Office Of Inspector General Semiannual Report To The Congress, October 1, 1990 Through March 31, 1991


TD171
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             United States
             Environmental Protection
             Agency
             Office o< 'he
             Inspector General
             Washington DC 20460
May1Q91
Office of the Inspector General
Semiannual Report    350R91001
to the Congress
October 1,1990
Through March 31,1991
  5) Printed on Recycled Paper

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foreword
                                      In order ior the Environmental Protection Agency to be a potent
                                       force in shaping, promoting, and enforcing national and
                                       international environmental policies, its decisions must be
                                    credible and beyond reproach. The Office of Inspector General
                                    is working closely to identify and correct not only specific
                                    problems, but systemic weaknesses and vulnerabilities that could
                                    undermine that credibility.
                                      As the Agency?s program responsibilities change, the Office of
                                    Inspector General's focus and approach is similarly changing.  For
                                    example, as the Construction Grant Program is being turned over
                                    to the States, the Office of Inspector General is planning for this
                                    phase and beginning to redirect its resources to other high risk
                                    areas that cut across Agency programs.  These areas include
                                    financial and management integrity and scientific integrity.
                                      Much of EPA's work is performed by contractors.  Our audits
                                    and investigations have identified overcharging, poor performance
                                    and collusion to fix prices by contractors. We have also found that
                                    existing controls over contract processing and management do
                                    not adequately protect the Agency from the risk of loss or assure
                                    that the Agency is getting the most for its money. We will be
                                    focusing more of our resources on audits of individual contracts as
                                    well as on the Agency's contract management process.
                                      Scientific research and data are the bases for many of EPA's
                                    decisions. These decisions impact major industries and the
                                    national economy as well. However, we have found serious
                                    problems with the scientific methods used by some labs under
                                    contract to EPA.  This has led us to expand our work in this area.
                                      Because of our mutual interest in the success of the Agency's
                                    programs and the urgency for the  best possible results from its
                                    resources, Agency management is working closely with the Office
                                    of Inspector General to ensure the integrity and improvement of
                                    EPA's operations.
                                    John C. Martin
                                    Inspector General

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                                            it Reports
 2-  SV-!IOP -•• 4",':;-;«;";, uve Actions
 2"   ;-.j'"-marv 01 'f'estigative Activities
 3i   L--3' "net cr. of Selected Prosecutive Actions
 3;'r   Dascnpt.or of Selected Prosecutive and Administrative Actions
     Concerning EPA Employees
 32   Civ;i and Adnwstrative Actions To Recover EPA Funds

 33  Section 4—fraud Prevention and Resource Management Improvements
 33   Review of Proposed Legislation and Regulations
 34   Suspension and Debarment Activities
 35   O!G Management initiatives
 36   Employee and Public Awareness
 37   Personnel Security Program
 38   President's Council on Integrity and Efficiency
 38   Committee on Integrity and Management Improvement
 39   Hotline Activities
 39   Professional and Organizational Development

 40  Appendices
 40  Appendix 1—Audit Reports Issued
 53  Appendix 2—Audits Without Management Decision
Sun filtering through the
redwoods at Muir Woods
National Monument, California
(photo by George Grant,
National Park Servicel

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The natural beauty of the
American West at Provo Rive,'
Falls,  Utah
(photo courtesy Utah Travel
Council).

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            ,LI-"A Computer
           Could Save
 MMfions o? Dollars

 Pi A diu not adecuatelv
 forecast its, computer
 requirements or match its
 needs to available resources.
 in addition, the Agency was
 unnecessarily spending an
 estimated $5.3 million annually
 due to inefficient (1) computer
 operations and use, (2)
 software applications design,
 and (3)  data storage and
 retrieval (page 11).

 3. EPA  Did Not Aggressively
 Pursue Regulation Of
 Potentially Harmful Chemical
 Substances.

 EPA's Office of Toxic
 Substances had regulated few
 existing chemicals thought to
 pose a significant risk to
 humans (page-12).

 4, Stronger Enforcement and
 Oversight Needed to Protect
 the Public from Harmful
 Pesticides.

 Delegated States and EPA
 regions  frequently did not take
 timely and appropriate
 enforcement actions against
 violators of pesticide laws to
 protect the public and the
 environment from exposure to
 harmful  pesticides (page 13).

 5. Agency Computer Files
 Not Adequately Protected.

 EPA was not sufficiently
 protecting its information
 resources, exposing the
 Agency  to unnecessary risks of
 unauthorized or improper
access to its mainframe
computer (page 14)
                                          •M SS, > Mitlior. o?
                                          .3 Costs
  • t V." . :5'iey v^a>'> and
;  anitatiO", .Xsno;  Nevada.
c-ics:iis-,d ?t- ,-'21,p 2C :4 ineligible
('"g.ntjeri-ig, equipmeri!,
c:onst,-uc:icT., and
administrative costs. In
addition, $2.347,748 of
unnecessary costs were
questioned (page 16).

8. Chicago Claimed Over $5.1
Million of Questioned Costs.

The Metropolitan Water
Reclamation District of Greater
Chicago claimed $3,549,043 of
ineligible construction and
engineering costs.  An
additional $1,566,933 of
unsupported or unnecessary
costs were questioned (page
16).

9. Grantees for D.C. Project
Claim $2.9 Million of
Ineligible or Unsupported
Costs.

The Government of the District
of Columbia, the Washington
Suburban Sanitary
Commission, and the County of
Fairfax, Virginia, jointly claimed
$1,936,115 of ineligible
engineering and construction
costs for the District's Regional
Water Pollution Control Plant
project. An additional
$954,879 of unsupported costs
were questioned (page 17).

10. Over $2.2 Million of
Ineligible and Unsupported
Costs Claimed for York
County, Virginia, Project.

The County of York, Virginia,
claimed $1,109,034 of ineligible
construction, engineering,
inspection, and other costs. An
additional $1,136,703 of
unsupported costs were also
questioned (page 17).
12. EPA Overstated Remedial
Action Starts in its Report to
the Congress

Inadequate documentation and
insufficient controls resulted in
EPA incorrectly reporting to
Congress that it had met the
National Priorities List (NPL)
remedial action  starts
requirement of the Superfund
Amendments and
Reauthorization Act of 1986
(page 20).

13. increased Monitoring and
Enforcement Needed to
Prevent Superfund Cleanup
Delays in Regions 1 and 5.

Regions 1 and 5 unnecessarily
delayed Superfund cleanups by
not timely reviewing required
documents  submitted by
potentially responsible parties
(PRP), not assessing stipulated
penalties, and not enforcing
voluntary agreements with
PRPs. Also, Region 1 was not
properly monitoring contractors'
performance (page 20).

14. Single Audit Process
Needs Major improvements.

EPA did not ensure timely
completion and  receipt of
single audit reports as required
by OMB Circular A-128, nor did
it ensure that prescribed
corrective actions were taken
(page 21).

15. Electrical Code Violations
Question Safety at the
Environmental Research
Center.

While violations of the National
Electrical Code found at EPA's
Environmental Research
Center (ERG), Research
Triangle Park, North Carolina,
had been corrected, most  of
the electrical systems still had

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not been inspected by local
authorities, leaving the facility's
safety in question (page 22).

16. EPA Not Obtaining
Certifications That Funds
Were Not Improperly Used
for Lobbying.

EPA did not require all
recipients of Federal grants,
loans, and contracts to certify
that the proceeds would not be
used for lobbying to influence
executive and legislative
decisions in connection with
their award. As a result, EPA
had no assurance that some
recipients were not using
Federal funds for lobbying
(page 22).

