 24

-------
 Region  9 Sides with
 Hawaii Grantee in
 Cost Dispute

 Region 9, in its May 27,1988,
 final determination letter,
 disallowed all costs claimed
 ($3,286,908) by the County of
 Kauai, Hawaii, under an EPA
 wastewater treatment
 construction grant  The
 County had failed to achieve
 the primary objective of the
 grant, awarded in March 1976,
 to eliminate the risks to public
 health and welfare from
 malfunctioning cesspools in
 the Wailua Houselots and
 Homesteads area. The County
 appealed Region 9's decision.
 On August 6,1990, over 14
 years after the grant award, the
 Region, with the concurrence
 of the Regional Administrator,
 amended the grant,  not
 requiring the County to provide
 wastewater treatment services
 to the Wailua Houselots and
 Homestead area. Further, the
 County does not have to
 refund any of the $2,465,931 in
Federal funds provided under
the grant
  We disagree with the appeal
 settlement because the grant
 amendment was accomplished
 without first revising the project's
 facilities plan to determine
 whether the change was
 appropriate under provisions of
 the Clean Water Act and EPA
 regulations.  Without a revised
 facilities plan, the Region has
 changed the primary objective of
 the grant without assuring that
 the amended project is necessary
 or eligible for Federal funding.
  We are also concerned that the
 public health concerns justifying
 the 1976 grant have not been
 corrected. This concern is
 increased because the County
 has received three Federal grants
 since 1962 to construct and
 expand the Wailua wastewater
 treatment plant to address public
 health hazards concerns in the
 Wailua Houselots and
 Homestead area.  Yet the area is
 not being served.
  Prior to the grant amendment,
 we communicated the above
 concerns to the Regional
 Administrator and Region 9
 officials. We also stated that the
 amendment would not be in the
 best interest of EPA because the
 County: (1) has a history of not
 accomplishing grant objectives,
 (2) has not properly operated  and
 maintained the Wailua
 wastewater treatment plant, (3)
 would be granted additional time
 to implement an adequate user
 charge system which should have
 been in place in 1976. In
 addition, we concluded that the
 grant amendment contained
 unrealistic and vague financial
 sanctions for nonperformance.
  Despite our concerns, Region 9
 settled the County's appeal by
 amending the grant. This action
 failed to address the health
 hazards cited in grant award
 documents, did not ensure that
the revised projects complied with
 applicable statutes and
 regulations, and did not
demonstrate EPA's willingness to
hold grantees accountable for
accomplishing objectives.
Status Of
Management
Decisions On IG
Audit  Reports
This section presents
statistical information as
required by the Inspector
General Act Amendments of
1988 on the status of EPA
management decisions on
audit reports issued by the OIG
involving monetary
recommendations.  In order to
provide uniformity in reporting
between the various agencies,
the President's Council on
Integrity and  Efficiency issued
guidance on  reporting the
costs under required statistical
tables of sections 5(a)(8) and
(9) of the Act, as amended.
  As presented, information
contained in Tables I and II
cannot be used to assess results
of audits performed or controlled
by this office.  Many of the
reports counted were performed
by other Federal auditors or
independent public accountants
under the Single Audit Act. EPA
OIG staff does not manage or
control such assignments.  In
addition, amounts shown as costs
questioned or recommended to
be put to better use contain
amounts which were at the time
of the audit unsupported by
adequate documentation or
records. Since auditees
frequently provide additional
documentation to support the
allowability of such costs
subsequent to the audit, we
expect that a high proportion of
unsupported costs will not be
sustained.
  EPA OIG controlled audits
resolved during this period
resulted in $29.7 million being
sustained out of $36.2 million
considered ineligible in reports
under OIG control. This results
in an 82 percent sustained rate.
                                                                                                                     25

-------
                                 Table I
                                 Inspector General Issued Reports With Questioned Costs
                                                                                                 Dollar Values (in thousands)

A. For which no management decision has been made by the
commencement of the reporting period
B. New Reports issued during period
Subtotals (A + B)
C. For which a management decision was made during
the reporting period
(i) Dollar value of disallowed costs
(ii) Dollar value of costs not disallowed
Number
178
89
267
147
128
83*
Questioned
Costs
177,939
104,175
282,115
58,475
32,566
25,908
Unsupported
Costs
78,718
33,136
11,854
22,269
4,038
18,231
                                 D. For which no management decision has been made by
                                 the end of the reporting period                                120
                                 Reports for which no management decision was made within
                                 six months of issuance                                       47
223,640    89,584

120,116    56,494
                                                               SEMI-ANNUAL PERIOD ENDING:  9/30/90
                                 * On 19 audits management did not sustain any of the $4,206,000 questioned costs. Sixty-four audits included
                                 are also included in C(ii) because they were only partially sustained.  Only the costs questioned that were
                                 not in C(l) sustained are included in this category.
                                                                                            39
                                                                                            72
                                                                                           111

                                                                                            45
   29,162
  121,086
  150,247

   30,953
Table II
Inspector General Issued Reports With
Recommendations That Funds Be Put To Better Use
                                                                    Dollar Value
                                                         Number  (in thousands)
A. For which no management decision has been made by the
commencement of the reporting period
B. Which were issued during the reporting period
Subtotals (A + B)
C. For which a management decision was made during the
reporting period
(i)  Dollar value of recommendations that were agreed
to by management
- based on proposed management action
• based on proposed legislative action
(ii) Dollar value of costs not disallowed
(iii) Dollar value of non-awards or unsuccessful bidders
D. For which no management decision has been made by
the end of the reporting period
Reports for which no management decision was made
within six months of issuance
                              SEMI-ANNUAL PERIOD ENDING: 9/30/90
* Four of the ten audits were the same audits in items C(i) and C(ii). Only the related dollars disallowed were
included in C(i), whereas the dollars which were not disallowed were included in C(ii).
** This amount represents the dollar value of recommendations that funds be put to better use.
10*
n/a
n/a
10*
29
66
5
7,661
n/a
n/a
7,145
16,148'
119,294
8,486
26

-------
Resolution of Significant Audits
Report Resolution
Report Issuance
Report Number/
Report Date
E2EW8-01-0370
9100510
REPORT DATE
9/29/89
P2CW6-02-0214
9100299
REPORT DATE
5/31/89
P2CW7-02-0031
0100110
REPORT DATE
1/12/90
P2CWV-02-0102
0100087
REPORT DATE
12/22/89
P2CW7-02-0167
9100260
REPORT DATE
5/2/89
P2CW7-02-0288
0100106
REPORT DATE
1/9/90
P2CW8-02-0086
0100123
REPORT DATE
1/25/90
P2CW8-02-0247
0100092
REPORT DATE
M 3/90
D8AMLO-03-0150
0100136
REPORT DATE
2/1/90
D8AMLO-03-0402
0100437
REPORT DATE
8/14/90
P2CWNO-03-01 1 1
0300039
REPORT DATE
3/30/90
C3HMKO-04-0131
0500585
REPORT DATE
2/14/90
E2CW7-04-0241
7200018
REPORT DATE

P2CWN9-04-0040
0300012
REPORT DATE
12/ 7/89
P2CWN7-05-0479
9300094
REPORT DATE
9/13/89
FS Questioned/
Grantee/ Recommended
Contractor Efficiency
DEP205G MA



NASSAU COUNTY NY
EAST GREENBUSH NY


ROCKLAND CO SD #1 NY



NORTH TONAWANDA NY


TONAWANDA NY



OSWEGO NY


BUFFALO SA NY

SYSTEMS INTEGRATION
GROUP MD-,
RESOURCE APPLICATDNS
INC VA

PHILADELPHIA CITY OF PA

NASHVILLE DAVIDSON
COUNTY TN


SADIEVILLE KY



MIAMI DADE fl



MEDINA CO OH



INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
2,978,630
9,785,330
0
0
2,965,324
19,492
0
0
469,787
10,115
0
0
998,109
727,324
0
0
499,797
517,981
0
0
692,789
0
0
0
487,878
130,093
0
0
195,927
282,679
0
0
0
0
0
5,211,489
0
0
0
645,755
3,287,192
0
0
0
0
829,993
0
0
0
1,383,394
0
0
3,943,720
0
0
0
786,983
23,034
16,223
0
Resolution of
Significant Audits
Federal Share
to be Recovered/
Sustained
Efficiency
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
2669,831
14,807
0
0
2,432,006
0
0
0
469,787
4,294
0
0
269,281
274,579
0
0
380,506
22,870
0
0
602,259
0
0
0
482,567
5,496
0
0
195,708
282,679
0
0
0
0
0
3,027,587
0
0
0
452,436
3,279,012
0
0
0
e
702,073
0
0
0
1,383,394
0
0
3,943,720
0
0
0
750,190
8,705
16,223
0
Report Number/
Report Date
D9CHLO-09-0127
0100182
REPORT DATE
3/7/90
E2AWPO-09-0072
0400025
REPORT DATE
7/30/90
E2CW6-09-0080
8000659
REPORT DATE
2/23/88

N3HMKO-09-0097
0500639
REPORT DATE
3/5/90

N3HMKO-09-0111
0500581
REPORT DATE
2/14/90

S2CW7-09-0087
9300074
REPORT DATE
8/3/89

S2CW7-09-0118
0300011
REPORT DATE
11/21/89

S2CW8-09-0111
9300093
REPORT DATE
9/13/89

P9CFL9-1 1-0043
0100226
REPORT DATE
3/28/90

NOTE
Grantee/
Contractor
CHEM-TLE
ENVIRONMENTAL
SERV CA

MARIPOSACO
WATER AGENCY CA
CAL WATER
RESOURCES CB CA


ST HELENA,
CITY OF CA



TRUCKEE SANITARY
DISTRICT CA


SANTA CRUZ SD CA



IONE, CITY OF CA


VACAVILLE, CITY OF CA

KAAREN JOHNSON
ASSOCIATES MD




Report Issuance
FS Questioned/
Recommended
Efficiency
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM
INEL
UNSP
UNUR
RCOM

INEL
UNSP
UNUR
RCOM

INEL
UNSP
UNUR
RCOM

INEL
UNSP
UNUR
RCOM

INEL
UNSP
UNUR
RCOM

NEL
UNSP
UNUR
RCOM

INEL
UNSP
UNUR
RCOM


622,577
0
0
0
0
0
0
3,601,400
873,127
0
o
0

462,092
0
0
0

455,682
0
0
0

884,445
0
0
0

49,106
o
543,463
0

1,018,915
0
0
o

640,954
111,134
0
0


Report Resolution
Federal Share
to be Recovered/
Sustained
Efficiency
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST
INEL
UNSP
UNUR
SUST

INEL
UNSP
UNUR
SUST

INEl
UNSP
UNUR
SUST

INEL
UNSP
UNUR
SUST

INEL
UNSP
UNUR
SUST

INEL
UNSP
UNUR
SUST

INEL
UNSP
UNUR
SUST


622,577
0
0
0
0
0
0
3,601,400
873,127
0
o
o

462,092
0
0
0

455,682
0
0
0

884,445
0
0
0

7.276
Q
543,463
o

911,000
0
0
o

640,954
22,710
0
0


INEL = INELIGIBLE COST
UNSP = UNSUPPORTED COST
UNUR = UNNECESSARY/UNREASONABLE COST
RCOM = RECOMMENDED EFFICIENCIES
SUST = RECOMMENDED EFFICIENCIES SUSTAINED






































































































27

-------
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
inquiries and investigations,
joint investigations with other
agencies.and OIG background
investigations.
Summary Of
Investigative
Activity
Pending Investigations as of
April 1,1990             225

New Investigations Opened
This Period              144
Investigations Closed
This Period
148
Pending Investigations as of
September 30, 1990      221
                              Prosecutive and
                              Administrative
                              Actions

                              In this period, investigative efforts
                              resulted in 14 indictments and 9
                              convictions.  Fines and
                              recoveries, including those
                              associated with civil actions,
                              amounted to $2,829,501.
                              Seventeen administrative actions*
                              were taken as a result of
                              investigations:
                                      Suspensions    3

                                      Reprimands    3

                                      Other         11
                               * Does not include suspensions
                               and debarments resulting from
                               Office of Investigations activities
                               or actions resulting from reviews
                               of personnel security
                               investigations.
        Profiles of Pending Investigations by Type
                                      Superfund
                                      50    22.6%
                                      Profiles of Pending Investigations
                                      by EPA Program Area
                                   Toxics
                                   10   4.
                                                         Air
                                                         21
                                                               9.5%
                                                        Enf. & Compli.	
                                                        2    .8%
                          Procurement Fraud
                          17    7.7%
                                                                          External Affairs
                                                                          1    .5%


                                                                         Pers Security
                                                                         7    3.2%

                                                                        'Administration
                                                                        15    6.8%
                                                                                                    Multi-Prog/Other
                                                                                                    12    5.4%
                   TOTAL - 221
                                                   TOTAL - 221

-------
 escription Of
elected
rosecutive
 ctions
i/ow is a brief description of
me of the prosecutive
tions which occurred during
i reporting period. Some of
>se actons resulted from
restigations initiated before
if//1, 1990.
Asbestos
Contractor
Convicted on
Bribe Charge


Robert Henkel, former
president of HRF Surface
Cleaning Inc., was convicted
on June 7,1990 on one count
of bribing an EPA asbestos
inspector, Howard Sleeker.
Henkel was sentenced to two
years in prison, of which 18
months was suspended, and
fined $100,000.  He was also
placed on three years
probation following his prison
term. Henkel is the 24th
asbestos removal contractor to
have either pled guilty or been
convicted of paying bribes to
Stecker.
  Stecker was bribed to
overlook violations of EPA
regulations regarding asbestos
removal projects conducted by
the contractors, and to avoid
job sites at which asbestos
removal projects were being
carried out. EPA regulations
require that specific practices
be used during demolition and
renovation of structures
containing asbestos to
minimize the potential
exposure of workers and the
general public.
  Stecker was sentenced last
year for conspiring to accept
bribes of more than $170,000
from asbestos removal
contractors during the years
1983 through 1987.  He was
sentenced to 5 years
incarceration, of which 4-1/2
years was suspended.  He
was also ordered to settle with
the Internal Revenue  Service
on any amounts due as a result
of the bribes he received.
  A joint investigation of Stecker
and asbestos removal
contractors in the New York
metropolitan area by the EPA
Office of Inspector General and
the Office of Labor Racketeering
of the  U.S. Department of Labor
has resulted in the indictment  of
24 contractors, representing 21
companies.  To date,  $781,000
in fines has been assessed.
Computer Hacker
Fails  in Attempt to
Enter EPA
Computer


John J. Sgro, 20, of Ewing
Township, New Jersey, was
indicted  in a New Jersey state
court on charges of theft of
services and wrongful access to
a computer after allegedly
illegally accessing the State of
New Jersey computer system.
He subsequently tried and failed
to access EPA's National
Computer Center at Research
Triangle Park,  North Carolina.
The Office of Inspector General
was called into the case after
EPA equipment detected the
unsuccessful entry, and
subsequently assisted New
Jersey State Police in executing
a search warrant at Sgro's
residence on August 3, 1990.
Computer equipment and
literature were seized.
Electrical
Contractors  Plead
Guilty to
Racketeering

Michael Gelb, president, and
Thomas Gelb, vice president,
Federal Chandros Inc., pled
guilty on July 19, 1990 to
charges that they were involved
from 1980 to 1986 in a scheme
to defraud the City of New York
by submitting false or fraudently
altered payment claims for
electrical work to various City
agencies. One of the projects
involved was the Owls Head
Water Pollution Control plant,
which was funded by an EPA
construction grant.  The Gelbs
photocopied original invoices
paid by Federal Chandros and
subsequently altered dollar
amounts and delivery
information.  They then
submitted them to the City for
payment. The fraudulent
billings for the Owls  Head
plant totalled $79,180.
                                                                                                                29

-------
Two Pennsylvania
Firms Indicted For
Environmental
Violations
Two former Trainer,
Pennsylvania, firms, Metro
Container Corporation, and
Metro-Enterprise Container
Corporation, Sidney S. Levy,
President, and one of the owners
of Metro, and Steven Zubrin, a
Metro maintenance supervisor,
were indicted on August 15,
1990 by a Federal grand jury on
a 17-count indictment that
charged them with criminal
violations of two Federal
environmental statutes, the
Resource Conservation and
Recovery Act and the Clean
Water Act, and  with conspiracy
to violate the two Federal
environmental statutes.
  A joint investigation by the
EPA OIG, the EPA Office of
Criminal Investigations, and the
Federal Bureau of Investigation
was initiated after a criminal
investigation by the  EPA OIG of
another allegation involving the
Superfund program found
evidence of serious
environmental violations. The
EPA OIG's initial investigation
had directed its focus on the
allegation that Metro records
necessary for EPA's cost
recovery case on the proposed
removal action against Metro
Container, a potentially
responsible party, were being
destroyed. This investigation
into the obstruction of
proceedings before  EPA, i.e., the
destruction of records necessary
to the cost recovery action or
search for potentially responsible
parties at the Metro Container
Corporation site, is still ongoing.
  As part of the joint
investigation a search was
executed at the site by members
of the EPA's  National
Enforcement Investigations
Center (NEIC).  NEIC personnel
excavated portions of the site
where Metro  conducted a drum
recycling business.  Using heavy
equipment, NEIC personnel
excavated portions of the site
where the hazardous waste was
believed to have been burled.
Buried drums were uncovered,
and numerous samples taken
from the site revealed the
presence of hazardous waste
in the yard and in the building.
In addition the presence of
contaminants was detected in
a pipe leading from the Metro
facility to Stoney Creek, a
tributary of the Delaware River.
Additional
Indictments  for
Hazardous Waste
Cleanup Firm

A Greensboro, North Carolina,
grand jury returned a two
count indictment on June 25,
1990 against Thomas L.
Ewing, President of Chem-tle
Environmental Services, Inc. of
San Antonio, Texas, and B. F.
Rippy, Operations Manager of
Chem-tle, for violation of 18
U.S.C. 287, False Claims.
Chem-tle Environmental
Sciences, Inc. was previously
indicted, on July 31,1989, in a
two-count indictment for
submitting false claims to EPA
totaling $177,629.
  Chem-tle, Ewing and Rippy
billed EPA for the three
months' operation of a quality
assurance program which they
never provided on the EPA
contract.  Chem-tle was the
EPA Emergency Response
Cleanup Service (ERCS) Zone
2 contractor. The ERCS
contract with Chem-tle was
cancelled for the convenience
of the Government.
Maryland Firm
Makes Restitutic
to Government

A settlement agreement w;
reached on July 23,1990
between the  Woodbridge
Construction Corporation,
Annapolis, Maryland, and 1
General Services
Administration whereby
Woodbridge will make
restitution to  the Governme
of $9,000.  Woodbridge WE
leasing its space in Annapi
Maryland, to EPA for the E
Central Regional Laboratot
part of the lease agreemer
Woodbridge was required 1
have on the premises a qu
operating engineer 24 houi
day, 7 days a week.
  In an investigation condi
by the EPA OIG with the
General Services Administi
OIG, it was disclosed that
Woodbridge did not provide
24 hour a day operating en
as required by the lease,
although it had billed and
received full remuneration f
providing the required servi
30

-------
Superfund
Contract
Laboratory
Program
Investigation
Yielding
Formidable
Results
The Office of Investigations
has a major investigative
initiative underway within the
Superfund program, directed at
fraud in the Contract
Laboratory Program (CLP).
Laboratory analyses under the
CLP are the empirical basis for
the entire  Superfund program.
Based on  testing for the
presence  of hazardous
chemicals by these
laboratories, the Superfund
program decides which
cleanup to initiate and how to
carry them out.  Fraudulent
analyses could result in a
danger to the public health and
safety as well as the
unnecessary expenditure of
cleanup funds. In addition,
fraudulent analyses could
hinder the Department of
Justice's efforts to collect the
cost of cleanups from  the
responsible parties.
  Our initiatives in the CLP,
which are very complex  and
time-consuming, to date have
resulted in a civil settlement of
$750,000, which was reported
in the last semiannual period
ending  March 31, 1990.
During this period one
indictment, reported below,
was returned against a
laboratory supervisor for
providing fraudulent laboratory
test results to EPA.
Contract Lab
Supervisor
Indicted
Dr. Vinh Iran, a former group
leader of the Gas
Chromatograph/Mass
Spectrometer Unit at Weston
Analytics, Lionville,
Pennsylvania, was charged on
July 30,1990 with two counts of
making false statements to EPA.
Weston Analytics is a division or
Roy F. Weston, Inc.
  Dr. Tran had allegedly
engaged in backdating laboratory
analysis results of certain water
and soil samples obtained from
various Superfund sites by EPA
and submitted to Weston for
analysis. It is further alleged that
Dr. Tran acted to conceal the
fraud by a process known as
"time travel" which involved
setting back the computer clock
attached to the Gas
Chromatograph/Mass
Spectrometer instruments to a
date and time earlier than the
actual date and time in order to
meet sample  testing
requirements set by  EPA.
  As reported previously, Roy F.
Weston, Inc, of Lionville,
Pennsylvania, paid the
Government $750,000 as part of
a consent judgment in response
to a civil action filed by the
Department of Justice under the
False  Claims Act.
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.
Employee  Makes
Restitution in
Travel Fraud and
FTS Telephone
Misuse  Case

An EPA employee at
Headquarters in Washington,
D.C. entered Into a Pretrial
Diversion Agreement on May
31,1990 with the U.S.
Attorney's Office, District of
Columbia.  This agreement
was reached after the
employee admitted fraudulently
obtaining $1,450 in travel
advances, accepting $406 in
collect telephone calls on the
office telephone, and
fraudulently obtaining $165 in
claims for reimbursement
applied for in the name of
other employees. As part of
the employee's offer to make
full restitution in the amount of
$2,021  and to perform 40
hours of community service,
prosecution was deferred for 3
1/2 months after which the
record would be expunged, if
the employee meets all the
conditions of the agreement.
The employee has already
begun making restitution. EPA
has begun action to remove
the employee.