17. Legality and
Environmental Benefit of
$8.1 Million Grant
Amendment Questioned.

Region 9's $8.1 million grant
amendment award to the
Monterey, California, Water
Pollution Control Agency may
have violated environmental
statutes, unnecessarily
increased EPA's and the
Department of Army's cost for
the project, and had no
apparent environmental  benefit
(page 23).

18. EPA Improperly Awarded
$5.5 Million Grant.

Region 9 improperly awarded a
$5.5 million grant to the
Gualala Community Services
District, California, to construct
a wastewater treatment facility
(page 23).

19. Philadelphia Claims $6
Million of Ineligible Costs.

The City of Philadelphia,
Pennsylvania, claimed $5.2
million of costs previously
recovered from customers and
an additional $784,000 which
should be reimbursed by the
U.S. Navy (page 24).
Section 2—
Audit Resolution

At the beginning of the
semiannual period, there were
289 audit reports for which no
management decision had
been made.  During the first
half of fiscal 1991, the Office of
Inspector General issued 748
new audit reports and closed
286. At the end of the
reporting period, 239 audit
reports remained in the Agency
followup system for which no
management decision had
been made.  Of the 239 audit
reports, 69 reports remained in
the Agency followup system for
which no management decision
was made within six months of
issuance (page 25).
  In two followup audits, the
Office of Inspector General
found that some problems
identified in previous audits
continued to exist (page 26).
However, we have nothing to
report this period with respect
to significant management
decisions with which we
disagree as required by the
1988 Inspector General Act
Amendments.
  For the 286 audits closed,
EPA management disallowed
$61.5 miltion of questioned
costs for recovery and agreed
with our recommendations that
$63.5 million be put to better
use. In addition, cost
recoveries in current and prior
periods included $6.6 million in
cash collections, and at least
$49.6 million in offsets against
biliings (page 25).
Section
Prosecutive
Actions
During this semiannual
reporting period, our
investigative efforts resulted in
16 convictions and 37
indictments.  Also, this
semiannual period our
investigative work resulted in
$3,648,156 in fines and
recoveries (page 29).
  A major investigative effort,
directed at the Superfund
Contract Laboratory Program,
is beginning to produce
significant results. Testing labs
in California, Connecticut and
Missouri were charged with or
found guilty of falsifying results,
and a California-based supplier
of testing containers used in
the labs is accused of falsely
claiming that they were
contaminant-free.  Also, a
contractor on a construction
project in American Samoa
was charged with forging
signatures on  acceptance
documents; two men in New
York City and  an Alabama man
were sentenced for their roles
in phony invoice schemes, and
18 individuals  were indicted in
an alleged telemarketing scam
in Dallas (page 30).
  Also, an EPA environmental
engineer perjured  herself in a
court case; an EPA employee
was convicted of forgery in an
attempt to inflate her paycheck
by $600; and an EPA
employee was found submitting
false travel voucher claims
(page 32).
  An electrical contractor
found guilty of bidrigging on
EPA-funded projects in
Georgia and Tennessee paid
the Government $2.9 million;
and a Connecticut testing
laboratory paid $650,000 in
fines and damages to  the U.S.
(page 32).
Section
Fraud Prevention and
Resource
Management

Review of Proposed
Legislation and Regulations

During this semiannual period,
we reviewed 44 legislative and
regulatory items.  The most
significant were a President's
Council on Integrity and
Efficiency report which
recommends changing the
reporting required by the 1988
Inspector General Act
amendments and the Office of
Management and Budget's
plans for implementing the
Chief Financial Officers Act of
1990 (page 33).
Suspension and Debarment
Activities

We completed 90 cases during
this reporting period, resulting
in 43 debarments, 22
settlement agreements, 25
suspensions, and 50 cases
closed after investigation.
There were 181  active cases at
the close of this  reporting
period (page 34).

OIG Management Initiatives

The OIG has launched two new
initiatives designed to promote
management and financial
improvements and integrity in
EPA's operations.  These are
major projects to expand the
contract audit program and
assistance to the Agency in
implementing the Chief
Financial Officers Act (page
35).

Personnel Security Program

During this reporting period, the
Personnel Security Staff
reviewed 350 investigations.
Among the actions taken,
based on these  reviews, were
the termination of a contractor
employee who falsified a
Standard Form 86,
Questionnaire for Sensitive
Positions; suspensions for 2
employees who  falsified the
Standard Form 171,
Application for Federal
Employment, one by not listing
a felony conviction, the other
for not listing terminations by
previous employers; a written
reprimand for an employee
who falsified the SF-171 by not
listing a conviction for credit
card fraud; and termination of
an employee for fraudulently
changing prescriptions (page
37).

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                                   Overview of  Significant Trends  In
                                   EPA  of Concern to the OIG
steel or chemicals, produces
billions of gallons of
wastewater daily.

• Nonpoint 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
sources of ocean pollution.
Sediments dredged from
industrialized urban harbors
are often highly contaminated
with heavy metals and toxic
synthetic or organic chemicals,
such as PCBs and petroleum
hydrocarbons.

• Wetlands. More than half of
the wetlands originally in the
contiguous United States have
been tost and others have been
degraded by pollution and
hydrotogical changes so that
they no bnger perform many of
their natural functions. To
achieve its no net bss goal,
EPA is increasing enforcement
of Federal restrictions on
activities which destroy or
degrade wetlands.
This section of our report
presents the Office of hspec;or
General's perspective on
significant vulnerabilities facing
EPA  These items serve to
highlight the crosscuttmg
problems the OIG believes mjs\
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
SCIENTIFIC DATA fNTEGRlTY

The scientific data uoon which
the Agency bases its policies,
programs, regulations, and
enforcement actions mus" be
sound and credible. Also, the
Agency must be assured that it
is getting its money's worth
from its investment in research
and laboratory testing. A
surprisingly large percentage of
laboratories investigated in the
Superfund's Contract
Laboratory Program were
found to have serious problems
with their methods. So far this
work has resulted in a number
of criminal and civil actions.
EPA is also working to improve
quality  control and internal
management controls in the
contract laboratory program.
   Four of the 10 high risk
areas reported by EPA in its
Fiscal 1991 FMFIA assurance
letter to the President are in
research and development.
Research and development
deficiencies included the lack
of planning and accounting for
research equipment, and
questionable research facilities
that may not have provided the
high quality, timely, scientific
and technical information
required to meet EPA's goals.
  We are particularly
concerned about the potential
for wrongdoing in the
pesticides program because
pesticides manufacturers pay
for studies submitted to EPA as
part of the registration process.
There is currently an ongoing
criminal investigation of one
pesticide laboratory that
allegedly provided EPA with
false test results.
The OIG  believes that EPA's
credibility is dependent upon
the quality of its scientific
research and data, yet this
area is highly vulnerable and
will be the object of greater
OIG involvement.
CONTRACTS AND
PROCUREMENT PRACTICES

Contractors have an enormous
role in helping the Agency
accomplish its mission.  EPA
must manage these contractors
so that they best serve the
public interest. There are Ihree
areas vital to effective
management of the Agency's
contractor program:  the
procurement process, contract
management, and cost
effectiveness determinations.
EPA relies on contractors to
assist in carrying out EPA's
mission to clean up past
pollution problems, develop
national policy, and set the
environmental agenda for Ihe
future.  Every year EPA
processes about 8,000 contract
actions, obligating more than
$1 billion.  EPA has 2,500
contracts worth $4 billion
whose project period has
expired, but which have not
been closed out.
   Contractors perform highly
technical work in such areas as
research and development, risk
assessment and standards
setting.  Although more and
more firms are entering the
environmental field, a relatively
small number of large firms
predominate, which dampens
competition.  OIG
investigations have identified
instances of overcharging and
collusion between contractors
to fix prices or circumvent the
competitive process, resulting
in millions of dollars in
disallowed costs, fines, and
civil recoveries annually.
   There is a dangerous
tendency in EPA for the
perceived urgency of program
needs to prevail over good
procurement practices.  We
have found many instances
where Federal regulations wer«
circumvented by EPA program
managers for the sake of
expediency.  For example, in
the Agency's solid waste
program, assignment
managers often obtained
services from subcontractors
through the prime contractor.
This practice  is (1) not cost
effective, (2) violates
procurement regulations

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because the subcontracts are
noncompetitively awarded, and
(3) removes accountability from
the prime contractor.  DIG
audits and investigations have
focused EPA management
attention on these types of
procurement abuses and
recommended corrective
actions to comply with
procurement requirements and
increase efficiency.
   Quality work at a reasonable
price can be assured  through
good contract management.
The DIG is alarmed that
Agency employees frequently
violated good contract
management and increased
the Agency's vulnerability to
fraud and abuse. For example,
we have found that work was
performed before the  work
plans were approved  and
money was obligated  even
before a contract was awarded.
Another area of concern is the
contractors' use of equipment
purchased with EPA funds or
provided by the Agency.
Sometimes this equipment is
kept or sold by the contractor
or its employees instead of
being returned to EPA.
Further, almost 90 percent of
EPA's contracting dollars are
spent on cost reimbursable
contracts.  This type of contract
has the advantage of flexibility,
but provides few incentives for
contractors to control costs,
with the government assuming
proportionately greater risk.
   Although the Agency
generally has responded
positively to our reports and
has taken steps to correct
identified problems, the OIG
intends to perform frequent
audits and investigations in
these areas to ensure further
improvements.
FINANCIAL MANAGEMENT:
CHIEF FINANCIAL
OFFICERS ACT

Enactment of the Chief
Financial Officers (CFO) Act
greatly expands the
requirement for the OIG to
perform financial audits.
During fiscal 1993, the OIG
must audit fiscal 1992 financial
statements for four Agency
trust funds and two revolving
funds.  The Hazardous
Substances {Superfund) trust
fund alone involves the annual
audit of $1 billion.  In addition
to auditing EPA's financial
statements, the CFO Act
requires the OIG to determine if
the funds have been
administered in accordance
with applicable laws and
regulations.
  OMB has cited EPA's
accounting system as a high
risk area, and financial
statements have not been
prepared since the present
system was implemented.
Prior audit reports have found
that EPA's accounting systems
do not provide complete,
consistent, reliable and timely
information for Agency decision
making. A current review has
found that without major
improvements, the Agency may
fully implement a $20 million
financial management system
that will be inaccurate and not
meet user needs.  Weaknesses
in the accounting systems are
serious problems that put the
Agency at increased risk of
loss from fraud, waste and
abuse. The OIG is committed
to providing audit coverage of
the Agency's financial
statements and working with
the Agency to fully implement
the CFO Act.
SUPERFUND

While progress has been
made, OIG audits and
investigations show that further
significant improvements are
needed to improve the cleanup
of Superfund sites.  EPA has
emphasized implementing the
needed improvements
identified in the Administrator's
1989 comprehensive review of
the Superfund program.  By
focusing its limited resources,
EPA has made significant
progress in one major area:
addressing the worst problems
at Superfund sites first.
   However, the OIG continues
to find fraudulent analyses,
falsified data, uncalibrated
equipment, backdated
analyses, and other serious
problems with the contract
laboratories used to analyze
samples from Superfund sites.
These problems could call into
question cleanup decisions
made on the basis of unreliable
data analyses and hamper the
recovery of EPA's cleanup
costs  from those responsible
for the contamination. Agency
officials are fully cooperating
with our investigations in this
area.
   Also,  EPA has not
adequately monitored the
cleanup activities by potentially
responsible parties under
voluntary agreements.  The
Agency is often not timely
reviewing and approving
project plans and other
deliverables, assessing
stipulated penalties for
noncompliance with the
cleanup agreements, or
adequately monitoring Agency
contractors hired to oversee
the private cleanups.
   Further, EPA's procedures
for reporting Superfund
accomplishments were
deficient. There were serious
inaccuracies in the Agency's
report to Congress on fulfilling
the statutory requirement to
start 175 substantial  and
continuous physical on-site
remedial actions at National
Priorities List sites between
October 17,1986, and
October 16,1989.  Many of the
178 remedial actions reported
to Congress did not meet the
statutory criteria.
 AUDIT FOLLOWUP

 Despite continued efforts to
 improve its audit followup
 activities, the Agency reported
 the lack of audit followup as a
 material weakness in both its
 1989 and 1990 Federal
 Managers'  Financial Integrity
 Act (FMFIA) report to Congress
 and the President.
 In our 1990 followup report on
 this new system, we pointed
 out that misinformation
 provided by Audit Followup
 Coordinators and entered into
 the new Management Audit
 Tracking System (MATS) had
 resulted in errors and
 omissions in the  new system's
 data base and in the first EPA
 Management's Semiannual
 Report to the Congress on
 Audits. In its  Management's
 Semiannual Report to the
 Congress on  Audits For the
 Period April 1,1990, through
 September 30, 1990, the
 Agency recognized that more
 work was needed to ensure
 that the many people involved
 in audit followup and tracking
 were rigorous in carrying out
 their responsibilities.  The OIG
 recently found that the Agency
 did not ensure that corrective
 actions were taken on single
 audit findings. Regions were
 not consistently tracking and
 monitoring single audit
 corrective actions in the MATS,
 and Headquarters' staff did not
 detect or correct these
 inconsistencies.  The Agency
 indicated that it was continuing
 to declare audit followup a
 weakness and would be taking
 a number of additional steps in
 1991 to further enhance the
 process.
   On December 17, 1990, the
 Assistant Administrator for
 Administration and Resources
 Management  and the Inspector
 General distributed several
 documents to Agency audit
 management  officials that had
 been developed by an Agency-
wide task force to strengthen
 EPA's audit management
 practices. One of these
 documents, a booklet entitled
 "Model Audit Management
 System, A System to
 Strengthen the Audit
 Management Ability of EPA
 Managers," identifies and
describes the  responsibilities of
key individuals for audit
 resolution and implementation
of corrective actions.