-------
 o6CtlOn  4—Fraud  Prevention and  Resource  Management  Improvements
This section describes
several activities of the
Office of Inspector General
to promote economy and
efficiency and to prevent
and detect fraud, waste, and
abuse in the administration
of EPA programs and
operations. This section
includes information
required by statute,
recommended by Senate
report, or deemed
appropriate by the Inspector
General.
Review Of
Legislation And
Regulations
Section 4(a)(2) of the Inspector
General Act of 1978, as
amended, directs the Office of
Inspector General to review
existing and proposed
legislation and regulations
relating to programs and
operations to determine their
effect on economy and
efficiency and the prevention
and detection of fraud and
abuse.  This semiannual
reporting period, we reviewed
36 legislative and 63
regulatory items.  The most
significant items reviewed are
summarized below.
Receivables and
Billings


We reviewed the proposed
change to EPA Resource
Management Directive 2540,
Chapter 9, Receivables and
Billings.  In our opinion, there
is not a sufficient link between
a debtor's delinquency or
nonpayment and their ability to
incur additional debt from the
Federal Government.
Therefore, we recommended
that a control be established
within EPA to prevent anyone
who is sufficiently delinquent or
has a poor credit history from
participating  in any activity in
which additional debt may be
incurred until all current debts
are resolved. We believe that
these controls (similar to those of
private enterprise) are necessary
to deter the delinquency or
nonpayment of debts, and to
protect the Agency from  further
loss from poor credit risks.
Federal Civil
Penalties Inflation
Adjustment Act of
1989
We reviewed S. 535, Federal
Civil Penalties Inflation
Adjustment Act of 1989, and fully
supported the Intent of the bill to
maintain the deterrent effect of
civil monetary penalties by
linking them to inflation.
However, we suggested that an
entity in the  Federal Government
have a coordinating role to
ensure that data are consistently
reported. We also expressed
our concern that it was unclear
whether the  amount of civil
monetary penalties imposed
would be counted after the initial
court action  or only after all
appeals have been exhausted.
In addition, the bill seemed to
assume that certain reporting
mechanisms would improve the
collection of  civil monetary
penalties by the Federal
Government. Although these
reporting mechanisms would
make penalty assessments and
collections more visible, we
believe that various
administrative techniques such
as use of collection agencies,
reporting those who have not
paid penalties to credit bureaus,
and offsetting tax refunds with
fines owed would be more likely
to improve collections.
 32

-------
•Ugh Performance
Computing Act of
 990

Ve recommended revisions to
le proposed bill, S. 1067, High
'erformance Computing Act of
990.  The bill suggested the
istablishment of accounting
lechanisms which would
.How users to be charged for
leir usage of a network and
opyright material available
iver a network. In our
ipinton, the bill should include
, mandatory chargeback
ystem for accounting and
uditing purposes. Also, the
iill did not address audit
oversight of the research
rogram, and we believe that
lis oversight should be
pecifically assigned and
icluded in the bill. Finally, we
ilt that EPA's  role as a result
if this legislation was unclear,
md that EPA's specific
esponsibilities regarding the
oordinated Federal research
irogram should be included in
ie bill.
Office  of
Government
Ethics Issuance of
Waivers
The Ethics Reform Act, as it
was amended on May 4,1990,
provides the Office of
Government Ethics (OGE) the
authority to issue executive
branch-wide waivers for those
interests which are too remote
or inconsequential to warrant a
disqualification under the
restrictions of 18 U.S.C.
section 208(a).  Subsequently,
OGE developed a list of
subjects that it believes would
be appropriate for some type
of waiver, including interests in
securities having a de minimis
value.
   Since agency ethics
regulations restrict not only
actual conflicts of interest, but
also the appearance of a
conflict of interest, we did not
agree that ownership of
securities in any corporations
that are regulated by a
particular agency should be
waived as de minimis. We
believe that it would weaken
the public perception of a
Federal agency's integrity and
ability to regulate if agency
officers and employees were
permitted to maintain interests in
securities of an agency-regulated
corporation. As public officials,
we should be concerned with the
public's perception of
governmental integrity.
Therefore, we suggested that it
might be more appropriate to
have the officer or employee
terminate interest in securities
having a de minimis value.
Establishment  of
Chief  Financial
Officers in the
Federal
Government


The "Financial Management
Reform Act of 1990," and the
"Federal Management Reform
Act of 1990," are concerned with
the issue of federal financial
operations and the creation of
"Chief Financial Officers"
(CFOs). We support the
proposed legislation establishing
Chief Financial Officers in the
Federal Government and believe
it will result in improved financial
management. Each bill states
that the financial statements will
be submitted to the Chief,
Financial  Officer of the United
States no later than December
31 of each year. We believe the
provision  should also state that
the financial statements should
be given to the Inspector
General at the same time. In
addition, the audit requirements
as stated are broad in scope and
should  be clarified.
   We did not agree with the
provision  of the Federal
Management Reform Act
regarding the requirement for the
Inspector General to perform an
audit of the financial statements
and submit a report by March
31. This timeframe can only be
met if the Inspector General
begins the audit  before the end
of the financial statement
reporting  period. In addition, the
report requirements to assess
internal program controls and
compliance with  laws and
regulations are too broad in
scope and should be more
specific. In our opinion, the Act
should  include a provision that
the Inspector General is
responsible for scheduling all
audits.
   We opposed the provision
in the Financial Management
Reform Act authorizing the
Chief Financial Officer to
contract the audits as this
authority should be limited to
the Inspector General. We also
did not agree that the financial
statements be prepared only
for revolving funds, trust funds,
and agency commercial
functions. We believe
comprehensive financial
statements would be more
likely to achieve the goal of
improved financial
management.

-------
 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 from farther EPA
involvement if there has been
a conviction of, or civil
judgment for,

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

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

• commission of
embezzlement, theft, forgery,
bribery, falsification or
destruction of records, making
a false statement, or receiving
stolen property; or

• commission of any other
offense indicating a lack of
business integrity or business
honesty that seriously and
directly affects the present
responsibility of a government
contractor or subcontractor.

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

Cases completed:

• Suspensions
• Debarments
• Voluntary Exclusions
• Settlements

Subtotal S&D action

Closed after Investigation

TOTAL CASES CLOSED

Active cases as of
September 30,1990

• Under OIG investigation
• Under program review
• Under OGC review
• Proposed for debarment

Total active cases
                               April 1,19x0 to
                               September 30,1990  FY 19J
220



 67
 39
  0
  4

110

141

251
3(
1-


1!

2!
                 2I
Suspension and Debarment Activities
Total debarments, settlements, and voluntary exclusions.
 200

 180
 160
                                                 140
                                                                               1990
 34

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The following are several
examples of suspension and
debarment actions:

EPA's concerted efforts are
continuing to eliminate unethical
asbestos removal contractors
 rom doing business with the
 government. These unlawful
 ictivities could adversely affect
 le public's health. The following
 Dersons and/or firms were
convicted of bribing EPA
 isbestos inspectors in attempts
 o influence their official actions.
In addition to substantial fines
and jail sentences, these
dishonest persons and firms
were debarred from participating
in federal benefits and
assistance programs, and from
Federal contracting:

• Marshall Katz, Richard Katz
and Robert Katz of the
Environmental Abatement
Corporation, Brooklyn, New
York.

• Gene Belsole, president of
Cleaner Industrial  Services of
New York, Inc.

• John Fiume and three New
York companies: Fiume Jet
Spray Co. Inc.; Fiume  Interior
Contracting and Design, Inc.;
and All State Environmental, Inc.

• Vincent Longo, president of
Complete Oil Burner, Inc., New
York.

• Valery Kaminov, principal of
the now defunct New York entity,
Val Enterprises.

• Toby Romano, president of
Breeze Demolition inc., New
York.

• Sheldon Richman, agent for
RCI contracting, Inc., New
York.

• Nelson W. Foucher,
president of  Alpine Wrecking
Corporation  of New York.

• Seymour Breiterman,
president of  DMX  Industries,
Inc. EPA suspended
Breiterman and subsequently
debarred him for 18 months.

• Bernard J. Tully of New
York.
Samar Chatterjee, general
manager and sole stockholder
of AES Engineers, Inc., (AES)
of Illinois, and president and
member of the Board of
Directors of Universal
Engineering Services, Inc.
(UES) of Indiana, pleaded
guilty to knowingly, willfully and
unlawfully participating in  a
scheme to defraud EPA.  He
was sentenced to 4 years
imprisonment; probation for a
5 year period; and ordered to
pay restitution of $110,000
each to EPA  and the South
Stickney, Illinois, Sanitary
District Chatterjee, UES  and
AES were debarred by EPA
from Federal  procurement and
assistance programs for 3
years.

    EPA's OIG has uncovered
adequate evidence supporting
a reasonable belief that one of
EPA's Contract Laboratory
Program (CLP) participants,
Metatrace, and one  of its
officials, Carol Byington, may
have committed acts of fraud
and failed to perform in
accordance with  the EPA CLP
protocols.  Accordingly, EPA
suspended Metatrace and
Carol Byington from
participation In Federal
assistance, loan  and benefit
programs and activities, and all
direct Federal procurement, for
a temporary period pending
completion of investigation or
ensuing legal, debarment,
and/or Program Fraud Civil
Remedies Act proceedings.
    Cases (cited above)
resulted from OIG related
involvement or investigation.
 Employee And
 Public Awareness
 A continuing priority of the Office
 of Inspector General is to
 enhance 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 relationship 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.  Also
 any contractor, grantee, or
 employee who claims funds in
 excess of or for other than the
 approved purpose are in violation
 of the law.  We believe that EPA
 employees are in the best
 position to detect, prevent,  and
 report fraud, waste, and abuse if
 they can recognize it.
   We have used a variety of
 media to provide information and
 encourage  specific segments of
 the concerned population to
 recognize and report conditions
 or actions that threaten EPA's
 resources or mission. OIG-
 developed publications,
videotapes, presentations, and
training help prepare EPA project
 or program managers and
 employees to identify and
 report suspected indicators of
 fraud that otherwise may have
 gone unnoticed.
Presentations

Elissa R. Karpf, Director, Audit
Operations Staff, gave two
presentations at EPA's
Grants Conference held in
May 1990. First, Ms. Karpf
discussed the OIG's
construction grant task force,
which was convened to
determine where
enhancements could be made
to our construction grant
program audit strategy. The
task force has recommended
several changes to previous
policy, including dollar
thresholds for projects to be
audited. The second
presentation addressed the IG
Act Amendments of 1988 and
the two major areas that will
directly affect EPA's grant
offices:  (1) standardization of
cost terminology in all financial
audit reports; and (2) the
highlighting of all audit reports
not resolved within 180 days in
the OIG's  semiannual report to
the Congress.
    Region 3, in conjunction
with the OIG, conducted a
training session for regional
management to inform them of
procedures and requirements
of the audit process and their
responsibility for audit
response and followup. P.
Ronald Gandolfo, Divisional
Inspector General for Audit,
provided an overview of the
importance of audits and the
positive impact they can have
on operations.  Ms. Karpf and
Robert Coia, discussed the
audit process in detail from a
Headquarters and regional
perspective.
    Ms.  Karpf and Christine
Baughman, Internal Audit
Division, gave presentations at
the Office  of Research and
Development's workshop held
for internal control
coordinators.  Topics included
the importance and need to
conduct internal control
reviews and the importance of
EPA project officers'
responsibility to provide oversight
of Agency contractors'
performance to ensure that
quality and timely products are
obtained.

-------
  John E. Barden, Assistant
Inspector General for
Investigations, and Michael J.
Binder, Director, Administrative
and Management Services
Division, gave a presentation
at the EPA Office of Research
and Development Directors'
Conference in September
1990 on detection and
prevention of fraud as it relates
to scientific misconduct.  The
presentation included a
discussion of the need for
controls in research, including
separation of duties,
documentation and
independent corroboration, and
the need for a high degree of
professional skepticism.

Semiannual Report

Over 1,600 copies of each
semiannual report to Congress
are distributed to members of
Congress on EPA-related
committees,  top EPA
managers, news media
(including wire services), State
agencies administering EPA
programs, State attorneys
general, citizens  (by request),
EPA libraries, and selected
environmental groups.
Articles and Publications

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
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.

OIG Recognition Award

The Office of Inspector
General Recognition Award is
presented to an EPA  official
who exemplifies teamwork  and
cooperation with the Office of
Inspector General in promoting
economy, efficiency, and
effectiveness in EPA.  During
this reporting period, the OIG
Recognition Award was
presented to Judith Blanchard for
working with the OIG  in the
formulation of its budget over the
last 3 years including fiscal 1990,
our first year with a separate and
independent appropriation of
funds.
 Inspector General John Martin
 presents the OIG Recognition
 Award to Judith Blanchard for her
 assistance with formulation of the
 OIG budget while assigned to the
 EPA Budget Office. Ms.
 Blanchard now works for the
 Office of Congressional and
 Legislative Affairs (photo by
 Michael Binder).
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  317
investigations. The following
conditions were identified  and
administrative actions taken:

• Four employees resigned
pending administrative removal
for falsification of the SF-171,
Application for Federal
Employment.  The falsification
included:  not listing prior
convictions, claiming college
degrees not earned, misuse of
Government funds for personal
gain, and timecard fraud.

• One employee resigned
pending administrative removal
for failure to qualify for a
security clearance because of
continuous use of controlled
substances. The security
clearance was required in
connection with the
employee's official duties.

• One employee resigned
pending administrative removal
for falsifying the  SF-171 and
other official Government
forms by  using numerous
social security numbers.

• Two employees received
written reprimands for failing to
list previous convictions on the
SF-171.

• Two other employees
received  oral reprimands  for
failing to  list previous
convictions on the SF-171.

• One contractor employee
was denied access to
confidential business
information because of failure
to list previous convictions for
use of controlled substances o
the SF-86, Questionnaire for
Sensitive Positions.

• Seven employees were
required to submit corrected S
171s or SF-86s to list minor
offenses they had failed to
report.

We continue working closely w
Agency program officials on th
implementation of the OPM
regulations regarding position
sensitivity designations and
granting of security clearances
   We are also entering
information into an operational
computer system which providi
management reports on the
status of ongoing investigation;
It also provides reports on thoj
investigations which need
updating.

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 President's
 Council On
 Integrity  And
 Efficiency
The President's Council on
Integrity and Efficiency (PCIE)
was established by Executive
Order In March 1981 to attack
fraud and waste, and Improve
management in the Federal
Government The PCIE
coordinates interagency
activities Involving common
issues, and develops
approaches and techniques to
strengthen the effectiveness of
the entire Inspector General
community.  The PCIE is
headed by the Deputy
Director, Office of
Management and Budget, and
Includes the  statutory
Inspectors General and other
key Federal officials.

Internal Operations
Committee
John C. Martin, Inspector
General, EPA, chairs the
Internal Operations Committee,
one of the PCIE's standing
committees.  The standing
committees are the means the
PCIE uses to segment and
perform its work. The Internal
Operations Committee is
composed of Inspectors
General from the Departments
of Treasury and Interior, the
Federal Maritime Commission,
and the Appalachian Regional
Commission.
   The Internal Operations
Committee seeks to promote
good administrative practices
through special projects and
surveys which contribute to a
common understanding of
issues important to the IG
community. The  Internal
Operations Committee is
responsible for conducting
special projects and surveys
regarding matters of common
interest to the IG community
and operational infrastructure.
The Subcommittee on
Qualifications Review, whose
work is chiefly confidential,
conducts ongoing objective
reviews of the professional
qualifications of prospective
Inspector General candidates.
Internal Operations Committee
Activities

The Internal Operations
Committee has been responsible
for a number of special
assignments, including
investigators' common medical
and fitness standards; OIG
procurement, legal counsel, and
personnel practices; and SES
performance review boards.
   A working group, with 23
agencies participating, was
established to develop common
medical and fitness standards for
OIG investigators. The working
group was divided into four
subgroups that tackled issues on
grandfathering current
employees, primary vs.
secondary positions,
maintenance standards, minimal
standards, waiver policies and
procedures, Federal Law
Enforcement Training Center
standards, medical standards
and physical requirements vs.
fitness program.  The working
group is now in the process of
developing a draft model
directive on these standards.
   The Committee also
conducted a survey identifying
ways in which OIGs obtain
procurement, legal counsel, and
personnel services. Responses
were received from 22 Agency
OIGs, which indicated most IGs
use agency procurement offices,
although some IGs have limited
procurement authority. For
personnel and legal services
about half of the IGs responding
carried out these functions within
the OIG, and the remaining half
rely entirely or in part on their
agencies for these services.
   The Committee also
completed an update of the
Performance Review Board
(PRB) membership  roster for
OIG SES employees.  The
update was published as a
notice in the Federal Register  on
September 10, 1990.  The notice
provides a roster of persons in
Offices of Inspector General who
have agreed to serve as
members of PRBs.  Offices of
Inspector General may use the
roster to establish PRBs
consistent with Federal
regulations and arrangements
made with their respective
agencies.
Technology Committee

The EPA OIG is a member of
the PCIE Technology
Committee, which addresses
technological issues as they
relate to Federal agencies and
the Inspector General
community. The Technology
Committee has held round table
discussions on hardware and
software procurement, strategic
management automation
planning, and computer issues of
concern to the Computer
Systems Security and Privacy
Advisory Board. Committee
activities will also encompass
electronic data processing audit
and investigative activities, and
studies of new technology that
can enhance productivity.

Investigative Standards and
Training

Inspector General Martin also
serves on the Investigative
Standards Subcommittee of the
Integrity and  Law Enforcement
Committee. This Subcommittee
will be involved with coordinating
OIG investigator training at the
Federal Law Enforcement
Training Center (FLETC) and
assisting new Offices of
Inspector General in developing
their investigative functions. Mr.
Martin also serves as the  PCIE
representative on the Board of
Directors at FLETC.
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 composed of senior EPA
program and regional officials
and is chaired by the Inspector
General.  The following
examples describe projects
completed during this reporting
period.

Awareness Bulletin on
Acceptance of Food,
Refreshments or
Entertainment

The acceptance of food,
refreshments,  or entertainment
from a prohibited source can
cause a Government
employee's integrity to be
questioned because of the
appearance of impropriety.
Spousal acceptance of food,
refreshments or entertainment
may also create concern
unless it is entirely unrelated to
the employee's Government
position. CIMI believed that
employees should be made
aware of regulations regarding
this matter as  a preventive
measure. As a result, CIMI
developed an  awareness
bulletin which focused on
regulatory prohibitions,
identification of prohibited
sources, and exceptions to the
prohibitions regarding the
acceptance of food,
refreshments,  or entertainment
from any person or entity.
   In addition, the bulletin
provided information on
Agency ethics officials to
enable employees to obtain
answers to questions concerning
this issue.
                                                                                                                     37

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Public Service Recognition
Week

To communicate support and
appreciation to EPA employees
at all levels, CIMI sought an
opportunity for the Agency to
speak out and show its
commitment to human
resources. As a result, CIMI
developed and coordinated a
series of special events during
Public Service Recognition
Week.  The program, hosted by
EPA's Administrator, William
Reilly, was highlighted by
speeches from Dr. Jerome Karle,
a Nobel Prize winner, and Dr.
Frances Kelsey of the Food and
Drug Administration, who was
primarily responsible for stopping
the importation of thalidomide
into the United States.
   Through this Public Service
Recognition Week program, CIMI
successfully provided a focal
point for enhancing employee
morale and the public's
understanding of the services
they performed. The program
effectively paid tribute to the
"unsung heroes" that make up
the public workforce.
Hotline Activities
The OIG Hotline Center
received 20 new complaints
and completed and closed 27
cases during the reporting
period.  Of the cases closed,
11 resulted in environmental,
prosecutive, or administrative
corrective action, while 16 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
referred 1,261 telephone
callers 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 a
company was emitting fumes
which were polluting the air. A
review of the complaint
disclosed that the company
was performing open spray
painting in violation of State air
quality regulations which
prohibit the emission of air
contaminants over the property
of other persons.  Based on
our inquiry, State authorities
informed the company of the
violation, and  the company
agreed that no further open
spray painting would be
conducted on the property.
The company was also
advised by the State that any
future violations would result in
enforcement action.

• A complaint alleged that a
Government vehicle had been
misused. The complainant
indicated that a passenger in
the car, while stopped at a
traffic light, placed an empty
beer bottle in  the road. A
review of the complaint
disclosed improper behavior in
a Government vehicle by a
contract driver while on
delivery. As a result of this
Complaint, the contractor and  its
employee were reprimanded and
warned of the ramifications of
any future reports of this nature.
Professional And
Organizational
Development
During this semiannual period,
the EPA OIG continued to
expand on initiatives started in
the first half of fiscal 1990 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, publication and
distribution of our own training
catalog,  and organization-wide
training on self-awareness and
organizational culture.  For the
semiannual period ending
September 30,1990, we
approved 453 training
enrollments for a total of 1,284
days of training  and participation
in professional development
seminars and conferences.
Contract and in-house courses
conducted by the OIG are
summarized below.

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 geographical
locations.

• Superfund Auditing Course.
This course was developed to
provide OIG staffers with an
understanding of the Superfund
program and the role of the OIG
in the program.  The
development of this course,
coordinated by the OIG
employee development
specialist, was a combined el
of all three primary
components of the OIG.  The
course consists of six units:  (
history of Superfund, (2) maji
concepts of the Superfund
program, (3) Superfund
program organizations and
resources, (4) auditing
cooperative agreements, (5)
auditing Superfund contracts,
and (6) internal (managemen
audits.

• Effective Briefing
Techniques.  This course was
designed to prepare auditors,
investigators, and managers \
give effective and persuasive
presentations, deal with
confrontation  situations, and
improve OIG/client relations.
The course includes sections
on effective oral
communication, visual
imagery, confrontational
management, and a video
workshop.  It stresses the
importance of teamwork
between OIG employees and
Agency management.

OIG Contracted  Courses

• Evaluating and Reporting 01
Internal Control Systems. Thi
course was designed to help
meet the requirements of the
Federal Managers' Financial
Integrity Act and  OMB Circula
A-123. The course includes
guidance on conducting and
reporting on vulnerability
assessments and internal
control reviews and
strengthening the audit
practices for determining
reliance on systems of interna
controls in complex
government systems.

• Questioned Cost/Complianc*
Auditing.  This course
analyzes policies, standards,
and practices to enhance the
auditor's ability to identify,
document, and report
questioned costs in a
governmental audit and to
participate in  their resolution.

• Total Quality Management
(TQM). The  Office of
Investigations participated in a
TQM workshop which provide*
 38

-------
 nanagement an overview of the
 scientific method of problem
 iolving known as the PDCA
 plan, do, check, and act). The
 workshop described several
 ypes of quantitative methods
 which are used in each phase of
 is PDCA cycle as a means of
 gathering and analyzing data for
 jse in the process control and
 mprovement cycle.

 DIG Training Activities

 • O/G Support Staff Seminar.
 'he OIG support staff
 jarticipated in the Myers-Briggs
 irogram as part of the Support
 Staff seminar. This program is a
 descriptive instrument used to
 de^tify how individuals'
 jerceptions, values, and thought
 irocesses affect their ability to
 jnderstand and be understood.

 • O/G Orientation Seminar.  The
 DIG orientation workshop for
 lew employees included opening
 emarks by John C. Martin,
 nspector General, and Anna
 Hopkins Virbick, Deputy
 nspector General. Each
 Assistant  Inspector General and
 leir management staff
 ^resented an overview of the
 office's organization and
 unction.

 To help OIG supervisors identify
 md select appropriate
 development opportunities for
 leir staff, we have updated the
 DIG Training and Development
 Sources catalog.  This catalog
 ists, describes, and provides
 chedules of over 97 courses
 hat are included in the OIG
computerized career profiles for
auditors, investigators, and
support staff. The catalog
includes profiles of required or
suggested training for the OIG
staff and a description of the
General Accounting Office
"yellow book" requirements for
training.  These 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.
The Supplemental
Appropriations and
Rescission Act of 1980
(Public Law 96-304) requires
the Inspector General to
report on EPA's delinquent
debts and efforts to improve
the collection of such debts.
Agencywide
Accounts
Receivable
Activity

Claims Office Actions

When the Agency's Servicing
Finance Offices 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 for
approval  of the final resolution
of the debts.  However, the
Claims Officer need not
immediately refer debts over
$20,000 until all Agency
collection actions have  been
taken.
   As of September 30, 1990,
the Claims Officer reported 34
accounts receivable valued at
$3,100,179.46. For this
reporting  period, the Claims
Officer:
• terminated one debt totaling
$56,424 because of a U. S.
Attorney's decision that the
debt was uncollectible;

• withdrew two debts totalling
$1,853,840 because the
Agency determined the costs
were allowable for a
constructed collector sewer
system; and

• returned two debts totaling
$24,761 to the Financial
Management Division because
the debts were not filed properly.

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 April 1, 1989, through
September 30,1990.  Although
the figures  reflect the Agency's
accounting records as of
September 30,1990, they were
obtained before the closing
process.  Therefore, they may
not be the Agency's final figures.
The OIG did not verify the
amounts presented below:
Collection
Amount Written Off
Interest Assessed
Interest Collected
$93,697,690 1
164,914
(1, 786,773) 1 2
1,009,048 1
                                        Accounts Receivable
                                           Non-Federal
                                                90 days or less
                                                over 90 days
                                           Subtotal
                                        Interagency Agreements
                                        Total
                                $29,170,414
                                123,288,236
                                152,458,650 1  3
                                  1,734,421 1  4
                               $154,193,071 1
                                  1 These figures are subject to change pending the subsequent
                                  reconciliation of EPA's accounts receivable.  The reconciliation is
                                  required as part of EPA's conversion to and  implementation of a new
                                  Integrated Financial Management System.

                                  2 The negative amount represents an adjustment to previous
                                  assessments.

                                  3 Data to determine what refunds are being appealed was not
                                  available for this semiannual period; therefore, we are unable to show
                                  what percentage of the Agency's records are receivables that are
                                  being appealed.  For refunds that are being appealed, collection
                                  actions are suspended until the appeals process is complete.

                                  * This amount is for debts owed EPA by other agencies. Although
                                  these debts do not have an impact on the U. S. Treasury, they do
                                  Impact the Agency budget. Approximately 37 percent of the total in
                                  this category is over 90 days old.
                                                                                                                             39

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     Appendix  1—Audit   Reports  Issued
      THE INSPECTOR GENERAL ACT REQUIRES A LISTING, SUBDIVIDED ACCORDING TO SUBJECT MATTER, OF EACH AUDIT REPORT ISSUE!
      THE OFFICE DURING THE REPORTING PERIOD AND FOR EACH AUDIT REPORT, WHERE APPLICABLE, THE DOLLAR VALUE OF QUESTIOt
      COSTS AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE.
   Audit Control
   Number
Auditea
                          Questioned Costs
               	Recommei
Final Report     Ineligible    Unsupported    Unnecessary/     Efficiei
Issued             Costs          Costs    Unreasonable   (Funds Be
                                              Costs  To Better
    1. INTERNAL & MANAGEMENT AUDITS (Listed by Action Official)

    Assistant Administrator for Air and Radiation

    E1GAGO-05-6004-0400034  OFFICE OF MOBILE SOUflCES          9/28/90
                         ADMINISTRATION OF PENALTIES FOLLOW?