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  Qjest'onen '""Sis
    Totai  nei r!,b,e
    Fede-a1  Sna"'; .nelicpfclr:'
    Total unsjpported*
    Federal  Share Unsupported"
  -  Total Jnnecessary/Unreascnabk:*
    Federal  Share Unnecessary/Unreasonable*
  Recommended Efficiencies(Func!s be Put to  Bettor Usj
  -  Total Efficiencies*
  -  Federal  Share Efficiencies'
                                                          $56 4 Million
*  Costs Disallowed to-be Recovered
    Federal Share ineligible
  -  Federal Share Unsupported
    Federal Share Unnecessary/Unreasonable
    (costs which EPA  management agrees are
    unallowable and is committed to  recover
    or  offset against future  payments)

-  Costs Disallowed as Cost Efficiency
  -  Federal Share Recommended  Efficiencies
    (funds made available by EPA management's
    commitment to implement recommendations u
    DIG performance or preaward audits)

OTHER AUDITS
  Audits Performed by Another Federal  Agency or  Single Audit Act Audits
  Questioned Costs
  -  Total Ineligible
  -  Federal Share Ineligible"
  •  Total Unsupported"
  -  Federal Share Unsupported*
  -  Total Unnecessary/Unreasonable"
  -  Federal Share Unnecessary/Unreasonable"
  Recommended Efficiencies{Funds be Put to Better  Use)
  -  Total Efficiencies*
  -  Federal Share Efficiencies*

  Costs Disallowed to be Recovered
  -  Federal Share Ineligible
  -  Federal Share Unsupported
  -  Federal Share Unnecessary/Unreasonable
    (costs which EPA  management agrees are
    unallowable and is committed to recover
    or  offset against  future  payments)
-  DIG MANAGLC AUDITS
  - EPA Audits Performed by the  0 G
  - EPA Audits Reformed by Independent Public  Accountants
  - EPA Audits Performed by State  Auditors

-  OTHLR AUDITS
   -  EPA Audits Peitormed  by another  Federal Agency
   -  Single Audit A:t Audits

TOTAL REPORTS ISSUED
    -  Audit Reporis Resolved (agreement by Agency
      officials to laKe satisfactory corrective action)

Investigative Operations

  Fines and Recoveries (including civil)
  Investigations Ooened
  Investigations Closed
  Indictments of Persons or  Firms
  Convictions of Persons or  Firms
  Adm nistrative Actions Taken Against EPA  Employees

Fraud  Detection and Prevention Operations

• Debarments, Suspensions,  Voluntary Exclusions,  and
  Settlement  Agreements (actions to deny persons or
  firms from  participating in EPA programs or
  operations  because of mis.conduc: or poor performance)
• Hothne Complamls Received
• Hotline Comp'amts Processed and  Closed
• Proposed Legisative and Regulatory Items Reviewed
• Personnel Secunty Investigations  Adjudicated
                                                                                                                                                  48
                                                                                                                                                  59
                                                                                                                                                  12
127
502

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                                                                                                                                          $3,648,1 be
                                                                                                                                                 11C
                                                                                                                                                 131
                                                                                                                                                   3/
                                                                                                                                                   If
                                                                                                                                                   11
"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  Torn  audit resolution  is provided  by  the EPA
                                                                             Financial  Manaoement Division and is unaudited

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anc!
            ••  '  •'' i-:i icai obuses.
            ; ; i   lei ''dViev*  EPA's
            -:, v  . :CP,, nrogram
           it J .'-Jp-'
 • ;  ;, in •c-jti-iate allegations
 , •<• pen o:" possible criminal
 -, -  ' ocuiie 5s: and promote
 -. r.ic yrioift'u, and effective
 ''•• ,  op£"3t'cits   The OIG is
  -Kpons tie tor reviewing
 u;c,uiaikTis and legislation,
 e £r>A Inspector General
-rts  directly to the
unistrator and the Congress
 has the authority to:
  * initiate and carry out
independent and objective audits
and investigations,
  « Issue subpoenas for evidence
and information,
  • Obtain access to any
materials in the Agency,
  • Report serious or flagrant
problems to Congress,
  * Select and appoint OIG
employees,
  » Ml Senior Executive Service
positions,
  » Administer oaths, and
  * Fnter into contracts.

  The Inspector General is
aopc-inted by, and can be
removed only by, the President.
This independence protects the
GIG from interference by Agency
management and allows it to
function as the Agency's fiscal
••jn'J operational watchdog.
Staffing Distribution—Fiscal
S991 Ceiiing

Office          staff & Support  Operations & Field   Total

 rsp»-:,tor General      r                               5
' :v O tice of Inspecto' Gsnsrsi
'uriuioo-s through three rr-a|or
offices each  headed by an
Assist.". nt Inspector General,
Office of Audit, Office of
Investigations, and Office of
Management,
  Nationally, there are seven
Divisionai 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
                                    212


                                    64
                                               243


                                               71

                                               31
                                                              Inspector General Act of 1978  <-s  more -iafaiiec1 statist.'-,.'  ->:. ir>c
                                                              amended, are listed below  Fne   status of audit reports, ?nei
                                                              Inspector Genera! Act            recommendations and nor oti
                                                              Amondments of 1988 require      results.
                                                              Source
                                               Section and Pa
                                                              Inspector General Act, as amended

                                                              Sec'ion 4'a"2'
Section 5id(;6),

Section b'an7),

Sect,on 5(a)i8i,
                                            Appendix :
                                                             Section 5(ai(10i,    Summary of Prevous Reprj'i;,
                                                                              Nc Management Decis.ons  311
                                                                              Explanation of the Reasons 6,.
                                                                              Management Dec yon Has N1. '
                                                                              Been Made  and a State're'i!
                                                                              Concerning the  P^S'red
                                                                              ~.-notable 'o; Acn'Ovng a
                                                                              IvMnagenvnt Deri-ion or ClCr
                                                                              Sue h Report
Appendix 1

        1

        2


        2



Appendix 2
                                                                                                         Appendix 2
                                                              * There were no instances where information or assistance requested
                                                              by the Inspector General was refused during this reporting period.
                                                              Accordingly, we have nothing to report under section 5(a)(5) of
                                                              the Inspector General Act of 1978, as amended.

                                                              ** There were no instances of management decisions with which the
                                                              Inspector General was in disagreement.
                                                   350

-------
                       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
Daniel S. Sweeney
Assistant Inspector General
Vacant
Deputy
            Technical Assistance Staff
            Gordon Milbourn
            Director
Office of Management
John C. Jones
Assistant Inspector General
                                     Technical Assessment and
                                     Fraud Prevention Division
                                     Michael J. Binder
                                     Acting Director
                                     Administration and
                                     Management Services
                                     Division
                                     Vacant
                                     Director
             Planning and Resources
             Management Staff
             Kenneth Hockman
             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
                                               Edward  Gekosky,
                                               Internal Audit

                                               Francis C  Kiley
                                               Washington Field Office
                                               Investigations

-------
                         '^p^-^^I^


                                               •lie
7rte Great Falls of the
Potomac River
(photo by Steve Delaney)
                                                                                         *
                                                                                         §
                                                                                             **•

-------
  S0Ction  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 iden-
tifies significant problems,
abuses, and deficiencies
relating to the Agency's prog-
rams and operations along
with recommendations 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, Superfund, and
Special and Early Warning
Reviews.
Summary of
Audit  Activities
and Results
     Questioned Costs And Recommended
     Efficiencies By Type Of Audit
             Construction
                                Others
                                                 Superfund
      Areas Of Effort By Staff Days
                                                      Sources Of Reports
                                      Performance
                                      5470  31%
                                                                 EPA
                                                               48 6%
                                                                 State Audits
                                                                  12  2%
           Total-17,559 Days
                                                       Total Reports • 748

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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:
ERA'S $20 Million
Financial Management
System May Not Meet
Agency Needs

Problem

Despite its projected $20
million cost, EPA had not
devoted adequate attention
and  resources to effectively
implement its new Integrated
Financial Management System
(IFMS).  Without major
improvements, the system
may not fully meet the
Agency's financial
management needs.

Background

In 1987 EPA contracted for a
new integrated financial
management system that would
combine accounting and
budgeting systems with other
financial and administrative
systems to comply with Office of
Management and Budget
requirements. EPA planned to
implement IFMS in three phases
by October 1990. Due to
problems in Phase 1's
implementation, budget changes,
and objections from program
officials, the plan to implement
phases 2 and 3 was abandoned.
The various modules included in
those phases will be
implemented individually.
Through fiscal 1990, EPA  had
obligated $8.2 million and  had
estimated that an additional
$11.5 million would be needed
to complete the system by
October 1993.

We Found That

EPA planned to spend nearly
$20 million, more than double its
initial estimate of $7.7 million,
but had  not provided sufficient
attention or resources to
implement the IFMS. Instead,
until recently, the task had been
delegated to committees,
comprised largely of part-time
employees. Completion of the
initial 3-year project had been
extended 3 years. Also, users
throughout the Agency were
dissatisfied with the system, and
many key requirements for
developing a major information
system were  not met.
  For example, the Agency had
not updated its needs statement,
feasibility study, and cost-benefit
analysis since 1986, or prepared
a system decision paper.  Also,
the Agency had not complied
with other key Agency and
Federal requirements for a
system, including (1)  adequate
system testing,(2) involvement of
users in design of one module
(budget preparation), (3)
documentation of alternatives
considered for a $1 million
reporting  system, (4) risk
analysis of the entire IFMS, and
(5)  adequate training  and
provision of guidance to users.
  Significant IFMS data integrity
and security problems have led
to user dissatisfaction and the
development of duplicate
systems.  Without key planning
and decision processes,
adequate system testing, and
sufficient user involvement, the
Agency may fully implement a
$20 million financial
management system that will be
inaccurate, not meet user needs,
and encourage duplicate
systems throughout the Agency.
                                                               We Recommended That

                                                               The Assistant Administrator for
                                                               Administration and Resources
                                                               Management:

                                                               • Establish an independent
                                                               organization with authority,
                                                               responsibility and adequate
                                                               resources to properly manage
                                                               IFMS't. implementation: and

                                                               • Require the updating or
                                                               completion of critical planning
                                                               and decision-making documents
                                                               and the implementation of
                                                               Federal and Agency
                                                               requirements for developing an
                                                               information system.

                                                               What Action Was Taken

                                                               The audit report (1 WOT53) was
                                                               issued to the Assistant
                                                               Administrator for Administration
                                                               and Resources Management on
                                                               March 29, 1991. A response  is
                                                               due by June 27, 1991. The
                                                               Agency agreed with cur findings
                                                               and recommendations and was
                                                               aggressively moving to
                                                               implement corrective actions.
Improved EPA
Computer Operations
Could Save Millions Of
Dollars

Problem

EPA did not adequately
forecast its computer
requirements or match its
needs to available resources.
In addition, the Agency was
unnecessarily spending an
estimated $5.3 million
annually due to inefficient (1)
computer operations and use,
(2) software applications
design, and (3) data storage
and retrieval.

Background

EPA's National Computer Center
(NCC) at Research Triangle
Park (RTP), North Carolina, is
one of the largest and most
complex data centers in the
country, using IBM  3090s for a
variety of applications. NCC is
managed by the National Data
Processing Division (NDPD),
Office of Administration and
Resources Management
(OARM), at RTP.

We Found That

NDPD did not accurately
forecast its computer resources
requirements for the first six
months of fiscal 1990.  As a
result, NDPD erroneously
identified the  need to procure
$3.8 million of additional
computers despite having more
than adequate reserve capacity.
  The Agency had not
developed appropriate policies
and standards for processing
jobs and naming computer files
that could enhance the
automation of its operations and
save at least $1.4 million
annually.
  NDPD was not effectively
using an IBM 3090 in Cincinnati,
Ohio, to share the Agency's data
processing workload although
that computer had considerable
reserve capacity. Use of this
computer for day-to-day
processing tasks could save the
Agency $1.3  million annually.
  Also, NDPD had not
determined the cost-
effectiveness of procuring
additional hardware compared to
upgrading existing software to

-------
 meet projected computer
 capacity needs.  In addition, the
 application software design
 review process was inefficient,
 with some designs being revised
 three or more times. Current
 standards and guidelines for
 design development were not
 comprehensive.  The Agency
 could save about $980,000
 annually by correcting these
 problems.
   NDPD was not efficiently
 using tape storage of data,
 especially for the Agency's
 Integrated Financial
 Management System (IFMS).
 Much seldom used data was on
 direct access storage devices
 (DASD) rather than less
 expensive tape.  In addition,
 NDPD could make greater use
 of an automated tape retrieval
 system to reduce the Agency's
 need for more DASD.  More
 efficient use of tape to store data
 could save the Agency about
 $670,000 annually.
   NDPD operating efficiency
 performance goals require 90
 percent of all IFMS transactions
 to be completed in less than 2
 seconds. In February 1990,
 IFMS used 17 single DASD disk
 packs which were only one-third
 full to obtain this goal.   As of
 June 1990, IFMS required 30
 disk packs to maintain
 acceptable performance.  Even
 though the amount of IFMS data
 has increased, the main purpose
 of using so many underutilized
 disk packs was to reduce
 response time. The use of disks
 is a short term, inefficient
 solution  to a software problem.
 Improving IFMS software
efficiency could save $480,000
 annually.
  NDPD prints an average of
2.1  million print lines daily. EPA
 had not  installed and
implemented software to give
microcomputer users the option
of storing instead of printing files
from the IBM 3090.
 Implementing such software
could save an additional
$450,000 annually.
We Recommended That

The Directors of the Office of
Information Resources
Management (OIRM) and the
Office of Administration and
Resources Management
(OARM) at RTP:

• Improve and validate the
methodologies for projecting
computer resource
requirements;

• Establish and enforce
standards governing the
instructions used to process jobs
and the names given to
computer files;

• Use the IBM 3090 in
Cincinnati  more efficiently to
share the Agency's data
processing workload;

• Identify major software
application programs which need
to be upgraded or redesigned
and improve the Agency's
application design review
process;

• Make more efficient use of
disk and tape storage; and

• Implement procedures to allow
users to download printed
reports from the IBM 3090 to
personal computers.

What Action Was Taken

The audit report (1100152) was
issued to the Directors of OIRM
and OARM at RTP on March
29,  1991.  A response is due by
June 27, 1991. During our
audit, NDPD revised its
computer capacity requirements,
eliminating the need for
procuring additional processing
capacity. In responding to the
draft report, the Agency
generally agreed with our
recommendations and was
implementing corrective actions.
EPA Did Not
Aggressively Pursue
Regulation Of
Potentially Harmful
Chemical Substances

Problem
EPA's Office of Toxic
Substances (OTS) had regulated
few existing chemicals thought
to pose a significant risk to
humans.

Background

The Toxic Substances Control
Act (TSCA) authorizes EPA to
regulate toxic chemicals which
present an unreasonable risk of
injury to human health or the
environment There  are over
60,000 existing chemicals in the
TSCA inventory.  OTS believed
that about 10,000 of those
potentially pose a health risk.
TSCA provides for priority review
if data indicates a chemical  may
pose a substantial risk from
cancer, genetic mutations, or
birth defects. Once a chemical
is designated for priority review,
the Agency has 180  days to
initiate  regulatory  action or
announce that the risk is not
unreasonable.  If  EPA
determines that the risk may be
prevented or reduced to a
sufficient extent by another
Federal agency's action, EPA
must refer the chemical to that
agency.

We Found That

OTS was not effectively using its
TSCA regulatory authorities for
existing chemicals.  OTS had
not followed established
guidelines for designating
chemicals for priority review and
had not developed adequate!
procedures to expedite ongoing
priority reviews.  OTS also had
not defined how it would work
with other Federal agencies
having regulatory authority over
chemical substances. As a
result, it takes years for OTS to
review and determine if a
chemical poses an unreasonable
risk to health or the environment.
   Since January 1, 1977, the
effective date of TSCA, only four
existing chemicals had been
regulated (RGBs, CFCs, dioxin,
and asbestos). Although four
others had been designated for
priority review prior to 1985,
EPA had not taken final
regulatory action. For example,
EPA is required to set drinking
water standards to protect
public health from hazardous
substances
(photo by Steve Delaney).