    Assistant Administrator For Administration and Resources Management

    E1AME9-11-0041-0100523  UNLIQUIDATED OBLIGATIONS          9/27/90
    E1BUGO-11-0028-0400014  TRAINING - TQH                   4/ 5/90
    E1LMFO-11-0072-0100357  EPA 1989 FUFIA ACTIVITY           6/22/90
    E1MMF9-77-0039-0100479  CONTROLS OVER OVERTIME            8/ 1/90
    P1SFF9-11-0032-0100492  SUPERFUND TRUST FUND AUDIT -       9/24/90
                         FISCAL 1989
    E1XHGO-13-0027-0400029  EPA FOLLOW/5 SYSTEM               8/14/90

    Assistant Administrator for Pesticides and Toxic Substances

    E1EPF9-05-0375-0100486  PESTICIDE DISPOSAL PRACTICES       9/28/90

    Assistant Administrator for Research and Development

    E1NBGO-15-0038-0400037  OFFICE OF RESEARCH AND DEVELOPMENT 9/24/90
                         AUTOMATED TRACKING SYSTEM

    Assistant Administrator for Solid Waste and Emergency Response

    E1HNA9-03-0240-0100491  SPILL  PREVENTION CONTROL AND       9/24/90
                         COUNTERUEASURE PROGRAM
    E1SFGO-75-0020-0400019  SUPERFUND CERCL/S POST-           6/74/90
                         IMPLEMENTATION STUDY
    E1SJGO-11-0022-0400036  SUPERFUND COST RECOVERY FOLLOHUP   9/24/90
    E7SGG9-05-0275-0400044  INVESTIGATIVE-DERIVED WASTE        9/28/90
                         DISPOSAL - REGION 5

    Assistant Administrator for Hater

    E7WG9-13-9024-0400018  OIL AND GAS WASTES                6/14/90
    E1WF9-03-0316-0100508  LEAD IN DRINKING HATER            9/26/90


    Deputy Administrator

    E6AWGO-10-0022-0400015  SPECIAL REVIEW OF THE HANDLING     5/ 1/90
                         OF AIR AND MER ISSUES - REGION 10

    Director, Office of Emergency and Remedial Response

    E1MMF9-11-0039-0400027  SUPERFUND ACCOUNTING - EDISON, NJ  8/ 7/90
40

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 mdft Control
 dumber
Audhee
Final Report
Issued
            Questioned Costs              „         .  .
	   Recommended
Ineligible    Unsupported    Unnecessary/      Efficiencies
                                                     Costs
                  Costs
         Unreasonable    (Funds Be Put
                 Costs   To Better Use)
procurements Contract Management D/v/s/on

F7SGB9-77-0021-0700274  MS CONTRACT fi/DOING SURVEY       4/20/90
                        SITE

legion 1

•1SGG8-14-0004-0400038  REMEDIAL INVEST IGAT IOH/            9/27/90
                        FEASIBILITY STUDY - NYANZA, MA
?7SGG8-74-0002-0400039  REMEDIAL INVESTIGATION/            9/27/90
                        FEASIBILITY STUDY -
                        IRON HORSE PARK,             MA
•7SGG7-74-0003-0400040  REMEDIAL INVESTIGATION/            9/27/90
                        FEASIBILITY STUDY - fiAIRD &
                        MCGUIRE                     MA

Reg/on 2

E1HWFO-02-0740-0700482  PROCESSING OF SECTION 307(H)       9/78/90
                        MARINE WAIVERS - REGION 2

Reg/on 3

E1SJDO-03-0785-0700485  SUPERFUND POST-SETTLEMENT          9/19/90
                        ACTIVITIES - REGION 3
E7HIYGO-03-6000-0400028  CHESAPEAKE BAY FOLLOflfUP            8/70/90

Reg/on 4

E7SGB9-04-0016-0700579  SUPERFUND REMOVIAL CLEANUP         9/26/90
                        ACTIVITIES - REGION 4

Reg/on 5

E1SFFO-05-0111-0100415  SUPERFUND CONFIDENTIAL DISCLOSURE  7/25/90
                        STATEMENTS - REG/ON 5
E7SHGO-05-0192-0400023  BETTER fiRITE SPECIAL  REVIEW        6/29/90

Reg/on 6

E7EPB9-06-0727-0700470  MONITORING STATE  PESTICIDES        9/ 5/90
                        PROGRAMS - REGION 6
E7EPGO-06-0732-0400035  FIRFA SECTION 7 PESTICIDES         9/20/90
                        ENFORCEMENT - REGION 6

Reg/on 9

EJSGG9-J4-0013-0400047  REMEDIAL INVESTIGATION/            9/27/90
                        FEAS/8/L/TY STUDY - SELMA
                        TREATING COMPANY             CA
              TOTAL INTERNAL S MANAGEMENT AUDITS

2. CONSTRUCTION GRANT AUDITS

P2CIV7-01-OJ80-0700309  DOVER
P2CW8-01-0797-OJ00370  SOMERSWORTH
P2CW*7-07-0012-0100351  OSSIPEE
                            NH
                            NH
                                  30
 5/ 8/90
 5/ 8/90
 6/19/90
                                                                                                   970,000
                                                                 970,000
    7,768
   12,569
   70,400
16,905
     0
     0
                                                                                                                                  41

-------
                                                                                       Questioned Costs
Audit Control Audrtee
Number
P2W8-01 -0044-0100489 HOPK.INGTON
P2CH*8-01 -0042-0100533 ALLENSTOWN
P2CW*8-01~0032-0100534 HARTLAND
S2CW*8-01 -0037 -0100350 NEW BEDFORD
S2CH*8-01 -01 56-0100407 WORCESTER
S2CIY*8-07-0035-0700458 VFfROPOL/rAW DISTRICT COM
S2CWL9-01 -0065-0100479 HULL
TOTAL OF ftFGION 07 = 10
E2FWPO-02-0284-0400033 EARLY WARNING - COMPOSTING
P2CH»7-02-0027-0 700247 PORTLAND-POMFRET-DUNK 1 RK.
P2CHf*8-02-0257-0 100248 CORNING
P2CW*8-02-0194-0100252 NIAGARA FALLS
P2CWL9-02-0027-0100288 CORNING
P2CT8-02-0025-0 100307 YOftKTOWN
P2CH*8-02-0088-OW376 CORTLAND
P2CW*8-02-0207-0100377 NFJH BALTIMORE
P2CW*7-02-0222-0700480 SYLVAN BEACH
P2CWL9-02-0050-0100481 NASSAU COUNTY
TOTAL OF REGION 02 * 10
E2CWLO-03-01 19-01 00524 EARL TOWNSHIP SEWER AUTH
E2CWLO-03-0105-0100525 EAST EARL SEVER AUTHORITY
F2AWPO-03-0069-0400077 DC GOVERNMENT
E2WPO-03-0325-0400032 PRJTS AWAITING ADM COMPLTH
P2CW*8-03-001 8-01 00249 BALTIMORE MAYOR & CTY COUN
P2DML9-03-0234-0100308 WSSC
P2Ctf*8-03-00 76-0 700376 BLOQUFIELD TUP SfWffi WTH
P2CHf '8-03-0278-0 700404 SOMERSET CO SANI DISTRICT
P2Cfl*8-03-0344-0 700406 DERRY TWP MUNI AUTHORITY
P2CH*8-03-004S-0100478 CHARLES CO COMMISSIONERS
P2CW8-03-0178-0100536 GREENBRIER CO PSD f2
TOTAL OF REGION 03 - 11
E2CNM9-Q4-0049'0200007 BRUCE
E2CWM8-04-0031 -0200008 BERKELEY CO USA
E2GHM8-04-0034-0200009 OMEGA
E2CWM9~04-0047-0200012 EDGEFIELD
E2CWN7 -04-0302-0300054 SYLACAUGA UTILITIES BD
E2CHN9-04-0251 -0300056 SHOBUTA CLARXI CO.
E2BHNO-04-0025-0300074 ORANGE CTY
E2CWN7-04-0079-0300094 COLUMBIA
E2WPO-04-0134-0400016 EARLY WARNING R-4
E2HHPO-04-0205-0400031 STATE REVOLVING FUND
P2CWN9-04-01 58-0300053 BRADENTON
P2WN9-04-0293-0300075 CENTRAL TAHPA
P2CM9-04-01 61 -0300081 LEXINGTON,
POT/9-04-0775-0300082 ATLANTA, CITY OF,
S2CWN7-04-0081 -0300051 KINGSPORT
S2OIN8-04-0249-0300087 UNION CITY
TOTAL OF REGION 04 = 76
E2CWH8-05-0586-0200010 WKA
E2WPO-05-0223-0400020 SELLERSBURG-EWS

NH
NH
ME
MA
MA
MA
MA

PR
NY
NY
NY
NY
NY
NY
NY
NY
NY

PA
PA
DC
MD
MD
MO
PA
MD
PA
MD
HV

MS
SC
6A
SC
AL
MS
FL
SC
TN
TN
FL
FL
KY
GA
TN
TN

IL
IN
Final Report
Issued
9/24/90
9/28/90
9/28/90
6/78/90
7/78/90
8/23/90
9/77/90

9/78/90
4/ 4/90
41 5/90
4/ 9/90
4/26/90
5/ 3/90
7/ 3/90
7/ 3/90
9/77/90
9/77/90

9/27/90
9/27/90
5/70/90
9/74/90
4/ 5/90
5/ 4/90
5/ 9/90
7/72/90
7/77/90
9/73/90
9/28/90

5/ 7/90
5/77/90
6/29/90
8/29/90
5/70/90
5/27/90
7/27/90
9/25/90
5/ 9/90
9/ 6/90
5/70/90
8/ 7/90
8/15/90
8/75/90
5/ 9/90
9/ 7/90

7/30/90
6/74/90
Ineligible
Costs
9,750
45,744
0
77,997
70,877
707,593
80,700
344,738

59,364
27,028
66,205
,50,877
79,470
277,920
79,744
363,424
533,556
7,464,982
767,233
485,872


799,372

779,397
62,364
349,437
302,280
882,455
3,228,338
703,524
56,702
79,436
50,753
7,231,066
15,227
7,176,077
208,624


56,747
154,452
98,607
3,483,653
503,097
733,760
7,290,573
47,870

	 	 — 	 	 — ncrouiiima
Unsupported Unnecessary/ Efficie
Costs Unreasonable (Funds B
Costs To Better
923
119,500
79,651
0
0
238,383
0
395,362

634
0
77,774
78,754
23,076
445,669
7,773
244,709
727,363
931,832
27,594
89,488


942,560

66
109,779
0
9,096,986
476,213
10,676,686
0
0
0
0
0
0
0
1,342


0
0
0
0
171,485
53,689
766,576
7,523

0
0
64,240
0
0
0
0
64,240

0
0
0
0
0
0
0
0
0
0
0
0


0

0
7,747
0
58,288
762,449
228,478
0
0
0
0
0
0
161,207
0


0
0
0
0
0
0
761 ,207
0
5,463
42

-------
Audit Control Audrtee
Number
F2AIVPO-05-0224-0400045 Hf TFRRF HAUTF-FhfS
P2CIVL9-05-0324-0700464 SUMM/T & PORTAGE
P2GHL8-05-0282-0100490 SUMMIT CO
P2CWN7-05-0087-0300059 NFORSD CLEVELAND
P2CIVN8-05-0494-0300065 SHEBOYGAN
P2CWN8-05-04 70-0300070 ZANFSV/LLF
P2CWN9-05-0336-0300076 IHFLLSV/LLF
P2CIYP7-05-0499-0400030 BEHIDJI
TOTAL OF REGION 05 = 10
E2CWN9-06-0031 -0300043 SLIDELL
F2CHfN9-06-0028-0300046 KROTZ SPRINGS
F2CIYN8-06-0037-0300055 fiARTLFSV/LLF
E2CHNO-06-0027 -0300057 JEFFERSOH PARISH
F2AWPO-06-0244-0400042 FARLY WARNING-CABOT
P2CIVN7-06-01 39-0300064 SANTA FF
P2CIYN7-06-0047 -0300088 CORPUS CHRIST/
TOTAL OF REGION 06 • 7
E2VN*7 -08-0036-010041 8 THREE LAKES HATER & SANIT
TOTAL OF REGION 08 = 1
F2CIY*8-09-0024-0300090 HONOLULU CITY & COUNTY OF
F2CIM9-09-0033-0300097 HONOLULU, CITY & COUNTY OF
E2CT8-09-0037-0300092 HONOLULU, CITY & COUNTY OF
E2AHPO-09-0072-04C0025 MARIPOSA CO. HATER AGENCY
F2AIVPO-09-0249-0400043 H/LO IfflfTP, HAKA// COUNTY
S2CHC8-09-07 13-020007 7 ORANGF COUNTY
S2CIV7-09-0700-0300052 FASTFRN MUN HfATFR D/ST
S2C)y»7-09-0)35-0300060 FOGFRLY ISLAND RFCLAV 0/ST
S2CIV*8-09-0140-030006I CA OFPT OF CORRECTIONS
S2CH*8-09-0219-0300063 VENTURA REG SAN D/ST
S2CIYN9-09-0045-0300067 FURFKA, CITY OF
S2CN*7 -09-01 94-0300068 hf/K/UP, COUNTY HfATFR D/ST
S2WYN9-09-00 75-0300069 DFLFUW CATHFR & CO
S2CI»»8-09-OJ77-0300077 SCOTTS VALLEY, CITY OF
S2CW8-09-0335-0300085 OAKLFY-SFTHFL ISLAND
S2BHH9-09-01 61 '-0300097 SAN FRANCISCO, CSC GREAT HI
TOTAL OF REGION 09 = 76
TOTAL CONSTRUCTION GRANT AUDITS
3. OTHER GRANT AUDITS
C3HHK.O-01 -0174-0500772 PITTSFIELD
C3HVJO-07-0753-0500787 CONNECT ICUT-DEPT , STATE OF
C3HVKO-OJ-0287-0507202 PITTSFIELD
C3HHKO-01-0282-0501215 CHICOPEE
G3HMKO-07-0757-0500753 BERLIN
G3HHK.O-01 -017 1-0500778 ST. JOHNSBURY
G3HMKO-0? -07 57 -0500780 WINCHESTER
G3HMKO-07 -0173-0500782 GARDNER
G3HMK.O-Q1 -0172-0500783 SPENCER
G3HMO-01 -01 85-0500867 NORTH ATTLF80ROUGH

IN
OH
OH
OH
HI
OH
OH
MN

LA
LA
OK
LA
AR
NM
TX

CO

HI
HI
HI
CA
HI
CA
CA
CA
CA
CA
CA
CA
IL
CA
CA
CA

s

MA
CT
MA
MA
NH
VT
NH
MA
MA
MA
Final Report
Issued
9/28/90
8/29/90
9/24/90
6/29/90
6/74/90
6/26/90
8/ 6/90
8/29/90

4/72/90
4/20/90
5/77/90
5/21/90
9/27/90
6/29/90
9/ 7/90

7/37/90

9/79/90
9/19/90
9/79/90
7/30/90
9/27/90
8/22/90
5/70/90
5/37/90
6/20/90
6/20/90
6/27/90
6/22/90
6/25/90
8/ 7/90
8/23/90
9/28/90

81

4/ 9/90
4/10/90
9/77/90
9/18/90
41 3/90
4/70/90
4/70/90
4/10/90
4/70/90
5/16/90
Ineligible
Costs

233,040
3,553,409
443,678
69,699
705,805
7,429,979
775,590
5,992,950
744,372
79,795
8,799,782
394,793

700,690
38,314
9,497,086
477,574
477,574
209,405
830,790
12,202,264


5,018
727,992
9,779
252,054
788,767
7,687,934


400,917
307,545
373,407
77,182,066
45,418,187

0
0
0
0
0
0
0
0
0
0
Unsupported
Costs

4,813,935
2,467,655
725,226
42,079
0
0
0
7,456,358
47 ,459
0
37,307
0

0
0
72,766
0
0
0
0
0


0
0
0
2,264,054
0
7,462,898


0
0
2,535,954
6,262,906
25,962,426

0
0
0
0
0
0
0
0
0
0
Unnecessary/ Efficiencies
Unreasonable (Funds Be Put
Costs To Better Use)

78,124
0
0
0
0
0
0
78,724
0
0
0
0

8,722
0
8,722
71,967,543
77,967,543
2,839,772
3,974,753
7,870,725


779,692
0
25,951
0
0
0


33,981
0
0
9,523,674
22,031,928

0
0
0
0
0
0
0
0
0
0
5,275,325







10,738,585













3,607,400
9,023,600











12,625,000
23,363,585











43

-------
                                                                                          Questioned Costs
Audit Control
Number
G3HMK.O-01 -01 82-0500871
G3HWKO-01-0177-0500907
G3HHK.O-01 -01 88-0500909
G3HMK.O-01 -0202-0500953
G3/M0-07-0200-0501027
G3HUK.O-01 -0203-0501 029
G3HmO-01-0199-0501048
G3HMO-01 -0252-0501 096
G3HVKO-OJ-0258-0501098
G3HMJO-01-0215-0501165
G3HMK.O-01 -0277-0501201
G3HMK.O-01-0278-0501243
G3HMKO-01 -0279-0501 246
N3HMKO-01 -0028-0500754
N3HHK.O-01 -01 52-0500779
N3mO-01 -01 87 -0500865
N3HHJO-01 -01 86-0500868
N3HHKO-01 -01 84-0500869
N3HMO-Q1 -01 81 -0500870
N3HMJO-01 -01 83-0500872
N3HMKO-01 -0179-0500885
N3HMK.O-01 -01 89-0500908
N3HMKO-0 1-0204-0501028
N3HMJO-01-0201-0501030
N3mO-Ol-025l-0501095
N3HMK.O-01-0244-0501097
N3/MO-0 1-0265-0501 164
N3HMK.O-01-0168-0501214
N3HMK.O-01-0254-0501242
N3HHK.O-01-0280-0501244
N3HHK.O-01 -0283-0501245
Auditee
WAKEFIELD
BRISTOL
PORTLAND WATER DISTRICT
HADLEY
EXITER
SCARBOROUGH SANITARY DIST.
SALISBURY
HARTFORD
FAIRHAVEN
INTERSTATE SANITATION COMM
WARREN
GARDNER
PLYMOUTH VILLAGE WAT. & SEW.
WORCESTER
LOWELL
CRANSTON
RHODE ISLAND, STATE OF
NANTUCKET
WATERBURY
VERMONT
HARTFORD
STATE OF NEW HAMPSHIRE
NEW HAVEN
STATE OF MAINE
PORTLAND
INDIAN TOWNSHIP
UNIV OF MAINE SYSTEMS
DANBURY
BURLINGTON
L0HELL
NORTHAMPTON
Final Report Ineligible Unsupported Unnecessary/ Efficien
Issued Costs Costs Unreasonable (Funds Be
Costs To Better 1
NH
CT
Mf
MA
NH
ME
MA
VT
MA
CT
MA
MA
.NH
MA
MA
Rl
Rl
MA
CT
VT
CT
NH
CT
ME
ME
ME
ME
CT
VT
MA
MA
5/16/90
5/23/90
5/23/90
6/26/90
6/25/90
6/26/90
6/20/90
8/ 6/90
8/ 6/90
8/28/90
9/17/90
9/25/90
9/26/90
4/ 3/90
4/70/90
5/16/90
5/16/90
5/76/90
5/16/90
5/16/90
5/17/90
5/23/90
6/26/90
6/26/90
8/ 6/90
8/ 6/90
8/28/90
9/78/90
9/25/90
9/26/90
9/26/90
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
                  TOTAL OF REGION 01 « 41
    G3/MO-02-0217-0500857
    G3H«KO~02-0218-0500858
    G3HMKO-02-0224-0500860
     G3HMKO-02-0225-0500861
     G3HMO-02-0226-0500862
     G3HMKO-02-0241-0500916
     G3HUK.O-02-0223-0500925
     G3mO-02-0262-0500977
     G3HMJO-02-0267-0500978
     G3/MO-02-0258-0500982
     G3HMKO-02-0271-0501044
     G3HHK.O-02-0287-0501054
     G3HUKO-02-0288-0501055
     G3HHKO-02-0304-0501100
     G3HHKO-02-0305-0501127
     G3HMKO-02-0325-0501194
     N3HHK.O-02-0133-0500760
     H3HMKO-02-0191-0500761
     N3HMK.O-02-0014-0500777
     N3HMO-02-0204-0500791
     N3HMK.O-02-0205-0500792
     N3HHKO-02-0187-0500835
     H3HHKO-02-0188-0500836
     N3HMKO-02-0189-0500837
FILLMQRE
BERGEN
PRASA
 PRASA
 PRASA
 CAPE HAY COUNTY MUA
 BYRON
 BERGEN COUNTY UA
 INTERSTATE SANITATION COMV
 HAMBURG
 CHESTER
 CASTLETON-ON-HUDSON
 CASTLETON-ON-HUDSON
 BUFFALO SA
 EAST BRUNSWICK. SA
 ROCKWAY VALLLEY RSA
 ERIE COUNTY
 NEW YORK, STATE OF
 SENECA NATION OF INDIANS
 ROCHESTER
 ROCHESTER
 JAHESTOHN
 SAYREV1LLE
 UMY
NY
m
PR
PR
PR
NJ
NY
NJ
NY
NY
NY
M
NY
NY
NJ
NJ
NY
NY
NY
NY
NY
NY
NJ
NY
5/16/90
5/16/90
5/76/90
5/16/90
5/16/90
5/25/90
6/18/90
7/ 2/90
7/ 2/90
7/ 2/90
7/17/90
7/24/90
7/24/90
8/ 7/90
8/14/90
9/13/90
4/ 4/90
4/ 4/90
4/10/90
4/20/90
4/20/90
5/10/90
5/10/90
5/10/90
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
M.

-------
Audit Control Auditee
Number
N3/MO-02-OJ 90-0500838 THERESA Iff
N3HMK.O-02-0206-0500839 FSSFX COUNTY NJ
N3HWKO-02-0279-0500844 UTICA NY
N3HMKO-02-0220-0500845 UTICA NY
N3HMK.O-02-0223-0500846 M/DDLFSFX COUNTY NJ
N3/MO-02-0758-0500905 NASSAU COUNTY NY
N3HMKO-02-0017 -0500906 NFIV YORK C/TY NY
N3HMO-02-0259-0500979 NFHf HARTFORD NY
N3HMJCO-02-0260-0500980 CAT SKILL NY
N3HUKO-02-0257-0500981 CAHDEN CTY COUN ON FCON OPP NJ
N3HMKO-02-0078-0507099 PLATTS8URGH NY
N3HHKD-02-01 46-0501 106 FREEVILLE NY
N3HMKO-02-0374-0507795 FSSfX COUNTY NJ
N3HMKO-02-0768-0507J96 SFNFCA NAT/ON OF INDIANS NY
N3HMKO-02-0307-0507797 FULTON NY
TOTAL OF REGION 02 - 39
C3HMJO-03-0256-0500928 VA HfASTF MANAGFMFNT VA
C3HMKO-03-0257-0500932 HAftFOflO COUNTY 6/86 MO
C3HMKO-03-0258-0500933 HARFOflD COUNTY 6/87 MD
C3HMKO-03-0259-0500934 HARFORD COUNTY FYF 6/88 MO
C3/MO-03-0260-0500936 WARFORD COUNTY FY 6/89 MO
C3HMKO-03-0376-050J026 ANNF ARUNDFL COUNTY MO
C3HHK.O-03-0352-0501183 BALTIMORE COUNTY 6/89 MO
C3HMKO-03-0357-0507792 SUSSEX COUNTY 6/89 OF
C3HHK.O-03-0378-0501193 FAIRFAX COUNTY 6/89 VA
C3HMJO-03-0380-0507200 VA STATE MER CNTRL BOARD VA
G3HMKO-03-OI87-0500827 TAL80T COUNTY 6/89 MO
G3HMKO-03-0263-0500998 INTERSTATE COMH ON POTOMAC MD
G3HMKO-03-0357-0500999 SA/NT MARY'S COUNTY UD
G3HMKO-03-0326-050100I SOMFRSFT COUNTY 6/89 MO
G3HMKO-03-0321-050J006 STBOUOS8URG 80BOUGH OF PA
G3HMKO-03-0272-0507007 LfOLA SFJFfl AUTHORITY PA
G3HHKO-03-03S6-OS01011 SAINT THOMAS TOWNSHIP PA
G3HVKO-03-0354-0507024 6FLLFFONTF SOftOUGH AUTH PA
G3HWKO-03-0392-0501213 ALTOONA C/TY AUTHORITY PA
G3/MO-03-0394-0507277 MONTGOMFftY COUNTY PA
G3HWKO-03-0396-0501278 HUNTINGTON 6/89 W
G3HWXO-03-0420-0507225 OU8L/N fiOftOUGH AUTHORITY PA
G3MKO-03-0393-0507240 OC DFPT CONSUMER & REG DC
N3HMO-03-0068-0500892 ERIE COUNTY FYF 72/87 PA
N3HVJO-03-0735-0500893 VA CONSERVATION & HISTORIC VA
N3HUK.O-03-0178-0500894 RICHMOND CITY OF VA
N3HUK.Q-03-0228-0500895 NATL COUNCIL OF SENIOR CTZN DC
N3HUKO-03-0229-0500896 HOWARD UNIVERSITY 6/88 OC
N3/MO-03-0738-05C0972 ALLFGANY COUNTY MO
N3HUK.O-03-0255-0500913 DELHAR TOM OF 6/86 MO
N3HUKO-03-0097-0500977 TFMPLF UNIVERSITY PA
N3HHK.O-03-0096-0500920 PITTSBURGH UNIVERSITY 6/88 PA
N3HUJO-03-0226-0500997 VA COMMONWFALTH UNIVERSITY VA
N3HMO-03-01 86-0501002 WILMINGTON CITY OF OF
N3HMKO-03-0293-0507003 CECIL COUNTY 6/89 MO
N3HHK.O-03-0286-0501004 NAT'L CAUCUS & C77? ON B AGE DC
N3HMKO-03-0287-0507005 NAT'L CAUCUS & CTR ON B AGE DC
N3HMKO-03-0290-0501008 CAMBRIDGE CITY OF 6/88 MO
N3/MO-03-0297-050J009 CAMBRIDGE CITY OF 6/89 MO
N3HMH9-03-0355-0507070 BALTIMORE CITY OF-FYE 6/88 MO
Final Report
Issued
5/70/90
5/70/90
5/74/90
5/74/90
5/74/90
5/23/90
5/23/90
7/ 2/90
11 2/90
7/ 2/90
8/ 7/90
8/8/90
9/73/90
9/73/90
9/73/90

6/ 7/90
6/27/90
6/27/90
6/27/90
6/27/90
7/73/90
8/30/90
9/77/90
9/77/90
9/77/90
5/ 7/90
7/ 6/90
7/ 6/90
7/ 6/90
7/ 6/90
7/ 6/90
11 6/90
7/73/90
9/18/90
9/79/90
9/79/90
9/20/90
9/25/90
5/21/90
5/21/90
5/21/90
5/21/90
5/21/90
5/24/90
5/24/90
5/25/90
5/25/90
11 6/90
11 6/90
11 6/90
11 6/90
11 6/90
11 6/90
11 6/90
7/6/90
— . . '-. . i "• ... i towwii" • •««•*• w
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9,311
0
0
0
0
0
0
0
0
0
0
0
0
0
0
477,756
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
45

-------
Audit Control Audrtee
Number
N3HMKO-03-0349-0501025 WEST VIRGINIA STATE OF
N3HHJO-03-0285-0501138 VA DEPT OF HEALTH 6/89
N3HUKO-03-0407-0501140 CECIL COUNTY
N3HMKO-03-0353-0501216 PORTSMOUTH CITY OF
N3HMJO-03-0415-05Q1219 VA POLYTECHNIC INSTITUTE
N3HMJO-03-0416-05Q1220 VA INSTITUTE OF MARINE SCI
N3HUKO-03-0427 -0507226 GEORGETOWN UNIVERSITY
N3HHKO-03-0050-0501239 MARYLAND STATE OF FYE 6/88
N3HUKO-03-0447-0507247 TEMPLE UNIVERSITY
TOTAL OF REGION 03 - 49

W
VA
MD
VA
VA
VA
DC
MD
PA

C3HHKO-04-01 84-0500797 LE)(INGTON-FAYETTE CO. GOV.'TM
C3/MO-04-0240-0500975 FT .LAilOERDALE
C3HHKO-04-0306-0501113 COBB COUNTY
C3WKO-04-0372-0507734 TALLAHASSEE
C3HMKO-04-0323-0501185 NASHVILLE & DAVIDSON COUNTY
C3IMO-04-0339-0507237 JACKSONVILLE
G3HHKO-04-0171 -0500750 JACKSON
G3/MO-04-0774-0500755 CLIFTON
G3HHKO-04-0080-0500756 KEVIL
G3HHKO-04-0029-0500796 PORT ORANGE
G3HNKO-04-0185-0500813 GADSEN HATER HORKS 8 SEWEfl
G3MVKO-04-0790-05C0824 ATHOOD
G3HIVKO-04-0788-05C0825 ATLANTIC BEACH
G3mO-04-01 89-0500826 ATtiOOD
G3HHKO-04-0795-0500828 CULLVAN
FL
GA
FL
TN
FL
TN
TN
KY
FL
AL
TN
FL
TN
AL
G3HKKO-04-01 98-0500887 OLD HICKORY UTILITY DISTRICTTN
G3HHKO-04-0222-0500898 SUUTER
G3HNKO-Q4-0219-OS00899 PAHOKEE
G3HHKO-04-0252-0500954 COLLIER COUNTY
G3HMKO-04-0243-0500962 MANATEE COUNTY
G3HHKO-04-0242-0500974 KEY WEST
G3HMKO-04-0254-0500989 HUNTSVILLE
G3HNKO-04-0244-0501033 BERRY
G3WKO-04-0241 -0501034 MANCHESTER
G3MVKO-04-0296-0507050 FORT MILL
G3HHKO-04-0301 -0501 066 PUNTA GORDA
G3/M0-04-0304-0507087 DILLON
G3/MO-04-0307-05077J2 QZARK. UTILITIES BOARD
G3HHKO-04-0313-0501133 SYLMWGA UTILITIES BOARD
G3HNKO-Q4-0324-0501 184 1 NE2
G3HHKO-04-0325-0507787 THOMASVILLE
G3/flVW-04-0332-0507798 NEW BERN
G3HHKO-04-0334-0501203 TARBORO
G3HHKO-04-0320-0501205 SARASOTA
G3HHK.O-04-0328-0501221 BELLE GLADE
G3HHKO-04-0336-0501224 NORTH AUGUSTA
G3HHKO-04-0338-0501234 TRYON
G3HWKO-04-0366-0507235 WESTERN CAROLINA REGION SA
G3HHKO-04-0340-0501236 GEORGETOWN COUNTY MSD
G3HHK.O-04-0344-0501261 AHOSKIE
N3HUKO-04-021 1-0500749 GEORGIA STATE UNIVERSITY
N3HHKO-04-01 91 -0500829 GEORGIA, UNIVERSITY OF
N3HAK.O-04-01 96-0500900 W)X COUNTY
N3HMKO-04-0212-0500901 DUKE UNIVERSITY
N3HHKO-04-0192-0500961 DOTHAN
N3HHKO-04-0223-0500963 HURFREESBORO
SC
FL
FL
FL
FL
AL
AL
KY
SC
FL
SC
AL
AL
KY
GA
NC
NC
FL
FL
SC
NC
SC
SC
NC
GA
GA
TN
NC
AL
TN
Final Report
Issued
7/73/90
8/76/90
8/23/90
9/79/90
9/79/90
9/79/90
9/20/90
9/25/90
9/25/90

4/20/90
6/ 6/90
8/ 7/90
8/74/90
8/37/90
9/24/90
4/ 2/90
41 3/90
41 3/90
4/20/90
5/ 7/90
5/ 7/90
5/ 7/90
5/ 7/90
5/ 8/90
5/78/90
5/22/90
5/22/90
6/26/90
6/ 7/90
6/ 6/90
6/ 7/90
6/ 6/90
6/ 6/90
7/20/90
7/27/90
8/ 2/90
81 7/90
8/13/90
8/31/90
8/31/90
9/75/90
9/74/90
9/ 7/90
9/75/90
9/79/90
9/24/90
9/24/90
9/24/90
9/28/90
41 2/90
5/ 8/90
5/22/90
5/22/90
6/ 7/90
6/ 7/90
	 ' 	 FB V«*WI 1 1 1 1 1 VI II
Ineligible Unsupported Unnecessary/ Efficient
Costs Costs Unreasonable (Funds Be
Costs To Better I
0
0
779,320
0
0
0
0
0
0
540,387
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
46

-------
udft Control Auditee
umber
3HUKO-04-0186-0500964 CLE1YSON UNIVERSITY SC
3HUKO-04-0186-0500965 CLEHSON UNIVERSITY SC
3WJO-04-0035-0500966 NC AT CHARLOTTE UNIVERSITY NC
3HUJO-04-0034-0500967 NORTH CAROLINA STATE UNIVER NC
3HWKO-04-0224-0500968 SANFORD FL
mm-04-0216-0500976 MECKLENBERG COUNTY NC
JHWKO-04-0207-0501037 COLLINS US
mKO-04-0220-0501032 LAKELAND FL
HHKO-04-0217 -0501 035 GASTONIA NC
HMO-04-0258-0501045 FULTON COUNTY GA
HHKO-04-0248-0501046 FULTON COUNTY GA
HWKO-04-0147-0501051 VALDOSTA GA
HHJO-04-0249-0501063 GA DEPT NATURAL RESOURCES GA
HUKQ-04-0273-0501064 NORTHERN KENTUCKY UNIVERSITYKY
HHKO-04-0303-0501065 FORT PAYNE AL
HUJQ-04-Q272-OS01067 MISSISSIPPI MEDICAL CENTER US
HUJO-04-0302-0501068 NC CENTRAL UNIVERSITY NC
WKO-04-01 17-0507076 BERKLEY COUNTY SC
mO-04-0314-0501088 FORT PAYNE AL
fMO-04-0275-0501122 PINELLAS COUNTY FL
WKO-04-0255-0501139 HILLSBOROUGH COUNTY FL
mO-04-0311 -0501 166 GAINESVILLE FL
HHKO-04-01 65-0501 167 HAfiTSVILLE SC
HUKO-04-0299-0507768 FLORIDA INST. OF TECHNOLOGY FL
HUKO-04-0317 -0501169 LOUISVILLE, UNIVERSITY OF KY
HAKO-04-0098-0501170 FORSYTH COUNTY NC
HMO-04-0225-050J786 ST. PETERSBURG FL
HSJO-04-0096-0501188 AL EMERGENCY MANAGEMENT AGFNAL
OTKO-04-0274-0501 199 OKALOOSA COUNTY FL
ttHW.0-04-0276-0501204 SHELBY COUNTY TN
WSJO-04-0257-0501222 GEORGIA DEPT OF EDUCAT ION GA
Y3HW(0-04-0253-0507223 LEE COUNTY FL
J3HWKO-04-0370-0507238 SAVANNAH GA
mUJO-04-0333-0501259 SOUTHERN MISSISSIPPI UNIVER MS
V3fMO-04-0346-0507260 FLEUING-NEON KY
V3fMO-04-0337-0507262 DADE COUNTY FL
N3MVKO-04-0247-0570964 RICHLAND COUNTY SC
TOTAL OF REGION 04 = 83
C3HMJO-05-0207-0500819 HAHHOND FY 88 IN
C3HHKO-05-01 57 -0500897 AKflON FY 88 OH
C3HVJO-05-0337-050I755 HAHHQND FY 89 IN
C3/MO-05-0369-0507189 LANSING FY 89 Ml
G3HHJO-05-0189-0500745 STEUBEN LAKES fflVD FY 87/88 IN
G3HMJO-05-01 69-0500746 ZIONSVILLE FY 87/88 IN
G3HM)(0-05-OI63-0500747 ELYRIA FY 88 OH
G3HUJO-05-01 67 -0500770 WILKINSON FY 87/88 IN
G3HWKO-05-07 87 -0500771 FARMER CITY FY 89 IL
G3HWJO-05-0780-0500775 «ONON FY 87/88 IN
G3HMJO-05-07 99-0500776 WILMINGTON FY 88 OH
G3/MO-05-07 56-0500787 GREENFIELD FY 87 HN
G3HUKO-05-01 85-0500788 Hf CHICAGO FY 89 IL
G3HUJO-05-02 76-0500793 VERSAILLES FY 87/88 IN
G3HMKO-05-0201 -0500806 KFHANEE FY 89 IL
G3HMKO-05-0206-0500820 VERNDALE FY 89 MN
G3HUJO-05-0208-0500832 DALE FY 87/88 IN
G3HVJO-05-02 75-0500850 HAUBSTADT FY 87/88 IN
Final Report Ineligible Unsupported Unnecessary/ Efficiencies
Issued Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
6/28/90
6/ 7/90
6/ 7/90
6/ 7/90
6/27/90
6/ 6/90
6/27/90
6/27/90
6/ 6/90
7/77/90
7/77/90
7/20/90
7/27/90
7/27/90
7/27/90
7/27/90
7/27/90
7/37/90
8/ 2/90
8/10/90
8/20/90
8/24/90
8/24/90
8/24/90
8/24/90
8/24/90
8/31/90
9/ 2/90
9/12/90
9/77/90
9/78/90
9/17/90
9/24/90
9/28/90
9/28/90
9/28/90
6/ 7/90

5/ 2/90
5/22/90
8/27/90
9/ 5/90
4/ 2/90
4/ 2/90
4/ 2/90
4/ 6/90
4/ 9/90
4/ 9/90
4/ 9/90
4/18/90
4/18/90
4/20/90
4/30/90
5/ 2/90
5/ 9/90
5/14/90
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

-------
Audit Control Auditee
Number
G3HVJO-05-0205-050085J SYRACUSE Pf SI/89
G3MJO-05-0214-0500852 ST JOHN FY 87/88
G3HUKO-05-0241 -0500863 ADRIAN Pf 89
G3HVJO-05-0226-0500880 BOQNVILLE FY 88
G3HVJO-05-0252-0500888 DALE Pf 89
G3HHJO-05-0259-0500889 KALIDA LSD Pf 89
G3HUJO-05-0254-0500890 FRANCESVILLE Pf 85/86
G3HVJO-05-0256-0500897 BLOOUFIELD-UESPO LSD Pf 89
G3HVJO-05-0258-0500974 NELSONVILLE-YORK. CSD Pf 89
G3HUK.O-05-0255-0500915 VADISON LSD Pf 89
G3HVJO-05-0274-0500937 ORLEANS FY 87/88
G3HVJO-05-0272-0500938 BATTLE LAKE Pf 89
G3HUJO-05-0273-0500939 CRQTHERSV1LLE Pf 87/88
G3HHK.O-05-0276-0500941 VONftOE CO DC Pf 89
G3HVKO-05-0282-0500955 ROCKf RIVER Pf 88
G3HUJO-05-0286-0500956 BEAVER LSD Pf 88
G3HVKO-05-0288-0500983 CLEVELAND CSD Pf 88
G3HUJO-05-0289-0500984 COLD/MATER VSD Pf 88
G3HUJO-05-0291 -0500985 WASHINGTON LSD Pf 86/87
G3HMKO-05-0284-0500986 CAVPBELLSPORf FY 89
G3HVJO-05-0290-0500987 WAYNE TRACE LSD Pf 88
G3HVJO-05-0287-0500988 SALEM CSO FY 88
G3HUJO-05-0262-0501015 TRI VALLEY LSD Pf 89
G3HUJO-05-0298-0501016 OTSEGO LSD Pf 89
G3HUJO-05-0297 -0501 017 SIDNEY CSO FY 89
G3HVJO-05-0770-0507039 GRABILL Pf 88
G3HUJO-05-0296-050W40 DARUSTADT Pf 87/88
G3/MO-05-0309-0507047 NEENAH-UENASHA SC FY 89
G3HWKO-05-0376-0501042 AVSOY FY 89
G3HVKO-05-0324-0507043 BIGFORK. FY 89
G3HUK.O-05-0312-0501056 STEtiARTVILLE FY 89
G3/MO-05-0373-0507057 HAPLETON FY 89
G3HUKO-05-031 4-0501 058 flROWNTON FY 89
G3HUKO-05-0315-0501059 SILVER LAKE FY 89
G3HUKO-05-031 9-0501 069 HORTHINGTON FY 89
G3HWJO-05-0330-050J070 CHUftUBUSCO FY 87/88
G3HVKO-05-0378-0507072 NASHNAUK FY 89
G3HHK.O-05-0322-0501073 N HOUGHTON CHS FY 89
G3HUKO-05-0320-0501074 DODGE CEHTER FY 89
G3HUKO-05-0321 -0507075 NEW PRAGUE FY 89
G3MJO-05-0326-0507087 ROCHESTER FY 89
G3HUKO-OS-0341 -0501082 LAKEFIELD FY 89
G3HMJO-05-0336-0501083 GOOOLAND FY 88/89
G3/MO-05-0357-0507084 NEOftSD CLEVELAND FY 89
G3HWJO-05-0328-0507085 LAKE STATION FY 89
G3HUJO-05-0325-0501086 TURKEY CREEK. FY 89
G3HUKO-05-0340-0501092 DUNDEE FY 90
G3HMO-05-0337 -0501102 SARTELL FY 89
G3HHKO-05-0338-0501103 MILACA FY 89
G3HVKO-05-0350-0507104 REDWOOD FALLS FY 89
G3/MO-05-0343-050J705 S Sf PAUL FY 89
G3HVKO-05-0375-0507778 MAZEPPA FY 89
G3HHKO-05-0348-0501121 HUTCHIHSQH Pf 89
G3HUK.O-05-0373-0501128 PIPESTONE Pf 89
G3HHK.O-05-0342-0501130 PINCKHEY Pf 90
G3HHKO-05-0374-0501131 BLACK.DUCK Pf 89
G3HHKO-05-0379-050n32 LONG PRAIRIE Pf 89
G3HHKO-05-0397-0501151 PLA/NV/EW-ELG/N SD FY 89
Questioned Costs

IN
IN
UN
IN
IN
OH
IN
OH
OH
OH
IN
UN
IN
VI
OH
OH
OH
OH
OH
Wl
OH
OH
OH
OH
OH
IN
IN
HI
UN
UN
UN
UN
UN
UN
UN
IN
UN
VI
UN
UN
IN
UN
IN
OH
IN
IN
VI
VN
UN
MN
VN
VN
VN
VN
VI
VN
VN
VN
Final Report
Issued
5/74/90
5/74/90
5/76/90
5/77/90
5/78/90
5/78/90
5/78/90
5/78/90
5/24/90
5/24/90
6/22/90
6/22/90
6/22/90
6/22/90
6/27/90
6/27/90
7/ 2/90
7/ 2/90
7/ 2/90
7/ 2/90
7/ 2/90
7/ 2/90
7/70/90
7/77/90
7/70/90
7/77/90
7/77/90
7/77/90
7/77/90
7/77/90
7/25/90
7/25/90
7/25/90
7/25/90
7/37/90
7/31/90
7/37/90
7/37/90
7/37/90
7/37/90
8/ 2/90
8/ 2/90
8/ 2/90
8/ 2/90
8/ 2/90
8/ 2/90
8/ 3/90
8/ 8/90
8/ 8/90
8/ 8/90
8/ 8/90
8/73/90
8/73/90
8/74/90
8/74/90
8/74/90
8/74/90
8/27/90

Ineligible Unsupported Unnecessary/ Efficiei
Costs Costs Unreasonable (Funds B«
Costs To Better
0
0
0
67,889
0
0
0
0
0
0
0
0
0
383,740
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

-------
Audit Control Audrtee
Number
G3HVKO-05-0398-0507752 CARVER Pf 89
G3HMKO-05-0381 -0501211 DELTA THP LANSING Ff 89
N3HMKO-05-0200-0500744 LOYOLA FY 88/89
N3HMKO-05-01 39-0500773 CLEVELAND Pf 88
N3HHKO-05-0131 -0500784 HARREN Pf 88
N3M«JO-05-0755-0500785 CLERMONT CO Pf 88
N3HMKO-05-0173-0500786 CHICAGO Pf 88
N3HMJO-05-0198-0500794 INDIANA STATE U
N3HMKO-05-01 97-0500795 HI SCONS IN MED COLLEGE
i3HMKO-05-0087-0500821 BATTLE CREEK FY 89
V3HHJO-OS-Q188-0500833 CWAHOGA CO Pf 88
WMO-05-0096-0500834 SHIAHASSEE CO FY 88
mHKO-05-0210-0500849 H IL U MACOMB FY 89
I3HMJO-05-02 13-0500864 MONTGOMERY CO FY 88
WMO-05-0092-0500879 EAU CLAIRE FY 88
y3/MO-05-0277-0500940 ILLINOIS DPH FY 88/89
tf/MO-05-0267-0507078 MENQMINEE /NO TRIBE FY 89
ttMJO-05-0287 -050701 9 LICKING CO FY 88
/3HHKO-05-0280-050J020 ASHTABULA, CO Pf 88
I3HHKO-05-0209-0501021 ASHTABULA CO Pf 87
N3HMCO-05-0377-0507038 COLUMBUS FY 89
N3HMJO-05-0285-0501049 FERDINAND Pf 87/88
N3HMJO-05-0329-050W71 INDIANA U FY 89
N3HVKO-05-0345-0507779 SIU CARBONDALE FY 88/89
N3HMKO-05-0367-0507720 OH/0 ST Pf 88/89
N3HWKO-05-0380-0507729 CASS LAKE Pf 89
N3HHJO-05-0407-0501190 WASHINGTON CO Pf 89
NSfMO-05-0408-0507797 EAU CLAIRE Pf 89
TOTAL OF REGION 05 = 704
C3/MO-06-OJ73-0500843 SAN ANTONIO
G3HTO-06-OI70-0500876 BAY CITY
G3/MO-06-0777 -0500877 DIBOLL
G3HHKO-06-0172-0500818 DIBOLL
G3HHK.O-06-017S-0500840 ARDMORE
G3WKO-06-0776-0500847 ARDHORE
G3WW/(0-06-0178-0500842 GAINESVILLE
G3HHKO-06-0179-0500848 LINDEN
G3WKO-06-0787-0500874 OAKDALE
G3HHKO-06-01 88-0500875 PRINCETON
G3HNK.O-06-01 89-0500876 RED RIVER
G3HNKO-06-01 85-0500877 BACLIFF MUNICIPAL UTILITIES
G3HMO-06-01 86-0500878 BACLIFF MUNICIPAL UTILITIES
G3HHH.O-06-0180-0500881 MIDWEST CITY
G3HHK.O-06-01 81 -0500882 NEDERLAND
G3HHK.O-06-01 82-0500883 SANGER
G3HHK.O-06-01 83-0500884 hfFLCH
G3HWKO-06-0205-0500929 PRINCETON
G3HMO-06-0213-050W13 CAVE CITY NNTP CONSTRUCTION
G3HIVKO-06-0230-0507 745 F4YF77FV / LLE

UN
Ml
IL
OH
OH
OH
IL
IN
HI
Ml
OH
HI
IL
OH
HI
IL
HI
OH
OH
OH
OH
IN
IN
IL
OH
MN
UN
HI

TX
rx
rx
rx
OK
OK
rx
rx
LA
rx
NM
rx
rx
OK
rx
rx
OK
rx
Afi
AR
G3HHKO-06-0233-0501146 JACKSONVILLE HASTEWER UTILAR
G3HIVKO-06-0237-0507I48 FAYEfrFV/LLF
G3Hiy/(0-06-0232-0507749 FAYETTEVILLE
G3HHK.O-06-0241 -0501 158 CAVE CITY mP
G3WKO-06-0242-0507159 CAVE CITY WKTP CONSTRUCTION
G3HHK.O-06-0243-0501160 CAVE CITY W(TP CONSTRUCTION
G3HUKO-06-0240-0501161 EDINBURG
AR
Afl
Aft
Aft
Afl
rx
Final Report
Issued
8/27/90
9/78/90
4/ 2/90
4/ 9/90
4/77/90
4/76/90
4/76/90
4/20/90
4/20/90
5/ 2/90
5/ 9/90
5/ 9/90
5/74/90
5/76/90
5/77/90
6/22/90
7/ 6/90
7/ 6/90
7/ 6/90
7/ 6/90
7/77/90
7/79/90
7/37/90
8/73/90
8/73/90
8/14/90
9/ 6/90
9/ 6/90