-------
OTS had been reviewing the
possibility of regulating urea-
formaldehyde in pressed wood
for 6 years, even though data
indicated that it may pose a
significant cancer risk,

We Recommended That

The Assistant Administrator for
Pesticides and Toxic
Substances:

• Develop program goals,
criteria, and  time frames for
review of potentially harmful
chemicals;

• Comply with the provisions of
TSCA requiring priority review of
chemicals which may pose a
significant health risk;

» Establish clear policy regarding
when EPA should refer
chemicals to other agencies and
when EPA should retain
chemicals for regulatory action:

* Coordinate with other Federal
agencies to  ensure that work on
risk assessments is not
duplicated; and

* Seek legislative change to
provide EPA with the authority to
review potentially harmful
chemicals referred to other
Federal agencies to ensure their
timely and appropriate review.

What Action Was Taken

Tne audit report (1100154) was
issued to the Assistant
Administrator for Pesticides and
Toxic Substances on March 29,
1991  A response is due by
June 27,  1991.  Agancy officials
generally agreed with the
recommendations in our draft
report and were implementing
corrective actions.
Stronger Enforcement
And Oversight Needed
To Protect The Public
From Harmful
Pesticides

Problem

Delegated States and EPA
regions frequently did not
take timely and appropriate
enforcement actions against
violators of pesticide laws to
protect the public and the
environment from exposure to
harmful pesticides.

Background

Under the Federal Insecticide,
Fungicide, and Rodenticide Act
(FIFRA), ail except two States
are responsible for primary
pesticide enforcement.
However, States are not
'equired to have administrative
penalty authority or enact iaws
requiring fines as stringent as
FiFRA whsch provides maximum
crvil penalties of $5.000. As part
of its oversight, EPA performs
mid-year and year-end reviews
of States' enforcement
programs. Under  FiFRA, a
State has 90 days to cot red any
noted significant deficiencies, 01
EPA may rescind all o<" part of
its program.  If States do not
initiate timely enforcement
actions. EPA may  do so.

We Found That

Both the States and EPA
regions needed to take stronger
and more timely enforcement
actions against violators of
FIFRA and exercise better
management control over iheir
enforcement cases.  Twelve of
16 States in  Regions 4, fi. and 7
had maximum penalty autKvity
significantly less than tnat
provided in FIFPA. In one
State. ar aerial applicator
illegally applied toxaphene,  an
EPA canned oesticide. on a
cotton field exceeding even the
amount recommended HI the
 original labeling and killed about
 66,000 fish in a nearby body of
 water. Despite the severity of
 the violation, the maximum fine
 was only $500 under the State's
 pesticide laws.  Another State
 issued warning letters to dealers
 for selling restricted use
 pesticides to uncertified
 applicators, a violation which
 called for denial, suspension,
 revocation, or modification of the
 dealers' licenses for the fiist
 violation under the State's
 penalty schedule.
   For 23 violations referred by
 an EPA region, one State
 started actions for only 12 of  the
 23 violations within 30 days as
 required by FIFRA, taking an
 average of about 50 days to  act
 on the 11  remaining referrals.
 The  regions were also untimely
 in processing enforcement
 actions referred by States.
   When EPA regions took
 enforcement actions, they
 sometimes reduced fines below
 the minimum allowed by national
 guidance without adequate
 justification or documentation.
 For example,  one region did  not
 fully  document reductions for 19
 reviewed cases.  The region
 only partially documented 2 of
 ! 4 cases where penalties were
 reduced by less than 40 percent.
 1 he  files for the five remaining
 cases did  not document
 reductions averaging about 80
 percent.  EPA regional oversight
 evaluations were not always
 performed, documented, or
 completed timely. Also, regions
 did not report all  known
 weaknesses or require States'
 timely corrections of i eoorted
 weaknesses.

 We Recommended That

 The  Assistant Administrator for
 Pesticides and Toxic
 Substances'

 • Encourage States with primary
 enforcement responsibility to
 seek administrative penalty
 authority for pesticide violations
 comparable to those allowed
 under FIFPA,

 • Require documentation of civil
 penalty reductions, including
 reasons for reductions  below
current limits, and reemphasize
that reductions are not automatic
and must be supported by the
 respondent;
• Develop timeliness criteria for
regional processing of State-
referred cases;

• Develop and implement a
system for the regions to track
and follow-up on significant
referrals from States as well as
referrals to the States; and

• Require regions to support the
results of in-house evaluations,
including a listing of inspections
and cases reviewed and a
description of the methodology
used to select them.

What Action Was Taken

The audit report (1100148) was
issued to the Assistant
Administrator for Pesticides and
Toxic Substances on March 26,
1991.  The Office of Pesticides
and Toxic Substances and the
regions generally agreed with
the findings and were in the
process of implementing the
recommendations, A response
to the report is due by June 24,
1991.

-------
Agency Computer
Files Not Adequately
Protected

Problem

EPA was not sufficiently
protecting its information
resources, exposing the
Agency to unnecessary risks
of unauthorized or improper
access to its mainframe
computer.

Background

Resource Access Control Facility
(RACF) is an IBM software
package used by EPA to
provide security for its IBM
mainframe computers at the
National Computer Center,
Research Triangle Park (RTP),
North Carolina.  RACF is the
most crucial security component
on the computer system,
responsible for safeguarding
some of EPA's most critical
computer files.

We Found That

Users of the IBM mainframe
computers were routinely given
significantly broader RACF
access authorities than needed
to perform their jobs,  potentially
allowing some users to update
or alter files.  Agency officials
were not using some of RACF's
management and operational
features to maximize protection
against deliberate or accidental
abuse of valuable information
resources. Users also violated
Agency procedures by sharing
and failing to safeguard their
computer passwords.
  Agency officials were not
giving sufficient guidance to, or
providing adequate control over,
contractor personnel responsible
for RACF security. Contractors
were improperly making final
determinations on users' special
RACF authorities, drafting policy
statements, designing the RACF
security program, and training
users in the use of RACF. Only
one EPA employee, who also
had a wide range of
administrative duties, was
assigned  to oversee the RACF
security program on a part-time
basis.  By not adequately
protecting its valuable
information files, EPA increased
its vulnerability to computer fraud
that could adversely affect its
mission and the integrity of its
programs.

We Recommended That

The Directors of the Office of
Information Resources
Management (OIRM) and the
Office of Administration and
Resources  Management
(OARM) at RTP:

« Establish controls to ensure
that users receive access
authorities commensurate with
those needed to perform ttieir
jobs;

• Fully  implement the RACF
management and operational
features to maximize the
protection against abuse of
information  resources;

• Develop a RACF
implementation plan, security
objectives, and quality
assurance procedures; and

• Establish  a full-time National
Data Processing Division
(NDPD) security officer position
requiring appropriate experience
and training to manage and
direct the NDPD security
program activities.
What Action Was Taken

The audit report (1100151) was
issued to the Directors of OIRM
and OARM at RTP on March
29, 1991. A response to the
audit report is due June 27,
1991. EPA generally agreed
with the findings and
recommendations in the draft
report and initiated actions to
correct many of the conditions
identified.