5/77/90
5/ 7/90
5/ 2/90
5/ 2/90
5/77/90
5/77/90
5/77/90
5/74/90
5/77/90
5/77/90
5/77/90
5/77/90
5/77/90
5/77/90
5/77/90
5/77/90
5/77/90
6/20/90
7/77/90
8/24/90
8/24/90
8/24/90
8/27/90
8/28/90
8/28/90
8/28/90
8/28/90
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
457 ,029
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
49

-------
                                                                                      Questioned Costs
Audit Control Audftee
Number
G3WKO-06-0239-0501162 ABERNATHY TX
G3HHKO-06-0197-OSQ1179 SAN JUAM TX
G3HHKO-06-0196-0501181 DERIDDER LA
G3HHKO-06-0252-0507257 CROSBY HUNICIPAL UTILITY TX
G3WKO-06-0253-0507252 EDINBURG TX
N3HHKO-06-01 43-0500743 BRYAN TX
N3HHKO-06-0166-0500807 CRCHDER COLLEGE OK
N3HHJO-06-0167-0500808 ARKANSAS DEPT OF HEALTH Aft
N3HHJO-06-0168-0500809 ARKANSAS DEPT OF HEALTH Aft
N3HHKO-06-01 42-0500810 CORPUS CHRISTI TX
N3HHKO-06-0106-0500811 CORPUS CHRISTI TX
N3HHJO-06-0177-0500830 ARKANSAS DEPT OF HEALTH Aft
N3HNKO-06-01 98-0500926 LAREDO TX
N3HHKO-06-01 99-0500927 LAREDO TX
N3HHKO-06-0215-0501037 MARSHALL TX
N3HHKO-06-0234-0501147 BAYTOHN TX
N3HHKO-06-0235-0501150 FORT HORTH TX
N3/MO-06-0202-0501J76 NACOGDOCHES TX
N3HHKO-06-0203-0501177 OKLAHOMA CITY OK
N3WKO-06-0218-0501253 BEAUUONT TX
TOTAL OF REGION 06 « 47
C3HUJO-07-0275-0501163 NEBRASKA DEPT OF EW.CQNTRQLNE
G3HHJO-07-0219-0500814 RED OAK IA
G3HNJO-07-0220-0500815 ATALISSA IA
G3HHKO-07-0222-0500822 CHAUTAUQUA KS
G3HHKO-07-0227 -0500847 PRAIRIE ACRES IUPROVEHENT KS
G3HHK.O-07-0229-0500859 JOPLIN HO
G3HNKO-07-0230-0500866 MALOfN MO
G3HHKO-07-0231 -0500873 WALKER HO
G3HHJO-07-0244-0500930 PAC/F/C JUNCTION IA
G3HWKO-07-0245-0500931 MYSTIC IA
G3HNKO-07-0259-0501060 HINFIELD KS
G3HHK.O-07-0260-0501061 SIKESTON BOARD OF UTILITIES HO
G3HWKO-07-0267-0501062 SIKESTON BOARD OF UTILITIES HO
G3mO-07-0281 -05011 41 KIUBERLING CITY HO
G3WKO-07-0276-0501142 JOPLIN HO
G3HWKO-07-0279-0507144 ELKHART KS
G3HHKO-07-0280-0501153 HUTCHINSON KS
G3HHKO-07-0277-0501154 ERIE KS
G3HHKO-07-0285-0501156 CENTRALIA HO
G3HHKO-07-0284-0501157 BEEHER NE
G3HHKO-07-0240-0501175 HILLARD HO
G3HHKO-07-0241 -0501178 WIGHT CITY HO
G3HHKO-07-0243-0501180 LIBERTY HO
G3HHKO-07-0292-0501254 OLATHE KS
G3HHKO-07-0294-0501255 NESS CITY KS
G3HHKO-07-0295-05Q1257 CRETE NE
N3HHKO-07-0172-0500762 SIOUX CITY IA
N3HAKO-07-021 8-050081 2 POLK COUNTY IA
N3HUKO-07-0223-0500823 DES HOINES IA
N3HPJO-07-0226-0500831 IOHA DEPT OF EMPLOYMENT SERVIA
N3HHKO-07-0255-0501014 EASTERN IOHA COM COLLEGE DISIA
N3HHJO-07-0242-0501173 KANSAS CORP CONTROL KS
N3WJO-07-02T7-0501174 K/fiKWOOD COMMUNITY COLLEGE IA
N3HKKO-07-0296-0501256 SEDGHICK COUNTY KS
N3HHKO-07-0197-0501258 INDEPENDENCE KS
TOTAL OF REGION 07-35
Rnal Report Ineligible Unsupported Unnecessary/ Efficiw
Issued Costs Costs Unreasonable (Funds B«
Costs To Better
8/28/90
8/31/90
8/3J/90
9/27/90
9/27/90
4/ 2/90
5/ 7/90
5/ J/90
5/ 1/90
5/ 7/90
5/ 7/90
5/ 9/90
6/79/90
6/79/90
7/16/90
8/24/90
8/27/90
8/37/90
8/37/90
9/27/90

8/28/90
5/ 1/90
5/ 7/90
5/ 3/90
5/74/90
5/15/90
5/16/90
5/16/90
6/27/90
6/27/90
7/27/90
7/27/90
7/27/90
8/24/90
8/24/90
8/24/90
8/27/90
8/27/90
8/28/90
8/28/90
8/37/90
8/37/90
8/37/90
9/27/90
9/28/90
9/28/90
4/ 5/90
5/ 7/90
5/ 3/90
5/ 9/90
7/77/90
8/30/90
9/70/90
9/28/90
9/28/90

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

50

-------
Vudtt Control Audttee
lumber
;3HMJO-08-OJ 74-0507229 DEPT OF ENVIRONMENTAL QUAL. Iff
J3HMJO-08-0078-0500855 MOVING OIL « GAS COMM/SS/ONNY
;3HMJO-08-0087-0500924 WEST FARGO, CITY OF NO
)3HMJO-08-0084-0500952 MADOCK CITY OF NO NO
I3HMKO-08-0097 -0500957 GFNFSFF OTR « SAN D/STfi/CT CO
;3HI
-------
Questioned Costs
Audit Control Auditee
Number
N3HHKO-09-0225-0500903 COLORADO RIVER INDIAN TRIBE AZ
N3HHKO-09-0091 -0500919 HAHAII, COUNTY OF HI
N3HUKO-Q9-0210-0500921 KINGS, COUNTY OF CA
N3HUKO-09-0211 -0500923 CORKING, CITY OF CA
N3HUKO-09-0216-0500943 SAN LUCAS COUNTY HATER DIST CA
N3mO-09-0217-0500944 ALBANY, CITY OF CA
N3HHKO-Q9-0219-0500946 VENTURA COUNTY OF CA
N3HWCO-09-0121 -0500947 SOUTH COAST AIR QUAL JBT 01 CA
N3HUJO-09-0201 -0500950 STEGE SANITARY DISTRICT CA
N3HHKO-09-0200-0500951 SAN FRANCISCO, CITY OF CA
N3HUK.O-09-0202-0500970 TRACY CITY OF CA
N3HMKO-09-0203-0500971 ORANGE COUNTY OF CA
N3HMKO-09-0204-0500972 OAKLAND CITY OF CA
N3HHKO-09-0205-0500973 LAKE COUNTY CA CA
N3HUKO-09-0095-0500993 SANTA CRUZ, CITY OF CA
N3HUJQ-09-0128-0500994 CALIFORNIA, STATE OF CA
N3HHKO-09-0229-OS00996 SONOUA, COUNTY OF CA
N3HMKO-09-0207-0501000 EUREKA, CITY OF CA
N3HHK.O-09-0232-050W12 GUADALUPE , CITY OF CA
N3HUKO-09-0251 -0501 091 RENO, CITY OF NV
N3HUKO-09-0254-0501W7 UERCED, COUNTY OF CA
N3/MO-09-0255-0501108 SAN DIEGO, COUNTY OF CA
N3HVKO-09-0234-0501109 SOUTH TAHOE PUD CA
N3HMK.O-09-0256-0501110 FRESNO, COUNTY OF CA
N3HUJO-09-0197-0501114 HARICOPA COUNTY AZ
N3HMKO-09-0257-0501115 GFR8Efl-LAS FLORES COM SER CA
N3HUKO-09-0258-0501117 SANTA CLARA VALLEY HATER Dl CA
N3HHKO-09-0233-0501124 BAY AREA AIR QUALITY UGUT DICA
N3HUJO-09-0259-0501125 SAN JOAQUIN VALLEYHIDE AIR CA
N3mO-09-0260-0501136 SAN DIEGO, CITY OF CA
N3HMKO-09-0265-0501137 OCEANS I OF, CITY OF CA
N3HMKO-09-0278-0501171 HORRO BAY CITY OF CA
N3HHKO-09-0279-0501172 EASTERN HUNICIPAL HATER DIS CA
N3HHKO-09-0281 -0501207 BANNING, CITY OF CA
N3HHKO-09-0276-0501208 HAWAII, DEPT. OF AGRIC. HI
N3HUKO-09-0287 -0501209 ELSINORE VAL HUNI 'HATER DIS CA
N3HUKO-09-0288-0501212 GUALALA COUHUNITY SERV. DISTCA
N3HUKO-09-0296-0501230 REP OF THE MARSHALL ISLANDS UH
N3HUKO-09-0297-Q501231 SHASTA COUNTY OF CA
N3HUKO-09-0277-0501232 PHOENIX, CITY OF AZ
N3HUKO-09-0237 -0501233 WODESTO, CITY OF CA
N3HHKO-09-0235-0501248 HAHAI 1 , DEPT OF HEALTH HI
N3HHKO-09-0301 -0501 249 GUALALA COM. SERV. CA
Final Report
Issued
5/22/90
5/25/90
6/13/90
6/13/90
6/22/90
6/22/90
6/22/90
6/22/90
6/ 6/90
6/ 6/90
6/ 8/90
6/ 8/90
6/ 8/90
6/ 8/90
7/ 3/90
7/ 3/90
7/ 5/90
7/ 6/90
11 9/90
8/ 2/90
8/ 9/90
8/ 9/90
8/ 9/90
8/ 9/90
8/10/90
8/10/90
8/10/90
8/14/90
8/14/90
8/15/90
8/15/90
8/29/90
8/30/90
9/17/90
9/17/90
9/17/90
9/18/90
9/20/90
9/20/90
9/20/90
9/21/90
9/26/90
9/26/90
DAA A •««•*%«
Ineligible Unsupported Unnecessary/ Efficie
Costs Costs Unreasonable (Funds B
Costs To Better
0
0
0
0
0
3,389
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
33,282
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
              TOTAL OF flEGION 09 «   68
G3/MO-
G3HVKO
G3HMKO
G3HUKO
G3HUJO
G3HUKQ
G3HHJO
G3HHKO
G3HHJO-
N3HHKO-
N3HHJO-
N3HUJO-
N3HUKO-
•10-0030-0500751
•10-0031-0500752
-10-0059-0500758
•10-0057-0500798
•10-0070-0500904
•10-0071-0500910
•10-0072-0500969
•10-0087-0501053
•10-0095-0501250
•10-0041-0500902
•10-0042-0500918
•10-0067-0500990
•10-0034-0500995
TANGENT, CITY OF
SPRINGFIELD, CITY OF
NFJBFRG, CITY OF
COFUfi D' ALENE, CITY OF
COLLEGE PLACE, CITY OF
JUNEAU, CITY AND fiOfiOUGH
UCCLEARY, CITY OF
HOMER, CITY OF
DAVENPORT, CITY OF
EUGENE, CITY OF
OREGON, STATE OF
ALASKA DEPT OF ENVIRON. CON AK
SUQUAMISH TRIBE             HA
OR
OR
OR
ID
HA
AK
HA
AK
HA
OR
OR
4/ 2/90
4/ 2/90
4/ 3/90
4/24/90
5/22/90
5/23/90
6/ 8/90
7/23/90
9/26/90
5/22/90
5/25/90
7/ 3/90
7/ 5/90
611,614

      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
      0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

-------
                                                                                     Questioned Costs
jdit Control
umber
HMJO- 70-0033-0501090
HMJO-10-0073-0501093
HMKO-10-0028-05011J6
HMKO-70-0083-0507I35
HMJO-70-0092-050J2JO
HMJO-10-0094-0501247
Auditee
IDAHO DEPT OF AGRICULTURE ID
HASH/NGTON, STATE OF HA
NORTH SEND, CITY OF Ofi
PORTLAND, Cm OF Oft
DFPr. COMMERCE & ECON DEV. AK
IDAHO DEPT OF LABOR & IND SVID
Final Report
Issued
8/ 2/90
8/ 3/90
8/70/90
8/15/90
9/17/90
9/26/90
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
0
0
0
0
10,167
0
0
0
0
0
0
0
0
0
0
0
0
0
             TOTAL OF REGION 10 =   79

             TOTAL OTHER GRANT AUDITS

.  SUPERFUND GRANTS

5fiFN9-04-0790-0300045  HS DEPT OF NAT RESOURCES    US
J6GN9-04-0273-0300048  GA DEPT OF NATURAL RESOURCESGA
jfiGN9-04-OJ29-0300049  NC, DHR                     NC

             TOTAL OF REGION 04 =    3

5SHN9-08-0092-0300096  SO. ADAMS COUNTY WSD        CO

             TOTAL OF REGION 08 =    1

5BKN9-09-0267-0300098  SOUTH BAY MULT I-SITE        CA

             TOTAL OF REGION 09 =    1

5CHN9-10-0151-0300095  OREGON DEQ                  OR

             TOTAL OF REGION 10 •    1

58FLO-11-0034-0100428  SF JAG-INTERIOR (OEPfi;
5BFLO-I1-0035-0100475  SF IAGS - INTERIOR AGENCIES

             TOTAL OF REGION 11 =    2

             TOTAL SUPERFUND GRANTS

.  OTHER CONTRACT AUDITS
515
                    10,167
2,155,614
4/20/90
5/ 1/90
5/ 3/90

9/27/90

9/28/90

9/27/90

1,593
5,813
1,083
8,489
65,431
65,431
0
0
81,028
81 ,028
0
8,435
0
8,435
3,159,365
3,759,365
2,903,899
2,903,899
0
0
0
0
0
0
207,194
207,194
0
0
0
0
  8/13/90
  8/24/90
                   154,948
               6,071,699
207,194
88MLO-01-0165-0100241
8AMLO-01-0164-0100242
8AMLO-01-OJ66-0100243
8AMLO-07-0793-OJ00322
8AMLO-01-0192-0100323
8AVLO-07-OJ9I-0700324
8AVLO-01-0190-0700325
(8AMLO-07-0794-0700352
J8AMLO-01-021 1-0100375
)8A«LO-07-0219-0700378
)8AVLO-07-0272-0700379
J8AMLO-01-0207-0100380
J8AMLO-01-0208-0100381
)8AMLO-07-0209-0700382
)8AMLO-OI-0206-0700383
58AMLO-07-0205-0700384
D8AMLO-07-02J3-OJ00385
D8AMLO-01-0214-0100386
D8AMLO-01-0278-0700387
INDUSTRIAL ECONOMICS INC
GREAT LAKES TOWING CO.
GRADIENT CORPORATION
MIDWEST RESEARCH INSTITUTE
THE CADMUS GROUP IKALTHAY
AST ASSOCIATES CAMBRIDGE
THE CADMUS GROUP
MA
OH
MA
ME
MA
MA
MA
TRC ENVIRONMENTAL CONSULT ANTCT
CE ENVIRONMENTAL INC
CAMP DRESSER MCKEE IWC
ALL/AflCE TECHNOLOGIES
CADMUS GROUP
ENSfl CORPORATION
ENSR CORPORATION
INDUSTRIAL ECONOMICS
ALLIANCE TECHNOLOGIES
STONE & HEBSTER ENV. SUS.
BARRY LARSON ASSOCIATES
TEMPLE BARKER & SLOANE INC.
ME
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
4/ 3/90
4/ 3/90
4/ 3/90
5/23/90
5/23/90
5/23/90
5/23/90
6/21/90
7/ 2/90
7/ 9/90
7/ 9/90
7/ 9/90
7/ 9/90
7/ 9/90
7/ 9/90
7/ 9/90
7/ 9/90
7/ 9/90
7/ 9/90
                                                                   'The dollar value of contract audits have not been shown.
                                                                    Public disclosure of the dollar value of financial recom-
                                                                    mendations could prematurely reveal the Government's
                                                                    negotiating positions or release of this information is
                                                                    not routinely available under the Freedom of Information
                                                                    Act.  The number of these reports and dollar value of the
                                                                    findings have been included In the aggregate data displayed
                                                                    belon.  Such data Individually excluded In this listing Hill
                                                                    be provided to the Congress under separate memorandum within
                                                                    30 days of the transmlttal of the semiannual report to the
                                                                    agency head.  The transmitted data will contain appropriate
                                                                    cautions regarding disclosure.
                                                                                                                                  53

-------
    Audit Control
    Number
Auditee
    Final Report
    Issued
              Ineligible
                 Costs
Questioned Costs             B
              	  RscoiiiMiei
               Unnecessary/      Efficiei
              Unreasonable   (Funds B«
                      Costs  To Better
Unsupported
       Costs
    D8AMLO-07-02J6-OJ00388
    D8AJKLO-0 7-0220-0100389
     D8AMLO-01-0248-0100421
     D8AHLO-01-0250-0100422
     D8AHLO-01-0246-0100423
     D8AMLO-07-0247-0700424
     D8AHLO-01-0256-0100425
     D8AHLO-01-0264-0100459
     D8AMLO-01-0263-0100471
     D8AHLO-01-0287-0100506
     D8AHLO-01-0276-0100507
     S8DHL9-01-0183-0100457
     S8DHLO-01-0315-0100535
ALLIANCE TECHNOLOGIES       HA
fASTERN RESEARCH GROUP      HA
 fiADGER ENGINEERING INC.    HA
 BADGER ENGINEERING INC.    HA
 RESOURCE ANALYSTS INC.      NH
 RESOURCE ANALYSTS INC.      NH
 ARTHUR D. LITTLE           HA
 CADMUS GROUP               HA
 EASTERN RESEARCH GROUP      MA
 TOXIKON CORPORATION         HA
 EASTERN RESEARCH GROUP INC. HA
 UNIVERSAL ENGINEERING CORP. HA
 CHARLES J. KRASNOFF & ASSOC.fi/
                   TOTAL OF BEG/ON 07
              32
     D8AHLO-02-0228-0100312
     D8AIYLO-02-0326-0100476
     D8AHLO-02-0327-0100477
 KOHLMANN BUGG/ERO
 HYDROQUAL INC
 HYDROWAL INC
NY
NJ
NJ
                   TOTAL OF REGION 02 =
     D8AMLO-03-0235-0700284
     D8AHLO-03-0236-0100285
     D8AMLO-03-0237-0700286
     D8AMLO-03-0238-0100287
     D8AHLO-03-0239-0100289
     D8AHLO-03-0240-0100290
     D8AHLO-03-0241-0100291
     D8AMLO-03-0242-0700292
     D8AMLO-03-0243-0700293
     D8AHLO-03-0244-0700294
     D8AMLO-03-0245-0700295
     D8DMLO-03-0246-0700296
     D8AHLO-03-0247-0100297
     D8CMLO-03-0248-0700298
     D8AMLO-03-0249-0700299
     D8AHLO-03-0250-0100300
     D8AMLO-03-0257-0700307
     D8BHLO-03-0252-0100302
     08CHLO-03-0253-010Q303
     D8AHLO-03-02S4-0100304
     D8AHLO-03-0273-0100326
     D8AHLO-03-0274-0100327
     D8AHLO-03-0276-0100328
     D8AHLO-03-0278-0100329
     D3AHLO-03-0281-0100330
     D8AM.O-03-0284-0100331
     D8AMLO-03-0294-0100332
     D8AHLO-Q3-0295-0100333
     D8AHLO-03-0296-0100336
     D8AHLO-03-0298-0100337
     D8AHLO-03-0275-0100338
     D8AULO-03-0277-0100339
     D8AHLO-03-0279-0100340
     D8AHLO-03-0280-0100341
     D8AWLO-03-0282-0700342
       08DWLO-03-0328-0700363
       D8AMLO-03-0334-0700364
 A7L/S FEDERAL SERVICES
 CHELSEA  INTERNATIONAL CORP
 ENVIRONMENTAL MGMT SUP
 GK.Y & ASSOCIATES  INC
 HYDROGEOLOGIC  INC
 HYDROGEOLOGIC  INC
 ICF  INCORPORATED
 jm  INTERNATIONAL CORP
 HERIDIAN RESEARCH INC
 MERIDIAN RESEARCH INC
 MITCHELL SYSTEMS  CORP
 ROY F. HfESTON  INC.
 SCIENCE  & POLICY  ASSOC  INC
 SRA  TECHNOLOGIES  INC
 TECHNICAL RESOURCES INC
 TECHNICAL RESOURCES INC
 TECHNICAL RESOURES INC
 UN/SYS CORPORATION DEFENSE
 V/AR i COMPANY INC
 WADE «/LLEft ASSOCIATES  INC
  ICF INCORPORATED
 HfESTAT INC
 AUTOMOMATED SCIENCES GROUP
 UNISYS CORPORATION
 V/AR & COMPANY
  ENVIRONOVICS INC
  UN/SYS CORPORATION
 CONSEWAT/OW FOUNDATION
  S080TKA * COMPANY INC
  EVALUATION RESEARCH CORP
  CSC APPLIED TECHNOLOGY DIV
  EARTH SATELLITE CORPORATION MD
  GENERAL SCIENCES CORPORAT/ONMO
  AVER/CAN MANAGEMENT SYSTEMS VA
  TECHNICAL RESOURCES INC
   800Z ALLEN 8  HAMILTON
   CftC  SYSTEMS INC
      7/ 9/90
      II 9/90
      8/ 6/90
      8/ 6/90
      8/ 6/90
      8/ 6/90
      8/ 6/90
      8/28/90
      9/ 6/90
      9/26/90
      9/26/90
      8/23/90
      9/28/90
5/ 9/90
9/73/90
9/73/90
MD
DC
MD
VA
VA
VA
VA
VA
MD
MO
VA
PA
DC
VA
HD
HD
MD
VA
VA
VA
VA
UD
MD
VA
VA
VA
VA
DC
DC
VA
VA
1 MD
)NMD
> VA
MO
MD
VA
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/26/90
4/27/90
4/27/90
4/27/90
5/24/90
5/24/90
5/24/90
5/24/90
5/24/90
5/24/90
5/24/90
5/24/90
5/25/90
5/25/90
5/25/90
5/25/90
5/25/90
5/25/90
5/25/90
6/28/90
6/28/90
54

-------
Questioned Costs
idtt Control Audrtee
Jtnber
AMLO-03-0335-0100365 SOLUTIONS fi/ DESIGN VA
AMLO-03-0337-0100366 ASCI CORPORATION VA
CMLO-03-0327-0100367 SOSOTKA 8 COMPANY INC DC
AMLO-03-0329-0100368 CC JOHNSON & MALHOTRA PC MD
AMLO-03-0330-0 700369 MERIDIAN CORPORAT 1 ON VA
AMLO-03-0337 -0700370 INFORMATION MANAGEMENT D/V VA
AMLO-03-0332-0700377 JACA CORPORATION PA
AMLO-03-0333-OJ00372 ENERGY & ENVIRONMENTAL VA
AMLO-03-0336-0700373 S COHEN & ASSOCIATES VA
AMLO-03-0363-0700391 C.C. JOHNSON & HALHOTRA MD
AMLO-03-0364-0700392 C.C. JOHNSON & MALHOTRA MD
AMLO-03-0365-0100393 RESOURCE APPLICATIONS INC VA
AMLO-03-0366-0100394 MARASCO NEHTTON GROUP LTD VA
AMLO-03-0367-0100395 ICF INCORPORATED VA
6MLO-03-0368-OJ00396 ICF INCORPORATED VA
FMLO-03-0369-OJ00397 SAUM ENTERPRISES INC VA
AMLO-03-0370-0100398 FORD AEROSPACE CORPORATION MD
;MLO-03-0371-0100399 POLICY & PLANNING EVAL VA
AMLO-03-0372-0700400 APOGEE RESEARCH INC MD
AMLO-03-0373-0700401 INFO SYSTEMS SOLUTION INTER MD
AMLO-03-0374-0700402 AMERICAN MANAGEMENT SYSTEMS VA
AMLO-03-0375-0700403 ROY F. WESTON INC PA
AMLO-03-0377-0700405 ROY F IVESTON PA
AMLO-03-0397-0100432 DAVID C COX & ASSOCIATES DC
AMLO-03-0398-0700433 COM FEDERAL PROGRAMS CORP VA
AMLO-03-0399-0700434 BETHLEHEM STEEL CORPORATION PA
AMLO-03-0401 -0100436 RESOURCE APPLICATIONS VA
AMLO-03-0402-0100437 RESOURCE APPLICATIONS INC VA
AMLO-03-0403-0100439 VIRGYAN INC VA
AMLO-03-0404-0100441 (CF TECHNOLOGY INC VA
AMLO-03-0405-0100442 CONCEPTUAL SYSTEMS INC MD
AMLO-03-0400-0100443 HESTAT INC MD
CMLO-03-0406-0100444 VIAR AND COMPANY VA
5AMLO-03-0423-0100494 ENVIRONMENTAL MGMT SUP MD
5CMLO-03-0424-0100495 6IONETICS CORPORATION VA
3CMLO-03-0425-0700496 filONETICS CORPORATION VA
3AMLO-03-0426-0700497 ENERGY & ENVIRONMENTAL ANAL VA
3AMLO-03-0427-0100498 JHfK INTERNATIONAL CORP VA
3CMLO-03-0428-0100499 KENDRICK & COMPANY DC
3AMLO-03-0429-0100500 PACIFIC ENVIRONMENTAL SfR VA
3AMLO-03-0430-0100501 TECHNOLOGY & MGMT SERVICE MO
8AMLO-03-0431-0100502 TECHNICAL RESOURCES INC MD
8DMLO-03-0432-0100503 8ENDIX FIELD ENGINEERING MD
8AMLO-03-0433-0100504 VIAR AND COMPANY VA
8AMLO-03-0444-0100570 SOOZ ALLEN S HAMILTON INC MD
8EMLO-03-0440-0100511 NETWORK MANAGEMENT INC VA
I8AMLO-03-0447-0100572 JACA CORPORATION PA
8DMLO-03-0442-07005I3 PACIFIC ENVIRONMENTAL SERV VA
8DMLO-03-0439-OI00574 BOOZ ALLEN & HAMILTON INC MD
)8AMLO-03-0438-01005J5 CLEMENT INTERNATIONAL VA
58AMLO-03-0446-0700576 ULTRA TECHNOLOGIES MO
)8DMLO-03-0436-0100517 S080TIC4 & COMPANY INC OC
)8AMLO-03-0434-OI00578 DYNAMAC CORPORATION MD
08AMLO-03-0435-0 700529 DYNAMAC CORPORATION MD
D8AMLO-03-0437-0700530 E.H. PECHAN & ASSOCIATES VA
D8AMLO-03-0443-0700537 TECHNICAL RESOURCES INC MD
D8AMLO-03-0445-0700532 HfOODWARD-CLYDE FEDERAL MD
TOTAL OF REGION 03 = 94
Final Report
Issued
6/28/90
6/28/90
6/28/90
6/28/90
6/28/90
6/28/90
6/28/90
6/28/90
6/28/90
7/77/90
7/77/90
7/77/90
7/77/90
7/72/90
7/72/90
7/72/90
7/12/90
7/12/90
7/12/90
7/12/90
7/12/90
7/12/90
7/13/90
8/14/90
8/14/90
8/14/90
8/14/90
8/14/90
8/14/90
8/15/90
8/15/90
8/16/90
8/16/90
9/25/90
9/25/90
9/25/90
9/25/90
9/25/90
9/25/90
9/25/90
9/25/90
9/25/90
9/25/90
9/25/90
9/26/90
9/26/90
9/26/90
9/26/90
9/26/90
9/26/90
9/26/90
9/26/90
9/26/90
9/28/90
9/28/90
9/28/90
9/28/90

: • 	 — 	 • necommenaeo
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)


























































                                           55

-------
Audit Control Auditee
Number
D8AMLO-04-0206-0700246 GKY & ASSOCIATES (FS & E) FL
D8AHLO-04-0221 -0100272 NSI TECHNOLOGY NC
D8AHLO-04-0235-0100276 KILKELLY ENV. ASSOC NC
D8AMLO-04-0262-0700327 META INC. COMPUTER SCIENCES FL
D8AULO-04-0295-0100374 NSI TECHNOLOGY NC
D8AMLO-04-033S-0100414 RESEARCH & EVALUATION ASSOC NC
D8AMLO-04-0363-0100440 ENTROPY ENVIRONMENTALISTS AL
D8AMLO-04-0362-0700445 ENTROPY ENVIRONMENTALISTS NC
D8AHLO-04-0361 -0100446 RESEARCH & EVALUATION NC
D8DHLO-04-0360-0100447 ENTROPY ENVIRONMENTALISTS NC
D8DMLO-04-0359-0700448 ENTROPY ENVIRONMENTALISTS NC
D8DMLO-04-0358-0700449 ENTROPY ENVIRONMENTALISTS NC
D8DMLO-04-0357-0700450 ENTROPY ENVIRONMENTALISTS NC
D8AMLO-04-0376-0 100472 NSI TECHNOLOGY NC
D8AMLO-04-0389-0100493 E. H. PECHAN & ASSOCIATES NC
D8CMLO-04-0395-0700520 SYSTEMS RESEARCH & DEV . NC
D8AMLO-04-0407 -0100521 AMBAC INTERNATIONAL SC
H8AMLO-04-0234-0700278 RESEARCH TRIANGLE INSTITUTE NC
H8AHLO-04-0232-0100279 RESEARCH TRIANGLE INSTITUTE NC
H8AMLO-04-0230-0100280 RESEARCH TRIANGLE INSTITUTE NC
H8AMLO-04-0231-0100287 RESEARCH Tfl /ANGLE INSTITUTE NC
H8AMLO-04-0367-0700468 RESEARCH TRIANGLE INSTITUTE NC
TOTAL OF REGION 04 « 22
D8DMLO-05-0230-OJ00255 LIFE SYSTEMS INC fY 87 OH
D8DMLO-05-0229-0100260 LIFE SYSTEMS INC FY 86 OH
0SDMLO-05-0227-0700267 LIFE SYSTEMS /NC FY 89 OH
D3DMLO-05-0228-OJ00263 LIFE SYSTEMS INC FY 88 OH
D8DMLO-05-0257-0100264 LIFE SYSTEMS INC FY 88 OH
08AMLO-05-0323-0100358 8MI COLUMBUS OH
D8AMNO-05-0377-0300072 PRC ENV/RONMENTAL MGT IL
D8AMNO-05-0376-03C0073 PRC ENV/fiONMENTAL MGT IL
D8AMNO-05-0412-030C078 8MI COLUMBUS OH
08EMNO-05-0413-0300079 ANIMAL NUTRITION INC IL
D8AUNO-OS-04 75-0300086 AN/MAL NUTRITION INC IL
P8AXW-05-0240-03C0062 OH MATERIALS (ARMY) OH
TOTAL OF REG/ON 05 - 72
D8CMLO-06-0759-0100253 RADIAN CORPORATION TX
08CSLO-06-0758-0 700254 SOUTHHEST RESEARCH INSTITUTED
D8AMLO-06-0765-07C0273 FTN ASSOCIATES, LTD. AR
D8AMLO-06-OJ84-0100320 RADIAN COfiPOfiATION TX
D8A5LO-06-0277-0100359 LOCXHEED ENGINEERING & SCI TX
08AMLO-06-0272-0700360 LOCKHEED ENGINEERING & SCI TX
D8AALO-06-0227 -0100451 RADIAN CORPORATION TX
08CMLO-06-0228-0700452 RAO (AN CORPORATION TX
D8CPLO-06-0229-0700453 RAO /AN CORPORATION TX
D8AALO-06-0245-0700466 EGSG AUTOMOTIVE RESEARCH /NSTX
D8AALO-06-0246-0 100467 RADIAN CORPORATION TX
D8CMLO-06-0251-OIC0509 SOUTHWEST RESEARCH /NST/TUTETX
TOTAL OF REGION 06 = 12
D8AHLO-07-0210-0100240 M/DIVEST RESEARCH INSTITUTE MO
DSDttLO-07-0233-0700367 BLACK & VEATCH MO
D8CMLO-07-0262-0700476 DEVELOPMENT PLANNING & RESE K.S
D8BHLO-07-0263-0100417 BLACK, & VEATCH INCORPORATED MO
Final Report Ineligible Unsupported Unnecessary/ Efficiencies
Issued Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
4/ 3/90
4/79/90
4/25/90
5/21/90
6/29/90
7/24/90
8/75/90
8/77/90
8/77/90
8/77/90
8/77/90
8/77/90
8/77/90
9/ 7/90
9/25/90
9/26/90
9/26/90
4/25/90
4/25/90
4/25/90
4/25/90
8/37/90

4/70/90
4/12/90
4/72/90
4/72/90
4/72/90
6/26/90
7/26/90
7/26/90
8/74/90
8/74/90
8/27/90
5/31/90

4/ 9/90
4/10/90
4/20/90
5/14/90
6/26/90
6/26/90
8/20/90
8/20/90
8/20/90
8/30/90
8/30/90
9/26/90

4/ 3/90
5/31/90
7/30/90
7/37/90
56

-------
Audit Control Audrtee
Number
D8DMLO-07-0270-0700429 FRANKLIN ASSOCIATES LIMITED KS
D8CMLO-07-0269-0700430 DEVELOPMENT PLANNING 8 RESOUKS
D8DMLO-07-0271 -0700437 FRANKLIN ASSOCIATES LIMITED KS
D8EMLO-07-0272-0700438 FRANKLIN ASSOCIATES LTD. KS
D8AALO-07-0274-0 100455 MIDWEST RESEARCH INSTITUTE HO
D8APLO-07-0286-0700465 MIDhfEST RESEARCH INSTITUTE MO
D8AALO-07-0290-0100488 MIDWEST RESEARCH INSTITUTE MO
D8ABLO-07-0291-0700505 MIDWEST RESEARCH INSTITUTE MO
D8ABLO-07-0293-0700526 MIDWEST RESEARCH INSTITUTE MO
D8AMLO-07-0238-0 100537 DEVELOPMENT PLANNING & RESC KS
D8DMLO-07-0235-0 700538 DEVELOPMENT PLANNING & RESC KS
D8DMLO-07-0234-0100539 DEVELOPMENT PLANNING & RESC KS
D8ASLO-07-0236-0700540 DEVELOPMENT PLANNING « RESCHKS
D8AMLO-07-0237-0 100541 KANSAS, UNIVERSITY OF KS
TOTAL OF REGION 07 = 18
D8APLO-08-0069-01 00262 WOODWARD-CLYDE CONSULTANTS CO
D8AMLO-08-0077-0100319 RCG/HAGLER, BAILLY, INC. CO
TOTAL OF REGION 08 = 2
D8APLO-09-0156-0100256 AQUA TERRA CONSULTANTS CA
D8CMLO-09-0157-0100257 SYSTEM APPLICATIONS, INC CA
D8CMLO-09-0158-0100258 SYSTEMS APPLICATIONS, INC CA
D8CMLO-09-OJ59-0100259 SYSTEMS APPLICATIONS, INC CA
D8AMLO-09-0760-0700269 ECO ANALYSIS, INC CA
D8AMLO-09-0761-0700270 TETftA TECH, INC CA
D8AMLO-09-0162-010027J TETRA TECH, INC CA
D8CMLO-09-OJ72-OI00282 SYSTEMS APPLICATIONS, INC. CA
D8CMLO-09-OJ73-0100283 SYSTEMS APPLICATIONS, INC CA
D8DMLO-09-0782-0100305 TRACOft MBA CA
D8CALO-09-OJ83-OI00306 SYSTEMS APPLICATIONS, INC CA
D8CMLO-09-0784-OI003I7 ENGINEERING SCIENCE, INC. CA
D8CALO-09-0786-0700373 ENERGY & RESEARCH CORP CA
D8CALO-09-0787-0700374 ENERGY & EHV RESEARCH CORP CA
D8CALO-09-OI88-0100315 SRI INTERNATIONAL CA
D8CALO-09-0785-OI00377 ENERGY & ENV RESEARCH CORP CA
D8AMLO-09-OJ90-07003I8 GEO/RESOURCE CONSULTANT INC.CA
D8CALO-09-0209-0 100344 ENERGY & ENV RESEARCH CORP CA
D8CALO-09-0208-0 700345 ENERGY & ENV. RESEARCH CORP CA
D8CALO-09-0272-0700346 ENERGY & ENV RESEARCH CORP CA
D8CALO-09-02 73-0 700347 ENERGY & ENV RESEARCH CORP CA
D8CALO-09-0274-0700348 ENERGY & ENV RESEARCH CORP CA
D8AVLO-09-02 75-0 700349 TETRA TECH CA
DSC ALO-09-02 78-0 700353 ENERGY & ENV RESEARCH CORP CA
D8CALO-09-0220-0700355 ENERGY & ENV RESEARCH CORP CA
D8AWLO-09-022J-0700356 ECO ANALYSIS, INC CA
D8AVLO-09-0231-0700390 ENGINEERING-SCIENCE INC CA
D8CALO-09-0206-OJ00409 ENERGY & ENV. RES. CORP CA
D8AALO-09-0222-0700472 GEO/RESOUftCE CONSULTANTS INCCA
D8CMLO-09-0245-0100413 S-CUBED, A OIV. OF MAXWELL CA
D8AALO-09-0252-0 700420 AEROCOMP, INC CA
D8CALO-09-0267-0700456 AEROCOMP, INC CA
D8AWLO-09-0269-0700460 JONES & STOKES ASSOC ., 1 NC CA
D8AALO-09-0270-OI00461 ACUfiEX CORP CA
D8AALO-09-0277-0700462 AEROCOMP INC CA
D8CALO-09-0272-0 700463 ENERGY & ENVIRON. RESEARCH CA
D8BVLO-09-0282-0700469 JRfi ASSOCIATES VA
Final Report Ineligible Unsupported Unnecessary/ Efficiencies
Issued Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
8/13/90
8/73/90
8/73/90
8/14/90
8/21/90
8/30/90
9/24/90
9/26/90
9/27/90
6/ 1/90
5/37/90
5/31/90
5/30/90
5/30/90

4/12/90
5/11/90

4/17/90
4/11/90
4/11/90
4/12/90
4/18/90
4/18/90
4/18/90
4/25/90
4/25/90
5/ J/90
5/ 1/90
5/ 8/90
5/ 9/90
5/ 9/90
5/ 9/90
5/ 9/90
5/77/90
6/12/90
6/13/90
6/15/90
6/15/90
6/15/90
6/75/90
6/22/90
6/22/90
6/22/90
7/ 9/90
6/ 8/90
6/27/90
7/20/90
8/ 3/90
8/22/90
8/28/90
8/28/90
8/28/90
8/28/90
8/37/90
57

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Audit Control
Number
D8APLO-09-0283-0700473
D8AMLO-09-0284-0100474
D8AHLO-09-0289-0100483
D8AWLO-09-0290-0700484
D8AALO-09-0302-0100522
D8BMLO-09-0304-0100527
D8SVLO-09-0305-0 700528
D8AMNO-09-01 50-0300042
D8AANO-09-01 89-0300050
D8AUNO-09-0227-0300071
D8AMNO-09-0264-0300083
D8BMNO-09-0230-0300101
TOTAL OF
D8AHLO-W-0062-0100265
D8AMLO- 70-0063-0700266
D8AHLO-10-OQ64-0100267
D8AUNO- 10-0061-0300044
08 AMNO-1 0-0091 -0300089
M8C«LO-70-0065-0700268
Auditee
ACUREX CORP.
ACURE X COUP
ACUREX CORP
ACUREX CORP
ENGINEERING SCIENCE, INC
THE RAND CORP
THE RAND CORP
AQUA TERRA CONSULTANTS
ERC ENVIRON. & ENERGY SVCS.
S-CUBED
S-CUBED
ROCWELL INTL CORP
REGION 09 ' 49
PTI ENVIRONMENTAL SVCS
PTI ENVIRONMENTAL SVCS
PTI ENVIRONMENTAL SVCS
PTI ENVIRONMENTAL SVCS
OMNI ENVIRONMENTAL SERVICES
COOPER CONSULT AM S, INC.

CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA

HA
HA
HA
HA
OR
Oft
	 	 " • - 	 1 1WW*****IVII«*W
Final Report Ineligible Unsupported Unnecessary/ Efficiencies
Issued Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)
9/ 7/90
9/ 7/90
9/78/90
9/78/90
9/26/90
9/27/90
9/27/90
4/17/90
5/ 9/90
7/ 5/90
8/75/90
7/ 9/90

4/72/90
4/72/90
4/72/90
4/72/90
9/74/90
4/78/90
              ror>«. OF REGION jo«    6

              TOTAL OTHER CONTRACT AUDITS             -  250

9. SUPERFUND CONTRACTS

D9AKLO-02-0306-0700427  ECOLOGf AND ENVIRONMENT     NY     8/ 9/90
              TOTAL OF REGION 02 »    7

P9AHNO-04-0326-0300093  FOUR SEASONS INDUSTRIAL  INC SC

              TOTAL OF REGION 04 •    7

P9AHNO-05-0260-0300047  OH MATERIALS (PR EQ RATES)  OH
P9AHNO-05-0365-0300084  OHV REMEDIATION             OH
              TOTAL OF REGION 05 •    2

 D9AKLO-06-0207-0700354  RADIAN CORPORATION
 D9AKLO-06-0222-0100426  RADIAN CORPORATION
TX
TX
               TOTAL OF REGION 06 *    2

 D9AK.LO-09-0223-0100362  JACOBS ENGINEERING GRP.,  INCCA

               TOTAL OF REGION 09 =    7

               TOTAL SUPERFUND CONTRACTS

               TOTAL AUDITS =   897
       9/20/90
       4/27/90
       8/16/90
6/22/90
8/ 7/90
       6/27/90
                      7,688,307
                              7,707,878
7,675
89,027,722
                                                                     9,040,132

                     49,477,050     33,735,943      22,240,737     722,395,439
 HDQ 771 - - REPORTS ISSUED BY TYPE AUDIT AND REGION
            SEMI-ANNUAL PERIOD ENDING  9/30/90
  58

-------
  HE INSPECTOR GENERAL ACT  REQUIRES A  SUMMARY OF EACH AUDIT  REPORT ISSUED BEFORE  THE  COMMENCEMENT OF THE
  EPORTING PERIOD FOR WHICH NO MANAGEMENT DECISION  HAS BEEN MADE BY THE END OF THE REPORTING PERIOD (INCLUDING THE
  VTE AND TITLE OF EACH SUCH REPORT), AN EXPLANATION OF THE REASONS SUCH MANAGEMENT DECISION HAS NOT BEEN MADE, AND
  STATEMENT CONCERNING  THE DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION ON EACH SUCH  REPORT.  (The IG
  ovides the summary, the date  and title of each such report.  The Agency provides the explanation of the reasons such management decision has
  it been made, and a statement concerning the desired timetable for achieving a management decision on each  such  report.)


   Followup Status Codes of Agency's Response at 9/30/90:

  No Response
  Incomplete Response Received
  Proposed Response Received Awaiting Final Determination
  Proposed Response Received in Review Process
  Final Response Received in Review Process
  In Pre-ARB Referral Process
  signment Control     Title
  mber
                           Final Report
                                 Issued
   SISTANT ADMINISTRATOR FOR WATER
  7F8-04-0331 -0100208
 REG 4 WATER DIV WETLAND BR GA
                                                         3/22/90
        ERA'S WETLAND POLICY CONFLICTS WITH COE, INEFFECTIVE USE OF AVAILABLE
   LAND REGULATORY STATUTES, INADEQUATE SECTION 404 JURISDICTIONS. AUTHORITY, AND
   ION 4'S INSUFFICIENT PROGRAM DEVELOPMENT AND RESOURCES SIGNIFICANTLY DECREASED
   EFFECTIVENESS OF EPA'S WETLAND PROTECTION.
  .PLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  BE: MANAGEMENT DECISION LETTER SENT TO OIG ON 7/13/90. OIG DISAGREED WITH
  KON AS WRITTEN AND ASKED FOR MORE SPECIFIC INFORMATION.  MANAGEMENT'S
  1SED RESPONSE WAS RECENTLY PREPARED AND IS BEING REVIEWED BEFORE RELEASE TO

  ESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
  WLUTION DATE IS 11/30/90.
  :OLLOWUP STATUS AT 9/30/90: [ 2 I
  WF9-05-0251-0100206
USER CHARGE SYSTEM
                                                 R5
                                                         3/28/90
  mmary: OUR REVIEW FOUND THAT EPA IS NOT ENSURING THAT $75 BILLION IN PUBLIC
  iSTMENT IN WWTPS IS BEING SAFEGUARDED FROM DETERIORATION, EPA IS NOT ENSURING
  VT GRANTEES GENERATE SUFFICIENT REVENUE THROUGH ADEQUATE USER CHARGE SYSTEMS
  PROPERLY OPERATE, MAINTAIN AND REPLACE WWTPS.
  (PLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  iDE: PREPARATION OF THE MANAGEMENT DECISION REQUIRED COORDINATION WITH
  3IONAL OFFICES TO GET THE MUNICIPAL PERSPECTIVE. THAT INFORMATION HAS BEEN
  LLECTED AND THE FINAL DETERMINATION LETTER (FDL) PREPARED.  THE MANAGEMENT
  :iSION IS BEING REVIEWED BEFORE RELEASE TO THE OG.
  ESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPECTED
  50LUTON IS 12/31/90
  FOLLOWUP STATUS AT 9/30/90: [ 1 ]

  SISTANT ADMINISTRATOR, OFFICE OF

  )SGO-05-6003-0400011    EXPORT OF HAZARDOUS WASTE FOLLOWUP    3/30/90

  immary: AGENCY IMPROVEMENTS RESULTS IN BETTER CONTROL OVER EXPORTS OF
  ZARDOUS WASTE.
  XPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
  \DE: THE RESPONSE REQUIRES THE COORDINATION OF THREE DIFFERENT PROGRAM OFFICES
  THE AGENCY.  THAT COORDINATION  IS BEING COMPLETED AND THE FINAL MANAGEMENT
  CISBN LETTER PREPARED.
 JESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
  SOLUTION DATE IS 11/30/90.
 FOLLOWUP STATUS AT 9/30/90' [ 1
 GAG9-05-6001-9400044
                         ASBESTOS NESHAPS ACP FOLLOWUP
                                                          9/28/89
 jmmary: ALTHOUGH PROGRESS HAS BEEN MADE, ALL OF THE CORRECTIVE ACTION THE
 SNCY PLANNED TO RESOLVE OUR 1988 REPORT RECOMMENDATIONS HAVE NOT BEEN
 XOMPLISHED
 iXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 ADE: RESPONSE REQUIRED COORDINATDN OF SEVERAL DIFFERENT PROGRAM OFFICES IN
 HE AGENCY  THAT COORDINATION WAS COMPLETED AND THE PROPOSED MANAGEMENT
 VISION
 ESPONSE WAS SIGNED AND SENT TO OIG ON APRIL 16, 1990. ON MAY 22, 1990, THE OIG
 EQUESTED ADDITIONAL INFORMATION BEFORE IT CAN AGREE ON RESOLUTION THE
 ESOLUTION IS EXPECTED BY DECEMBER 1, 1990
 DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

3 FOLLOWUP  STATUS AT 9/30/90: [2]
Assignment Control     Title
Number
Final Report
     Issued
                                             DIRECTOR, WATER DIVISION, REGION 4

                                             P2CWN9-04-0034-0300018      FLORENCE KY
                                                                                                                                  2/29/89
Summary: FLORENCE KY CLAIMED $915,509 OF INELIGIBLE OR UNSUPPORTED COSTS THIS
CONSISTED OF $181,649 OF INELIGIBLE ENGINEERING FEES & CONSTRUCTION  COSTS.IN
ADDITION, $733,860 OF UNSUPPORTED COSTS WERE QUESTIONED.
 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: MANAGEMENT DECIDED TO DELAY ISSUING THE FDL UNTIL A GENERAL AGREEMENT
COULD BE REACHED BETWEEN PROGRAM, OIG, AND GRANTS ADMINISTRATION UNIT AS TO
WHAT CONSTITUTES ACCEPTABLE ALTERNATIVE DOCUMENTATION.  ORIGINAl DOCUMENTS WERE
DESTROYED BY FIRE.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
RESOLUTION IS 12/31/90.