-------
Construction
Grants
EPA's wastewater treatine,'-'
works construction grants
program is the largest smqx
program the Agency
administers.  Under ifie
provisions of Publk- Lav,- ,-*,~
as amended, the Agen*, • ,
authorized to make grdi '
covering 55 percent dini
some instances, uf' ff .
percent of the aligir'f, . • ,
constructing wantf,* _< -.
treatment facilities.  L\. ••. •
semiannual fjerioc'  $?
,vas obligated or • '.  -•• •
att&rn&iivt' hjnoing r'iecf'-3n>Sfr',s
DJ fte Sfa/es,  T^e  iew 7tfe V.'
:^3rg(-v F &A  '•I'h Ot-^ei-'C'nr:
••>f^ in'Oiefw- ."/,-y' a progw ;o
                                                                                                  yi'.'-2 • 'illiof, v, ';3 awa.-'jej 'or
                                                                                                                            Of

-------
Over $8.5 Million Of
Oxnard, California,
Project Claims Were
Ineligible
 Oxnard, CA
 Questioned
 0   5   10   15   20  25
                      30   35  40
Wlionsofdolars



Problem
Non-edera1 |     ]
The City of Oxnard, California,
claimed $8,572,231 of
ineligible construction,
engineering, legal, force
account, and administrative
costs.

We Found That

EPA awarded a $17,650,599
grant to the City of Oxnard for
improvements to the wastewater
treatment plant and ocean
disposal facility. We questioned
$8,572,231 of the grantee's final
claim as ineligible, including:

• $4,493,218 of construction and
legal costs in excess of
approved amounts;

• $1,491,117 of engineering,
legal, insurance, and force
account costs allocable to the
ineligible portion of the project;

• $1,362,077 of costs for
services outside the scope of the
project, legal services and
related force account previously
determined ineligible, costs billed
twice, work not completed or
paid for, and amounts  based on
estimates or otherwise not
substantiated; and

• $1,225,819 of engineering,
insurance, and force account
technical services costs incurred
after the authorized construction
contract completion date.

  The City also did not apply
$66,269 of interest earned on
excess Federal payments to
offset grant expenses.
               We Recommended That

               The Regional Administrator,
               Region 9, not participate in the
               Federal share of ineligible costs
               (56,485.975); ensure trie Federal
               share of interest earned
               ($56,802) is credited to the
               grant; and recover the applicable
               amount from the grantee.
What Action Was Taken

The audit report (1300045) was
issued to the Regional
Administrator, Region 9, on
March 25, 1991.  A response is
due by June 23,  1991.


Sun Valley, Nevada,
Claims Over $8.5
Million Of Questioned
Costs
                Tha Sun Valley Water Si San. District
               Millions of dollars

               IHH Feoerai        Nor, Fader^l


               Problem
               The Sun Valley Water and
               Sanitation District (District),
               Nevada, claimed $6,221,120 of
               ineligible  engineering,
               equipment, construction, and
               administrative costs. In
               addition, $2,347,748 of
               unnecessary costs were
               questioned.

               We Found That

               EPA awarded three grants
               totaling $9,212,689 to the District
               to plan, design, and construct
               interceptor and collection sewers
               for the unsewered community of
               Sun Valley.  We questioned
               $6,221 ,120 of claimed costs as
               ineligible, including:

               • $5,051 ,1 52 of engineering
               design, equipment, and
               construction costs related to the
               collection system which did not
               meet eligibility requirements that
               the bulk of the expected flow
(generally two-thirds) be from
the residences existing on
October 18,1972;

• $995,653 of engineering
inspection fees in excess of
eligible amounts, allocable to the
ineligible portion of the
construction project, or were
incurred after the authorized
construction contract completion
date; and

• $174,315 of administrative,
legal, and  other charges related
to the arbitration of an ineligible
daim settlement under the
engineering subagreement,
construction of the ineligible
collection system, and redesign
and construction of the
interceptor and costs claimed in
excess of  approved  amounts.

  We also questioned as
unnecessary $2,437,748 claimed
for design  and construction of
the underutilized interceptor
portion of the  project To
increase utilization, the District
was considering extending
sewer service to a new
residential  area outside of the
approved EPA project's scope
for which the grantee would
receive connection fees of about
$3.2 million.

We Recommended That

The Regional  Administrator,
Regbn 9:

• Not participate in the Federal
share of ineligible costs
($4,665,840);  determine the
eligibility of the Federal share of
unnecessary costs ($1,760,811);
and recover the applicable
amount from the grantee.

• If the unnecessary costs are
determined to be ineligible, not
dose the grant until  the District
assures EPA that the District will
pay enough of any revenues
received from annexing  the new
residential  area to cover the
Federal share ($1,760,811) of
the costs incurred for the design
and construction of the
underutilized interceptor portion
of the project.
                                                                  What Action Was Taken

                                                                  The audit report (1300053) was
                                                                  issued to the Regional
                                                                  Administrator, Region 9, on
                                                                  March 28, 1991. A response is
                                                                  due by June 26, 1991.
                                                                                                   Chicago Claimed Over
                                                                                                   $5.1  Million Of
                                                                                                   Questioned Costs
                                                                                  Metropolitan Water Reclam. District
                                                                                                    Audited
                                                                                  Questioned
                                                                                     100    200    300   400   500   600
                                                                                 MiHions of dollars



                                                                                 Problem
Non-Federal
                                                                  The Metropolitan Water
                                                                  Reclamation District of
                                                                  Greater Chicago (MWRD)
                                                                  claimed $3,549,043 of
                                                                  ineligible construction and
                                                                  engineering costs. An
                                                                  additional $1,566,933 of
                                                                  unsupported or unnecessai-y
                                                                  costs were questioned.

                                                                  We Found That

                                                                  EPA awarded five grants totaling
                                                                  $341,084,591 to MWRD for
                                                                  construction of the connecting
                                                                  structures, tunnels and shafts of
                                                                  the Mainstream Tunnel and
                                                                  Reservoir Plan. This included
                                                                  earth and rock excavation,
                                                                  construction of rock tunnels,
                                                                  grouting tunnel walls, and
                                                                  construction of connecting
                                                                  sewers. We questioned
                                                                  $3,549,043 of the grantee's
                                                                  claim as ineligible, including:

                                                                  • $1,902,458 of engineering
                                                                  costs incurred after contract
                                                                  completion dates;

                                                                  • $1,050,441 of additional costs
                                                                  incurred by construction
                                                                  contractors after they had
                                                                  encountered both excessive and
                                                                  inadequate excavation
                                                                  performed by another contractor;

                                                                  • $434,449 of legal settlement
                                                                  costs resulting from a dispute
                                                                  between the grantee and a
                                                                  construction contractor;
"6

-------
 • $139,350 of engineering (xists
 over-billed to EPA; and

 • $22,345 of indirect costs
 related to the direct costs
 questioned.

   We also questioned
 $1,531,308 of inadequately
 supported force account,
 subcontractor, engineering, and
 settlement costs and $35,625 of
 unnecessary costs for work
 reassigned from one contractor
 to another due to the original
 contractor's inability to perform.

 We Recommended That

 The Chief, Financial
 Management Branch, Region 5.
 not participate in the Federal
 share of ineligible costs
 ($2,661,783); determine the
 eligibility of the Federal share of
 unsupported and unnecessary
 costs  ($1,175,200); and recover
 the applicable amount from the
 grantee.