IG FOLLOWUP STATUS AT 9/30/90' [ 1 ]

PROCUREMENTS CONTRACTS MANAGEMENT DIVISION
Financial Analysis Section
                                             P9AHN9-05-0347-0300036    OH MATERIALS (PR EQ RATES)  OH
                                                           3/27/90
                                             Summary: WE HAVE RECOMMENDED REDUCTIONS OF $670,000 TO PROPOSED FIXED RATES FOR
                                             EQUIPMENT PRIMARILY BECAUSE OF ERRORS IN UTILIZATION METHODS, ADJUSTMENTS FOR FULLY
                                             DEPRECIATED EQUIPMENT AND UNSUPPORTED ESTIMATES AND ASSUMPTIONS BY THE CONTRACTOR
                                              EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                             CONTRACT HAS NOT BEEN AWARDED YET. NEGOTIATIONS ARE STILL PENDING.
                                             =DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                             IG FOLLOWUP STATUS AT 9/30/90. [ 1  ]

                                             PROCUREMENT CONTRACTS MANAGEMENT DIVISION
                                             Washington Cost Advisory Branch
                                             P9AHN9-05-0460-0300007   OH MATERIALS (ZONE 4A)
                                             OH
                                                           10/31/89
                                             Summary: WE RECOMMENDED REDUCTIONS OF $781,847 TO THE PROPOSED COSTS FOR
                                             RELOCATION INCENTIVES, DIRECT CHARGE OF ANTICIPATED BONUS AND IMPROPERLY CALCULATED
                                             BASE WORK YEAR.
                                              EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                             CONTRACT HAS NOT BEEN AWARDED YET. NEGOTIATIONS ARE STILL PENDING.
                                             =DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                             IG FOLLOWUP STATUS AT 9/30/90: [ 1 ]

                                             P9AHN9-10-0167-0300023   RIEDEL ENVIRONMENTAL SERV OR
                                                                                                                                   2/ 1/90
                                             'Summary:
                                             -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                             CONTRACT HAS NOT BEEN AWARDED YET. NEGOTIATIONS ARE STILL PENDING.
                                             -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:

                                             IG FOLLOWUP STATUS AT 9/30/90: [ 1  ]

                                             GRANTS ADMINISTRATION DIVISION

                                             M3BBLO-04-0197-0100211   INSTITUTE FOR TECH DEVELOP  MS             3/23/90
                                             'Summary:
                                             -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                             DEPARTMENT OF COMMERCE DID THE INITIAL AUDIT THE AGENCY REQUESTED A FULL AUDIT BY EPA'S
                                             OIG  THE OIG HAS DECIDED NOT TO DO A FULL AUDIT.  THE AUDIT
                                             WILL BE RESOLVED BASED ON THE COMMERCE FINDINGS.
                                             =DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
                                             RESOLUTIONS 12/15/90.
                                                                       IG FOLLOWUP STATUS AT 9/30/90' I 1
                                                                                                                                         59

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Assignment Control
Number
                           Title
                                                         Final Report
                                                               Issued
                                                OH
                                                               10/16/89
G3HMJ9-05-0498-0500043    NEW LONDON LSD FY 88
•Summary:
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: THE
FINAL DETERMINATION LETTER WAS SENT TO THE GRANTEE AND THE DIG. [Action Official faxed tfie Final
Determination Letter to the DIG on 10/2/90.]
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: DIG CLOSED THIS
AUDIT ON 10/3/90.
IG FOLLOWUP STATUS AT 9/30/90: [ 5 ]

                        SW MERCER LSD FY 88
                                                OH
                                                               10/16/89
G3HMJ9-05-0493-0500045
•Summary:
•EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: THE
FINAL DETERMINATION LETTER WAS SENT TO THE GRANTEE AND THE DIG. [AcSon Official faxed the Final
Determination Letter to (he DIG on 10/2/90.]
=DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: OIQ CLOSED THIS
AUDfT ON 10/3/90.
IG FOLLOWUP STATUS AT 9/30/90: [ 5 ]

G3HMJO-05-0070-0500169    GIBSONBURG VSD FY 88
                                                OH
                                                               11/3/89
'Summary:
•EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: THE
FINAL DETERMINATION LETTER WAS SENT TO THE GRANTEE AND THE DIG [Action Official faxed the Final
Determination Letter to the DIG on 10/2/90.]
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: OIG CLOSED THIS
AUDfT ON 10/3/90.
IG FOLLOWUP STATUS AT 9/30/90: [ 5 ]

C3HMJO-05-0078-0500194        ADA EXEMPTED VSD FY 88  OH
                                                               11/9/89
'Summary:
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE FINAL DETERMINATION LETTER WAS PREPARED 2/14/90 AND SENT TO THE
GRANTEE AND OIG ON THAT DATE. (Action official faxed the Final Determination Letter to the OIG on
10/30/90.)
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: OIG SHOULD
CLOSE THIS AUDIT SHORTLY.

IG FOLLOWUP STATUS AT 9/30/90: [ 1  ]

G3HMJO-05-0063-0500196        NELSONVILLE-YORK CSO FY 88  OH          11/9/89

'Summary:
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE FINAL DETERMINATION LETTER WAS SENT TO THE GRANTEE AND OIG.  [Action
Official faxed the Final Determination Letter to the OIG on 10/2/90.]
=DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: OIG SHOULD
CLOSE
THIS AUDIT SHORTLY. [IG closed this audit on 10/3/90.)
IG FOLLOWUP STATUS AT 9/30/90: [ 5 ]

G3HMJO-05-0066-0500198        NORTHERN LSD FY 88
                                                       OH
                                                               11/9/89
'Summary:
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE FINAL DETERMINATION LETTER WAS SENT TO THE GRANTEE AND THE OIG.
[Action Official faxed the Final Determination Letter to the OIG on 10/2/90.]
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: OIG CLOSED
THE AUDIT ON 10/3/90.

IG FOLLOWUP STATUS AT 9/30/90: [ 5 ]

REGION 5 GRANTS FINANCIAL MANAGEMENT

P2CWN6-05-0044-0300006        WHITING                  IN          10/30/89

Summary: WE QUESTIONED INELIGIBLE CONSTRUCTION AND ENGINEERING COSTS OF
$136,803.  IN ADDITION, WE QUESTIONED UNSUPPORTED ADMINISTRATIVE  «
EXPENSES OF $16,500.
 EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE OIG ACCEPTED MANAGEMENT'S DECISION AND CLOSED THIS AUDIT 10/3/90.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: IG FOLLOWUP
STATUS AT 9/30/90: [ 3 ]
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  FDL SHOULD BE
RELEASED BY 1/18/91.

IG FOLLOWUB STATUS AT 9/30/90: [ 2 ]
Assignment Control      Title
Number
Final Ri
      Is
                                                                               N3HMKO-05-0143-0500671
                                                                                                          WAYNE CO FY 88
                                                                                                                           Ml
                                                                               'Summary:
                                                                               -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BE
                                                                               MADE:  GRANTEE WAS ASKED BY AGENCY TO PROVIDE ADDITIONAL INFORMATION ABC
                                                                               POSSIBLE EARNED INTEREST ON GRANT MONEY.  MANAGEMENT DECISION LETTER WAS
                                                                               TO OIG ON
                                                                               9/22/90. OIG IS REVIEWING THE DECISION TO DETERMINE IF THEY WILL CLOSE THE AUI
                                                                               =DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPH
                                                                               DECISION BY THE OIG IN OCT. 1990.
                                                                               IG FOLLOWUP STATUS AT 9/30/90: [  1 ]

                                                                               P2CWN4-05-0183-5100159        EUCLID  OH
                                                                                                                                               7
                                                                               Summary: WE QUESTIONED THE ENTIRE GRANT AWARD OF ALMOST $14.3 MILLION  T>
                                                                               GRANTEE FAILED TO MEET GRANT CONDITION NO. 3 AND OPERATE THE PLANT SUFFICE
                                                                               MEET IT NPDES PERMfT.
                                                                               -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEI
                                                                               MADE: THE GRANTEE IS IN LITIGATION WITH THEIR CONTRACTOR OVER INCURRED COS
                                                                               AGENCY MUST AWAIT THE OUTCOME OF THAT LEGAL PROCESS BEFORE COMPLETING Tl
                                                                               MANAGEMENT DECISION.
                                                                               -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: IG FOI
                                                                               STATUS AT 9/30/90: [ 3 ]
                                                                               P3DWL1-05-0360-5100559   PRC ENG CT FY 80/81
                                                                                                                              IL
                                                                               Summary: WE RECOMMENDED OVERHEAD RATES OF 145.36 PERCENT AND 131.73 PE
                                                                               FOR FISCAL YEARS 1981 AND 1980, RESPECTIVELY.
                                                                               -EXPLANATION OF THE REAS NS MANAF DECISION HAS NOT BEEN MAD
                                                                               INITIALLY PREPARED FDL DISALLOWING $686,156 OF LEGAL AND SETTLEMENT COSTS.OI
                                                                               AGREED. SUBSEQUENTLY, OIG REVERSED ITS POSITION AND REINSTATED THESE COSTS.
                                                                               REGION DISAGREED AND REFERRED THE AUDIT TO OFFICE OF REGIONAL COUNSEL.
                                                                               P2CWN4-05-0357-6100389    DETROIT WSD
                                                                                                                             Ml
                                                                                                                                               a
                                                                               Summary: THE CITY OF DETROIT, Ml CLAIMED OVER $169,000 OF UNREASONABLE ENGII
                                                                               COSTS.
                                                                               •EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
                                                                               RESOLUTION OF THIS AUDIT REQUIRED THE AGENCY TO DEVELOP GUIDANCE ON DETERMIN
                                                                               ALLOWABLY OF COSTS INCURRED AFTER THE CONTRACT COMPLETION DATE SPECIFIED IN A
                                                                               THIS GUIDANCE WAS ISSUED ON 10/1/90,
                                                                               -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLI
                                                                               EXPECTED BY 1/1/91.
                                                                               IG FOLLOWUP STATUS AT 9/30/90: [ 2 ]

                                                                               P2GWN4-05-0264-6100390    DETROIT WSD
                                                                                                                             Ml
                                                                                                                                               8/1
                                                                               Summary: WE QUESTIONED INELIGIBLE FORCE ACCOUNT COSTS OF $20,872 INCURRE) PRIOR
                                                                               GRANT AWARD. IN ADDITION, UNSUPPORTED FORCE ACCOUNT COSTS OF $36,370 INCURRE1
                                                                               THE APPROVED CONSTRUCTION COMPLETION DATE WERE QUESTIONED.
                                                                               •EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MA
                                                                               RESOLUTION OF THIS AUDIT REQUIRED THE AGENCY TO DEVELOP GUIDANCE ON DETERMIN
                                                                               ALLOWABILfTY OF COSTS INCURRED AFTER THE CONTRACT COMPLETION DATE SPECIFIED IN AI
                                                                               THIS GUIDANCE WAS ISSUED ON 10/1/90.
                                                                               -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLL
                                                                               EXPECTED BY 1/1/91.
                                                                               IG FOLLOWUP STATUS AT 9/30/90. [ 2 ]

                                                                               P2CWN4-05-0263-6100391    DETROIT WSD
                                                                                                                             Ml
                                                                                                                                               8/1
                                                                               Summary: THE GRANTEE CLAIMED UNREASONABLE FORCE ACCOUNT COSTS OF $286,00
                                                                               GRANTEE ALSO CLAIMED INELIGIBLE COSTS OF $15,000.
                                                                               -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN I
                                                                               SOLUTION OF THIS AUDIT REQUIRED THE AGENCY TO DEVELOP GUIDANCE ON DETERMINE
                                                                               ALLOWABILITY OF COSTS INCURRED AFTER THE CONTRACT COMPLETION DATE SPECIFIED IN A (
                                                                               THIS GUIDANCE WAS ISSUED ON 10/1/90.
                                                                               -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLU
                                                                               EXPECTED BY 1/1/91.
                                                                               IG FOLLOWUP STATUS AT 9/30/90: [ 1 )

                                                                               P2CWN4-05-0280-6100574    DETROIT WSO
                                                                                                                             Ml
                                                                                                                                              9/3
                                                                               Summary: WE QUESTIONED INELIGIBLE COST OF $293,000 MOSTLY FOR CHANGE ORDERS W
                                                                               QUESTDNED UNNECESSARY COST OF $399,000 FOR FORCE ACCOUNT AND GRANTEE DEI
                                                                               CHANGE ORDER COSTS OF $148,00 WERE UNSUPPORTED.
                                                                               -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MAC
                                                                               RESOLUTION OF THIS AUDIT REQUIRED THE AGENCY TO DEVELOP GUIDANCE ON DETERMINE
                                                                               ALLOWABILITY OF COSTS INCURRED AFTER THE CONTRACT COMPLETION DATE SPECIFIED IN A G
                                                                               THIS GUIDANCE WAS ISSUED ON 10/1/90.
                                                                               -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLU
                                                                               EXPECTED BY 1/1/91.

                                                                               IG FOLLOWUP STATUS AT 9/30/90: [ 2 ]
 60

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 isignment Control     THIe
 imber
                              Final Report
                                    Issued
3WN4-05-0265-6100575    DETROIT WSD
                   Wl
                                                               9/30/86
mmary: THE GRANTEE CLAIMED INELIGIBLE AND UNSUPPORTED CONSTRUCTION COSTS OF
)9,000.  THE GRANTEE ALSO CLAIMED UNREASONABLE ENGINEERING
=TS OF $374,000.
PLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: THE
OLUTON OF THIS AUDIT REQUIRED THE AGENCY TO DEVELOP GUIDANCE ON DETERMINING THE
OWABILITY OF COSTS INCURRED AFTER THE CONTRACT COMPLETION
 E SPECIFIED IN A GRANT.  THIS GUIDANCE WAS ISSUED ON 10/1/90.
•SIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION IS
ECTEDBY 1/1/91.
 DLLOWUP STATUS AT 9/30/90: [ 2}
 JVN5-05-0242-7000034
DETROIT WSD  Ml
10/6/86
 «mary: WE QUESTIONED INELIGIBLE CONSTRUCTION AND ENGINEERING COSTS OF $20,006
 XHTION, WE QUESTIONED UNSUPPORTED ENGINEERING COSTS
 40,495 INCURRED AFTER THE APPROVED CONSTRUCTION COMPLETDN DATE.
 'LANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 )E: THE RESOLUTION OF THIS AUDIT REQUIRED THE AGENCY TO DEVELOP GUIDANCE ON
 ;RMINING THE ALLOWABILITY OF COSTS INCURRED AFTER THE CONTRACT COMPLETION
 E SPECIFIED IN A GRANT. THIS GUIDANCE WAS ISSUED ON 10/1/90.
 SIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  RESOLUTION
 (PECTED BY 1/1/91.
 DLLOWUP STATUS AT 9/30/90: [ 2 ]
 WN5-05-0246-7000044
DETROIT WSD
                                                              10/ 7/86
 imary: THE GRANTEE CLAIMED UNREASONABLE FORCE ACCOUNT COSTS OF $336,000.
 'LANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 )E: THE RESOLUTION OF THIS AUDIT REQUIRED THE AGENCY TO DEVELOP GUIDANCE ON
 IRMINING THE ALLOWABILITY OF COSTS INCURRED AFTER THE CONTRACT COMPLETION
 ': SPECIFIED IN A GRANT. THIS  GUIDANCE WAS ISSUED ON  10/1/90.
 :SIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  RESOLUTION
 (PECTED BY 1/1/91.
 DLLOWUP STATUS AT 9/30/90: [ 2 ]

 A/N5-05-0275-7000045   DETROIT WSD
                                    10/ 7/86
 imary: WE QUESTIONED $00,000 OF INELIGIBLE ENGINEERING AND CONSTRUCTION
 NEERING COSTS OF $112,000 INCURRED AFTER THE APPROVED CONSTRUCTION
 PLETION DATE WERE NOT SUPPORTED.
 'LANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 )E: THE RESOLUTION OF THIS AUDIT REQUIRED THE AGENCY TO DEVELOP GUIDANCE ON
 ERMINING THE ALLOWABILITY OF COSTS INCURRED AFTER THE CONTRACT COMPLETION
 E SPECIFIED IN A GRANT.  THIS GUIDANCE WAS ISSUED ON 10/1/90.
 iSIRED TIMETABLE FOR ACHIEVING  A MANAGEMENT DECISION: RESOLUTION
 
-------
Assignment Control      Title
Number
            Final Report
                  Issued
P2CW6-03-0237-0100237    HAMPTON ROADS SANITATION   VA
                                                                3/30/90
Summary: RECOMMENDED COST RECOVERY INCLUDES INELIGIBLE ($156,009) AE FEES AND
UNSUPPORTED ($244,350) GRANT RELATED INCOME.
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: DUE TO THE SIGNIFICANT DOLLAR AMOUNTS (OVER $109 MILLION CLAIMED) AND
COMPLEX ISSUES, THE PROGRAM REQUIRED ADDITIONAL TIME TO CONDUCT THE REVIEW AND
SUBMIT THEIR RECOMMENDATIONS TO THE AUDIT MANAGEMENT SECTION.  THE GRANTEE'S
RESPONSE WAS  EXTREMELY DETAILED.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A FINAL
DETERMINATION LETTER WAS SUBMITTED TO 06 ON 9/28/90.
IG FOLLOWUP STATUS AT 9/30/90' [ 4 ]

P2CW7-03-0210-0100238    HAMPTON RDS SANITATION
   VA
                                                                3/30/90
Summary: RECOMMENDED COST RECOVERY INCLUDES $3.7 MILLION OF INELIGIBLE
ENGINEERING AND CONSTRUCTION COSTS AND $2 MILLION OF UNSUPPORTED LAND COSTS.
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: DUE TO THE SIGNIFICANT DOLLAR AMOUNTS (OVER $109 MILLION CLAIMED) AND
COMPLEX ISSUES, THE PROGRAM REQUIRED AQOmONAL TIME TO CONDUCT THE REVIEW AND
SUBMIT COMMENTS TO THE AUDIT MANAGEMENT SECTION.  THE GRANTEE'S RESPONSE WAS
EXTREMELY DETAILED,
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  A FINAL
DETERMINATION LETTER WAS SUBMITTED TO THE DIG ON 9/28/90

IG FOLLOWUP STATUS AT 9/30/90: [ 4 1
REGIONAL ADMINISTRATOR, REGION 2

P2CW8-02-0033-0100119    NASSAU CO             NY
                   1/23/90
Summary: THE COUNTY OF NASSAU, NEW YORK CLAIMS $11,172,040 IN UNALLOWABLE
PROJECT COSTS IN THE CONSTRUCTION OF LATERAL AND TRUNK SEWERS  UNDER GRANT
C360982-05.
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION IS THE
DELEGATED AUTHORITY RESPONSIBLE FOR THE AUDIT'S RESOLUTION.  DUE TO A LARGE
NUMBER OF AUDITS REQUIRING RESOLUTION AND A LACK OF STAFF AT NYSDEC, THE AUDIT
COULD NOT BE RESOLVED BY 9/30/90.
-DESIRED TIMETABLE  FOR ACHIEVING A MANAGEMENT DECISION:  EXPECTED
RESOLUTION IS 1ST QUARTER OF FY91.
IG FOLLOWUP STATUS AT 9/30/90: [ 1 ]

P2CW7-02-0220-0100122    CASTILE
NY
                    1/25/90
Summary: THE TOWN OF CASTILE, NY CLAIMED $185,214 FOR INELIGIBLE COSTS OF $21,321
ASSOCIATED WITH CONSTRUCTION OF A PUMP STATION, LIFT STATIONS,  COLLECTION SEWERS,
A FORCE MAIN, INTERCEPTORS AND SEWAGE TREATMENT PLANT MODIFICATIONS
-EXPLANATION OF THE  REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION IS THE
DELEGATED AUTHORITY RESPONSIBLE  FOR THE AUDIT'S RESOLUTION  DUE TO A LARGE
NUMBER OF
AUDITS REQUIRING RESOLUTION AND A LACK OF STAFF AT NYSDEC, THE AUDIT COULD NOT
BE RESOLVED BY 9/30/90
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPECTED
RESOLUTION IS 1ST QUARTER OF FY91.
IG FOLLOWUP STATUS AT 9/30/90: [ 1 ]
P2CW8-02-0176-0100124    OSWEGO
                                              NY
                                                                1/25/90
Summary: THE GRANTEE CLAIMED UNALLOWABLE COSTS OF $371,943
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: FINAL
MANAGEMENT DECISION LETTER WAS SENT TO DIG ON 9/24/90.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  DIG HAS
ACCEPTED
THE MANAGEMENT DECISION AND WILL CLOSE THE AUDIT SHORTLY.
IG FOLLOWUP STATUS AT 9/30/90' [ 1 ]

P2CW8-02-0027-0100125   AUBURN
 NY
                    1/25/90
 Summary: THE CITY OF AUBURN, NY CLAIMED $1,900,049 FOR INELIGIBLE COSTS OF $1,302,680
 AND UNSUPPORTED COSTS OF $597,369 ASSOCIATED WFTH THE  PREPARATION OF PLANS AND
 SPECIFICATIONS AND CONSTRUCTION OF NEW SANITARY SEWERS AND PHOSPHOROUS REMOVAL
 FACILITIES.
 -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
 THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION IS THE DELEGATED
 AUTHORITY  RESPONSIBLE FOR THE AUDIT'S RESOLUTION. DUE TO A LARGE NUMBER OF AUDITS
 REQUIRING RESOLUTION AND A LACK OF STAFF AT NYSDEC, THE AUDtt COULD NOT BE RESOLVED BY
 9/30/90.
 -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPECTED
 RESOLUTION IS 1ST QUARTER OF FY91.

 IG FOLLOWUP  STATUS AT 9/30/90: (1 ]
Assignment Control     Title
Number
Final R<
      Is
                                 P2CW8-02-0028-0100129    NYC - SPRING CREEK
                                                                                                                             NY
                                                                                                                                               1
                                 Summary: THE GRANTEE CLAIMED TOTAL UNALLOWABLE COSTS OF $2,944,029 FOR THE
                                 AND CONSTRUCTION OF A RETENTION BASIN.
                                 -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN M/
                                 NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION IS THE DELEGATED AU
                                 RESPONSIBLE FOR THE AUDIT'S RESOLUTION. DUE TO A LARGE NUMBER  OF AUDITS RE
                                 RESOLUTION AND A LACK OF STAFF AT NYSDEC, THE AUDIT COULD NOT BE RESOLVED BY!
                                 -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPB
                                 RESOLUTION IS 1ST QUARTER OF FY91.
                                 IG FOLLOWUP STATUS AT 9/30/90' [ 1 ]

                                 P2CW7-02-0228-0100139   WESTCHESTER CO
                                                NY
                                                                 2
                                 Summary: THE GRANTEE CLAIMED TOTAL UNALLOWABLE COSTS OF $6,404,317 TO UPC
                                 WASTEWATER TREATMENT PLANT.
                                 -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN I
                                 THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION IS THE DELEG/>
                                 AUTHORITY RESPONSIBLE FOR THE AUDIT'S RESOLUTION.  DUE TO A LARGE NUMBER OF
                                 REQUIRING RESOLUTION AND A LACK OF STAFF AT NYSDEC, THE AUDIT COULD NOT BE RESOI
                                 9/30/90.
                                 -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPB
                                 RESOLUTION IS 1ST QUARTER OF FY91.
                                 IG FOLLOWUP STATUS AT 9/30/90: [ 1 ]

                                 P2CWL9-02-0049-0100229   NASSAU COUNTY
                                                                                                                              NY
Summary: THE GRANTEE CLAIMED TOTAL UNALLOWABLE COSTS OF $138,923 FOR THI
CONSTRUCTION OF VARIOUS SOLIDS HANDLING MODIFICATIONS TO A TREATMENT PLANT AND i
SLUDGE DEWATERING FACILITY.
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN H
THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION IS THE DELEGA
AUTHORITY RESPONSIBLE FOR THE AUDIT'S RESOLUTION.  DUE TO A LARGE NUMBER OF
REQUIRING RESOLUTION AND A LACK OF STAFF AT NYSDEC, THE AUDIT COULD NOT BE RESOI
9/30/90
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPEC
RESOLUTION IS 1ST QUARTER OF FY91.
                                 IG FOLLOWUP STATUS AT 9/30/90: [  1 ]

                                 P2CWL9-02-0208-0100233    AMHERST
                                                                                                                            NY
                                                                                                                                               3/
Summary. THE GRANTEE CLAIMED UNALLOWABLE COSTS OF $1,294,339 FOR CONSTRUCTION
YOUNGS ROAD INTERCEPTOR AND COLLECTION SEWERS FOR SOUTHEAST AMHERST.
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN M
THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION IS THE DELEGA1
AUTHORITY RESPONSIBLE FOR THE AUDIT'S RESOLUTION. DUE TO A LARGE NUMBER OF ,
REQUIRING RESOLUTION AND A LACK OF STAFF AT NYSDEC, THE AUDIT COULD NOT BE RESOL
9/30/90.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPEC
RESOLUTION IS 1ST QUARTER OF FY91.
                                 IG FOLLOWUP STATUS AT 9/30/90: [ 1 ]

                                 P5BGL9-02-0366-0100245   NYS MULTI-SITE
                                                                               NY
                                  Summary: THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION CU
                                  UNALLOWABLE COSTS OF $293,032 COMPRISED OF INELIGIBLE COSTS   OF $71,897 M
                                  UNSUPPORTED COSTS OF $221,135 ASSOCIATED WITH THE REMEDIAL
                                  INVESTIGATION/FEASIBILITY STUDY ON THREE HAZARDOUS WASTE SITES AT FULTON TERM
                                  CLOTHIER AND VOLNEY LANDFILL.
                                  -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEI
                                  MADE: THE AUDIT REPORTED THAT THE THRE SUPERFUND CLEAN-UP SITES HAD
                                  SIGNIFICANT BUDGET OVERRUNS, NO FORMAL SUBCONTRACTS, AND OTHER QUESTIONED
                                  COSTS. THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION RECEN"
                                  SUBMITTED DOCUMENTATION REQUESTING FORMAL BUDGET MODIFICATIONS AND EPA
                                  ACCEPTANCE OF THE FULLY EXECUTED SUBCONTRACTS.
                                  -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE AC
                                  EXPECTS TO ISSUE A FINAL  DETERMINATION BY  11/15/90.
                                  IG FOLLOWUP SFATUS AT 9/30/90: [ 1 ]

                                  G3HMKO-02-0145-0500441    HUDSON REG HEALTH COMM
                                                                                    NJ
                                                                                                  1/1
                                  *Summary:
                                  -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEI>
                                  MADE:  THE AUDIT QUESTDNED COSTS CHARGED SOLELY TO THE EPA GRANT WHEN, IN
                                  FACT, OTHER GRANTS BENEFITTED FROM THE DISBURSEMENT.  THE AGENCY HAS REQUES
                                  THAT THE AUDITOR DETERMINE WHAT PERCENTAGE OF THE COSTS SHOULD BE ALLOCATE
                                  THE EPA GRANT.
                                  -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE AG
                                  EXPECTS TO ISSUE A RESOLUTION LETTER BY 11/15/90.

                                  IG FOLLOWUP STATUS AT 9/30/90' [ 1 ]
62

-------
Assignment Control
Number
Title
Final Report
      Issued
C3HMKO-02-0165-0500589    EQB
                                              PR
                                                                 2/15/90
'Summary:
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE AUDIT QUESTIONED COSTS IN SEVERAL PROGRAM GRANTS.  EQB HAS
EXPERIENCED SIGNIFICANT FINANCE DEPARTMENT STAFF TURNOVER INCLUDING THE CHIEF OF
FINANCE OHE PRIMARY PERSON WORKING ON RESOLUTION).  EQB RECENTLY INFORMED THE
AGENCY THAT AN AUDIT RESPONSE WILL BE SUBMITTED SHORTLY.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  FINAL
RESOLUTION IS EXPECTED BY 11/30/90.
IG FOLLOWUP STATUS AT 9/30/90: [ 1 ]

G3HMKO-02-0169-0500601    LOVE CANAL AREA REVIT AGENCY NY
                                      2/22/90
'Summary:
•EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE:  THE GRANTEE HAS OVERSPENT IN SEVERAL BUDGET CATEGORIES, SIGNIFICANTLY
UNDERSPENT THE OVERALL GRANT AWARD, AND MAJOR GRANT ACTIVITY IS STILL TO BE
ACCOMPLISHED, THE GRANTEE HAS SUBMITTED A FORMAL REQUEST FOR GRANT EXTENSION.
THE AGENCY HAS REQUESTED ADDITIONAL INFORMATION FROM THE GRANTEE.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: A FINAL
DETERMINATION IS EXPECTED BY 11/30/90.
IG FOLLOWUP STATUS AT 9/30/90: [ 1 ]

E2CWL9-02-0063-9100508    NYSDEC 205 G
                     NY
                                      9/29/89
 Summary: NYSDEC'S ADMINISTRATION OF THE CONSTRUCTION MANAGEMENT ASSISTANCE
 PROGRAM (205 (G)) WAS NOT ADEQUATE TO ENSURE THE PROPER CONTROLLING AND
 REPORTING OF PROGRAM EXPENDITURES.
 •EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
 MADE: THE AUDIT  INCLUDED OVER $1 MILLION IN PERSONNEL SERVICE COSTS CLAIMED BY
 NEW YORK STATE.  THE STATE HAS SUBMITTED A PROPOSED APPROACH TO REVIEW AND
 ANALYZE APPROXIMATELY THREE YEARS OF TIME/EFFORT ACTIVITY. THIS PROPOSED APPROACH
 IS BEING REVIEWED  BY THE AGENCY AND THE AUDITORS.
 -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPECTED
 RESOLUTION IS 12/31/90.

 IG FOLLOWUP STATUS AT 9/30/90: [ 2 ]

 Regional Administrator, Region 9

 S2CW7-09-0015-0200001    SULTANA COMM SER DIST    CA             11/22/89

 Summary: INELIGIBLE COSTS WERE $22,753 AND UNREASONABLE COSTS WERE $808,753. THE
 UNREASONABLE COSTS WERE ASSOCIATED WITH THE PIPELINE CONSTRUCTION AS A RESULT OF THE
 EXISTENCE OF SAGS AND DEFLECTIONS IN THE COMPLETED PIPELINE WE HAVE ASKED FOR A REGIONAL
 TECHNICAL INSPECTION.
 -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: A
 FINAL DETERMINATDN LETTER WAS SENT TO THE DIG ON 5/18/90. OIG DISAGRED WITH THE
 RESPONSE TO ONE OF THE FINDINGS.  THE AUDIT RECOMMENDED THAT FLOW MEASUREMENTS BE
 REVIEWED BY THE STATE WATER RESOURCES
 CONTROL BOARD (SWRCB) TO DETERMINE IF FACILITIES ARE OPERATING AT A FLOW LEVEL OF 75
 PERCENT OR MORE.  SWRCB IMPLEMENTED MANDREL TESTING STUDIES
 TO ASSESS THE AUDFTS FINDINGS. TESTS WERE COMPLETED IN MIDSEPTEMBER AND SWRC IS
 REVIEWING THE RESULTS.
 -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPECTED
 RESOLUTION IS XT. 1990.
IG FOLLOWUP STATUS AT 9/30/90: [  1 ]

S5BG-8-09-0202-0300037    CA DEPT OF HEALTH
                                                CA
                                                                 3/30/90
Summary: COSTS OF $2,419,415 QUESTIONED AS INELIGIBLE AND $1,639,629 AS UNREASONABLE
INELIGIBLES RELATED TO FORCE ACCOUNT AND CONTRACT COSTS  UNREASONABLE RELATED TO
CONTRACT COSTS, GRANTEE'S FINANCIAL MANAGEMENT SYSTEM DETERMINED INADEQUATE. MOST
INELIGIBLE COST RESULT OF THIS.
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: DUE TO THE LARGE
NUMBER OF COMPLEX FINANCIAL ISSUES AND REVIEW TIME NEEDED TO ACCESS THE LARGE VOLUME
OF HISTORICAL RECORDS RELATED TO RESOLVING THE PROGRAMMATIC ISSUES, THE MANAGEMENT
DECISION LETTER HAS TAKEN OVER SIX MONTHS TO RESOLVE. A MANAGEMENT  DECISION WAS
PROVIDED TO THE DIG ON 9/26/90.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
RESOLUTION IS 10/31/90.

IG FOLLOWUP STATUS AT 9/30/90. [  4 J
Assignment Control     Title
Number
Final Report
      Issued
                                                     S2CW7-09-0116-0300038    SAN DIEGO, CITY OF
                                                                                                                              CA
                                                                                                                                                 3/30/90
                                                     Summary: COSTS OF $13,177,522 QUESTIONED AS INELIGIBLE AND $33,460,195 QUESTIONED AS
                                                     UNREASONABLE/UNNECESSARY. INELIGIBLE RELATED TO CONSTRUCTION CONTRACT AND CO COSTS,
                                                     A/E, AND F/A COSTS OTHER COST QUESTIONED RELATED TO GUF, EXCESSIVE AXE, AND ND SEWER USE
                                                     ORDINANCE APPROWED.
                                                     -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                                     THE AGENCY AND DIG HAD TO ADDRESS ISSUES CONCERNING THE COST EFFECTIVENESS OF THE GAS
                                                     UTILIZATION FACILITY. MANAGEMENT DECISION WAS PROVIDED TO THE OB ON 9/27/90.
                                                     -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: OIG WILL CLOSE THE
                                                     AUDIT SHORTLY.
                      IG FOLLOWUP STATUS AT 9/30/90' [ 5 ]

                      N3HMKO-09-0022-0500031    MARSHALL ISLANDS, REPUBLIC MH
                                                                                                                                                10/11/89
                                                     Summary: THE REPORT QUESTIONED COSTS OF $130,678: $128,000 FOR DESIGN SERVICES FOR
                                                     WHICH BID DOCUMENTATION COULD NOT BE LOCATED AND $10,678 IN PROGRAM EXPENDITURES
                                                     WHICH EXCEEDED AUTHORIZED AMOUNTS.
                                                     -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
                                                     THIS AUDIT COVERED TWO GRANTS - ONE CONSTRUCTION GRANT AND ONE PROGRAMMATIC GRANT.
                                                     THE AGENCY DID NOT RECEIVE AN ADEQUATE RESPONSE TO EXPLAIN THE QUESTIONED COSTS UNTIL
                                                     THE DEPARTMENT OF THE INTERIOR PROVIDED A COPY OF AN FY89 AUDIT WHICH INDICATED THAT ALL
                                                     QUESTIONED COSTS HAD BEEN RESOLVED.
                                                     -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
                                                     RESOLUTION IS 10/31/90.
                                                     IG FOLLOWUP STATUS AT 9/30/90' [ 1  ]

                                                     N3HMKO-09-0061-0500293    TRUST TERR OF THE PAC ISO   MP
                                                                                                                     12/12/89
                                                     'Summary:
                                                     -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: THE
                                                     TRUST TERRITORIES OF THE PACIFIC ISLANDS HAS YET TO RESPOND TO THE AGENCY'S INITIAL INQUIRY
                                                     REGARDING THE AUDIT'S QUESTIONED COSTS OF OVER $7,000. THE AGENCY IS WORKING WITH THE
                                                     OIG TO PREPARE A FINAL  DETERMINATION LETTER FOR THE GRANTEE.
                                                     -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
                                                     RESOLUTION IS 10/31/90.
                                                     IG FOLLOWUP STATUS AT 9/30/90' [ 1  ]

                                                     E2CW7-09-0091-8100958    MAUI   COUNTY  OF
                                                                                                    HI
                                                                                                                     9/29/88
                                                     Summary: FINAL AUDIT OF 3 CONSTRUCTION GRANTS AND AN INTERIM AUDIT OF 1 GRANT
                                                     FOR WASTEWATER TREATMENT SYSTEM FOUND INOPERABLE AND UNDER-UTILIZED FACILITIES
                                                     WITH TOTAL COSTS QUESTIONED OF $32,305,267 (F.S. $24,428,213). FACILITIES POORLY
                                                     MAINTAINED, ABANDONED, AND REDUNDANT.
                                                     -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
                                                     MADE:  ISSUES RELATING TO UNUSED CAPACITY AND MAINTENANCE OF FACILITIES WERE
                                                     DIFFICULT TO RESOLVE LOCALLY.  THE FINAL DETERMINATION LETTER WAS PROVIDED TO THE
                                                     OIG ON 9/27/90.
                                                     -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  OIG WILL
                                                     CLOSE THE AUDIT SHORTLY.
                                                     IG FOLLOWUP STATUS AT 9/30/90. [ 5 ]

                                                     S2CW7-09-0166-9300096    MORRO BAY/CAYUCOS WTF
                                                                                                      CA
                                                                                                                     9/18/89
                                                     Summary: FINAL AUDIT OF 3 CONSTRUCTION GRANTS FOR DESIGN AND UPGRADE OF
                                                     WASTEWATER TREATMENT PLANT FOUND TOTAL COSTS QUESTIONED OF $255,113 (FS
                                                     $191,337).  THE INELIGIBLE COSTS WERE PRIMARILY FOR CONSTRUCTION COSTS OUTSIDE THE
                                                     SCOPE OF THE CONTRACT.
                                                     -EXPLANATION OF THE REASONS MANAGEMENT  DECISION HAS NOT BEEN
                                                     MADE:  ISSUES CONCERNING POST AUDIT COSTS CLAIMED HAD TO BE RESOLVED BETWEEN
                                                     THE STATE WATER BOARD AND THE OIG. ALSO, THE GRANTEE'S APPEAL OF A PREVIOUS AUDIT
                                                     IMPACTED THE RESOLUTION OF THIS AUDIT THE FINAL DETERMINATDN LETTER WAS PROVIDED
                                                     TO THE OIG ON 9/27/90.
                                                     -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  THE OIG WILL
                                                     CLOSE THE AUDIT SHORTLY.
                                                    IG FOLLOWUP STATUS AT 9/30/90. [ 5 ]

                                                    E2AWP9-09-0065-9400025    HOMELAND EARLY WARNING    CA
                                                                                                                      3/31/89
                                                    Summary: SPECIAL REVIEW OF CONSTRUCTION GRANT OF WASTEWATER TREATMENT PLANT
                                                    FOUND $3,737,139 IN FED, SHARE COSTS QUESTIONED.  AN EARLY WARNING LETTER ADVISED
                                                    THAT COSTS FOR THE COLLECTION SYSTEM PORTION OF THE PROJECT DID NOT QUALIFY FOR
                                                    FUNDING BECAUSE OF THE "2/3 RULE".
                                                    -EXPLANATION OF THE REASONS  MANAGEMENT DECISION HAS NOT BEEN
                                                    MADE: THE OIG IS TRANSMITTING THIS AUDIT TO THE AUDIT RESOLUTION GROUP (ARG).
                                                    AFTER REVIEW, IF THE ARG CANNOT RESOLVE THE AUDIT, IT WILL BE NECESSARY TO PRESENT
                                                    IT TO THE AGENCY'S AUDIT RESOLUTION BOARD.  WHILE THIS IS OCCURRING, THE GRANTEE IS
                                                    WORKING TO RESOLVE THE ISSUE TO THE AUDITOR'S SATISFACTION.
                                                    -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                                                               IG FOLLOWUP STATUS AT 9/30/90: [ 2 ]

-------
Assignment Control     Title
Number
            Final Report
                 Issued
E2AWP9-09-0230-9400043    EARLY WARNING-MARINA CWD   CA
                   9/26/89
Summary: SPECIAL REVIEW OF GRANT TO BUY CAPACITY RIGHTS FROM REGIONAL
WASTEWATER TREATMENT PLANT RESULTED IN AN EARLY WARNING LETTER TO EPA
MANAGEMENT THAT THE AWARD VIOLATED 40 CFR3S 2250 AND THAT TOTAL COSTS
QUESTIONED OF $1,694,000 (F.S. $931,700) WOULD CAUSE "WINDFALL".
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: RESOLUTION OF THIS AUDIT IS BEING HELD IN ABEYANCE PENDING THE EXPECTED
ISSUANCE IN DEC. 90 OF AN AUDIT REPORT FOR THE MONTEREY REGIONAL POLLUTION
CONTROL AGENCY.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
RESOLUTION OF THIS AUDIT IS MARCH 1991.

IG FOLLOWUP STATUS AT 9/30/90: [ 5 )

REGIONAL ADMINISTRATOR, REGION 6

E2CWN9-06-0150-0300017   PASADENA              TX                12/26/89

Summary: THE CITY OF PASADENA, TX DID NOT MAINTAIN TWO CRYOGENIC OXYGEN
GENERATION UNITS IN A SERVICABLE CONDITION AS REQUIRED BY EPA REGULATIONS.  THE BID
PRICE FOR THE OXYGEN GENERATION FACILITIES IN THE AMOUNT OF $2,761,660 WAS
QUESTIONED IN OUR AUDIT REPORT.
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN
MADE: ORIGINAL MANAGEMENT DECISION MADE 1/16/90.  GRANTEE DISPUTED FINDINGS.
SECOND MANAGEMENT  DECISION MADE 6/13/90.  DIG DISAGREED WITH THAT DECISION AND
REQUESTED ADDITIONAL INFORMATION FROM THE GRANTEE.  MOST RECENT MANAGEMENT
DECISION WAS PREPARED ON 8/15/90 AND IS BEING REVIEWED BY THE OFFICE OF REGIONAL
COUNSEL.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: IG FOLLOWUP
STATUS AT 9/30/90: [ 3 ]
REGIONAL ADMINISTRATOR, REGION 8

P2CW8-08-0068-0100212   DELTA CITY OF
CO
                                                                 3/23/90
Summary: CITY OF DELTA CO DID NOT FULLY MEET THE OBJECTIVES OF AN EPA CONSTRUCTION
GRANT AWARDED TO THEM TO ALLEVIATE HEALTH HAZARDS CREATED BY FAILING SEPTIC TANKS IN
THE NORTH DELTA AREA
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: A
PROPOSED DECISION WAS SUBMITTED TO THE OIG ON 7/12/90.  THE DIG RESPONDED THAT THE
GRANT DID NOT MEET THE PRIMARY OBJECTIVE OF SERVICING NORTH DELTA THE AGENCY CONTENDS
THAT THE OBJECTIVES WERE MET.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: THE AUDIT WAS
REFERRED TO HQ IG ON 7/30/90.

IG FOLLOWUP STATUS AT 9/30/90: [ 6 ]
Assignment Control     Title
Number
Final Ref
      Isa
P5CG'8-08-0117-9100484    COLORADO DOH
                                                                                                                              CO
                                                                                                                                                9/2
                                 Summary: FINAL AUDIT OF COOPERATIVE AGREEMENT FOR EVALUATION AND REMEDIATION PL
                                 CLEAN YAK TUNNEL/CA GULCH SUPERFUND SITE FOUND TOTAL COSTS QUESTIONED OF $1,18!
                                 $967,468 WAS FOR UNSUPPORTED AND UNAUDITED SUBCONTRACTOR COSTS.
                                 -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MAI
                                 4/10/90, THE REGION SUBMITTED ITS FINAL DECISION TO THE DIG. THE OIG DID NOT CONCU
                                 RECOMMENDED REFERRAL TO THE AUDIT RESOLUTION BOARD. ON 7/13/90 HQ/OIG MET Wl"
                                 GRANTS ADMINISTRATION DIVISION (GAD) AND AGREED TO ALLOW THE COSTS IF GAD APPRC
                                 DEVIATION FROM PROCUREMENT REGULATIONS.  A REQUEST WAS SUBMITTED 9/25/90.
                                 -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPECT
                                 RESOLUTION IS DEC. 1990.
IG FOLLOWUP STATUS AT 9/30/90: [ 6 ]

REGIONAL ADMINISTRATOR, REGION 10

E2AWPO-10-0017-0400012   ELBE WATER DIST EARLY WARN  WA
                                                                                                  3/C
                                 Summary: THE ELBE WATER AND SEWER DIST PROPOSED TO CONSTRUCT A $2.2 MILL!
                                 MODIFICATION OR REPLACEMENT TO SERVE 39 HOUSES (ABOUT $60,000 PER HOUSE). HOWEVf
                                 PROJECT WAS NEITHER COST EFFECTIVE NOR DID IT QUALIFY AS A MODIFICATION OR REPLAC
                                 PROJECT.
                                 -EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MAC
                                 OIG HAS FOLLOWED-UP WITH REGIONAL MANAGEMENT ON A DISPOSITION OF THIS  AUDIT.
                                 TECHNICAL REVIEW WAS REQUESTED FROM THE PROGRAM TO DETERMINE IF THIS WAS A FAIL
                                 DESIGN.
                                 -DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION:  EXPEC
                                 RESOLUTION IS DEC. 1990
                                 IG FOLLOWUP STATUS AT 9/30/90: [ 1 ]

                                 E3BG'6-10-0066-8100761    MOSES LAKE IRR & REHAB DIST WA
                                                                                                                                                8/3
Summary: INTERIM AUDIT OF DEMONSTRATION GRANT TO RESTORE MOSES LAKE AND TO CC
NON-POINT POLLUTION SOURCES FOUND TOTAL COSTS QUESTIONED OF $2,439,103 (F.S. $1,20!
GRANTEE USED STANDARD METHOLOGY INSTEAD OF DEVELOPING NEW INNOVATIVE TECHf>
-EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN IV
PROGRAM OFFICIALS AND THE OIG COULD NOT RESOLVE THIS AUDIT. EPA'S AUDIT RESOLUTION
WAS ASKED TO INTERVENE TO RESOLVE THE  ISSUES.
-DESIRED TIMETABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLU
ANTICIPATE IN DEC. 1990

IG FOLLOWUP STATUS AT 9/30/90: [ 6 ]
TOTAL AUDITS ISSUED BEFORE REPORTING PERIOD FOR WHICH NO MANAGEMENT DECISION WAS MADE DURING THE REPORTING PERIOD'    64
 " =  Agency procedures do not require Ihe IG's approval on Agency's Management Decision on an audit (other than a preaward or an internal and management audit) with the Federal
share of questioned costs of less than $100,000. Therefore, we have not provided a summary of the audit

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Mailing Addresses and Telephone Numbers c  OIG HOTLINE (800) 424-4000 or (202) 382-4977
Headquarters Office of
Inspector General
401 M Street, S.W. (A109)
Washington, DC  20460
(FTS  or 202) 382-3137

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
JFK Federal Building OIG 521
Boston, MA 02203
Audit: (617) 535-3160 FTS 835-3160
lnvestigations:(617) 565-3928
FTS 565-3928

Chicago
Office of Inspector General
111 West Jackson Boulevard
6th Floor (5-OIG-TUB6)
Chicago, IL 60604
Audit: (FTS or 312) 353-2486
Investigations: (FTS or 312) 353-2507

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

Denver
Office of Inspector General
999 18th Street, Suite 500
Denver, CO 80205-2405
Audit: (303) 294-7520 FTS 330-7520
Investigations: (303) 293-1650
FTS 330-1650

Kansas City
Office of Inspector General
726 Minnesota Avenue
Kansas City, KS66101
Audit: (913) 551-7824 FTS 276-7824

New York
Office of Inspector General
90 Church Street, Room 802
New York, NY  10007
Audit:  (FTS or 212) 264-5730
Investigations: (FTS or 212) 264-0399
Philadelphia
Office of Inspector General
841 Chestnut Street
13th Floor
Philadelphia, PA  19107
Audit (FTS or 215) 597-0497
Investigations: (FTS or 215) 597-9421
Research Triangle Park, NC
Office of Inspector General
EPA Administration Building
Alexander Drive, Room 113
Research Triangle Park, NC 27711
Audit: (919) 541-1028 FTS 629-1028
Investigations: (919) 541-1027
FTS 629-1027

Sac
Offio •*'  «r
801 I
Sacramento, cA 95814
Audit: (916) 551-1076 FTS 460-1076

San Francisco
Office of Inspector General
2II Main Street (1-1)
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, WA 98101
Investigations: (206) 442-1273
FTS 399-1273

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