 What Action Was Taken

 Five audit reports (1300048,
 1300049, 1300050, 1300051,
and 1300057) were issued to
the Chief, Financial
Management Branch, Region 5,
on March 29,  1991.  Responses
to the audit reports are due by
June 27,  1991.
Grantees For D.C.
Project Claim $2.9
Million Of Ineligible Or
Unsupported Costs
 Washington Suburban Sani. Comm.
Millions of dollars



Problem

The Government of the
District of Columbia, the
Washington Suburban
Sanitary Commission, and the
County of Fairfax, Virginia,
jointly claimed $1,936,115 of
ineligible engineering and
construction costs for the
District's Regional Water
Pollution Control Plant
project  An additional
$954,879 of unsupported
costs were questioned.

We Found That

The U.S. Department of the
Interior, Federal Water Pollution
Control Administration, awarded
one grant each to the District of
Columbia, the Washington
Suburban Sanitary Commission
(WSSC), and the County of
Fairfax totaling $13,329,320
The grants provided joint funding
of the District's Regional Water
Pollution  Control Plant (WPCP)
for construction of additional  grit
removal,  primary sedimentation
and chlonnation facilities.  We
questioned $1,936,115 of me
grantees' claims as ineligible,
including:

• $688,201 for facilities and
equipment that either were never
placed in service or were
abandoned;

• $522,408 of project inspection
and design costs outside the
grants' scope:

• $398,564 claimed by WSSC
and the County of Fairfax  IP
excess of their grant ceilings;

• $172.845 claimed by WSSC in
excess of payments  made to the
District for its share of the
project costs;

• $116,293 of construction,
project inspection, and
engineering costs incurred
before contract award or after
contract completion; above the
lowest bid prices; applicable to
ineligible  cost, not adequately
supported; or billed twice; and

• $37,804 of indirect costs
applicable to ineligible costs and
program  income not credited to
the grant.
   We also questioned $954,879
 of inadequately supported
 project inspection, engineering,
 and construction costs.

 We Recommended That

 The Regional Administrator,
 Region 3, not participate in the
 Federal share of ineligible costs
 ($1,064,863); determine the
 eligibility of the Federal share of
 unsupported costs ($525,183):
 and recover the applicable
 amount from the grantee.

 What Action Was Taken

 The audit report (l 100157) was
 issued to the Regional
 Administrator, Region 3, on
 March 29, 1991. A final
 response  is due by June 27,
 1991.
 Over $2.2 Million Of
 ineligible And
 Unsupported Costs
 Claimed For York
 County, Virginia,
 Project
f~Coumy 01 York, VA
Problem

The County of York, Virginia,
claimed $1,109,034 of
ineligible construction,
engineering, inspection, and
other costs. An additional
$1,136,703 of unsupported
costs were also questioned.

We Found That

EPA. awarded two grants
totalling $8,689.595 to the
County of York for the design
and construction of interceptor
and collector sewers, force
mains, and pumping stations.
The grantee claimed ineligible
costs of S'.-109,034. including
 • $928,298 of construction and
 project improvement costs for
 road restoration outside the
 approved projects scope,
 incorrect calculations of
 excavation and backfill costs.
 materials unnecessary or more
 expensive than required for
 adequate construction, delays  ir
 easement acquisition, and costs
 claimed twice;

 • $121,68(3 of engineering tees
 computed using a prohibited
 method, applicable to ineligible
 construction, or for unallowable
 financing costs' and

 • 559,056 of force account
 project inspection fees and
 administrative costs applicable t<
 ineligible construction or incurrec
 after original construction
 contract completion dates and
 unallowable administrative
 expenses.

  We also questioned
 $1,136,703 of unsupported
 administrative, engineering,
 project inspection, anc*
 construction costs
We Recommended That

The Regional Administrator,
Region 3, not participate in the
Federal share of the ineligible
costs  ($831,776), determine the
eligibility of the Federal share of
unsupported costs ($852,527),
and lecover the applicable
amount from the grantee.

What Action  Was Taken

The audit report (1100147) was
issued to the Regional
Administrator, Region 3, on
March 25, '991  A response is
due by June ?3, 1991.

-------
San Francisco Ciairned
$1.8 Million Of
Ineligible Arid
Unreasonable Costs
 City & County of San Francisco
 Audited
 Questioned
      20
Mfccnsoi dollars


Problem

The City and County of San
Francisco (CCSF), California,
claimed $1,629,956 of
ineligible  construction arid
operating expenses. An
additional $168,625 of
unreasonable construction
costs were questioned.

Background

On September 28, 1990, we
issued an audit report (0300097)
covering costs claimed from
March 31, 1986, to September
27, 1988,  for the Great Highway
reconstruction portion of tne
project. Of the $4,587,536
claimed for the highway project,
we questioned $497,876 as
ineligible and $3,381,272 as
unreasonable.  1 his report
covers the eligibility of remainder
of the $81,661,196 of
construction contract costs
claimed for the period February
4, 1981, through April 27, 1989

We Found That

EPA awarded a grant, as
amended, of $87,570,172 to
CCSF for  construction of the
Westside Storage and 1 ransport
Facilities.  Of the $77,073,660
audited for this report, we
questioned $1.629,95^ as
ineligible, including

* $1,284,235 of construction
costs claimed in excess o>
approved  amount;;;

«  55302,897 of construction
costs allocable to the ineligible
portion of the project; and
 • $42,824 (or costs outsido the
 scope of work and ordinary
 'jpefar.-ig ax;xnr,es of local
 fjovernmont.

  We also oije.iiionc-d $168.02
 of uneasonabk- construction
 r.csis daimed tor improving the
 Great Highway tc a level whicn
 substantially exoeedtx! ihe
 Hig-iway'i ongina' comJ'tion

 We R
Region 9. not participa:e in the
Fecleia! sh* 3 ot "leligibie costs;
ft' 222,467V de=;r?rr-.:r,3 the
eligibility of P~e 7 (••!&' n- share ot
unroasonabie rosis  :$'26.469i.
i-n-:' recovo' ttio a;:p\'cab\e
anioun* fror" frie :]rantoe

What Ac'.ior* Was Action
Ihf. a'.iait rsr/ort i 'SC'O'J'SSi wa.,
issued to me Regional
                    !). on
                  response «;
due by June 27  >3P?  ' A
wsyx>/(S« to oir r~?.vio'jr- audit
repi.v due on December 27.
1990, fisii i>(-!. 'tv-r' 'et.-e/Veu a.s

-------
Super-fund
Program
 The Superfund program was
 created by the Comprehensive
 Environmental Response,
 Compensation, and Liability Act
 of1980(CERCLA). The act
 provided a $1.6 billion trust fund
 to pay for the costs associated
 with the cleanup of sites
 contaminated with hazardous
 waste.  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. On November 5,
 1990, the Omnibus Budget
Reconciliation Act of 1990 was
enacted, authorizing
appropriations for 3 additional
years and extension of the
taxing authority tor 4 additional
years.
  The parties responsible for the
hazardous substances are liable
 for cleaning up the site
 themselves or reimbursing the
 Government tor 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 tor 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;

 » Examination of a sample of
agreements with States carrying
out response actions; and
  • Examination of remedial
  investigations and feasibility
  studies prepared tor remedial
  actions.

   The Inspector General is
  required 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
 submit a detailed annual report
 to the Congress on January 1  of
 each year on the progress
 achieved in implementing
 CERCLA during the preceding
 fiscal year.  The OIG is required
 to review this report for
 reasonableness and accuracy.
 and the Agency is required to
 attach the result of the OIG
 review to the Agency's annual
 report.  Our report on the
Agency's report tor fiscal 1989
 was issued on  October 18,
 1990.

-------
EPA Overstated
Remedial Action Starts
In Its Report To The
Congress

Problem

Inadequate documentation
and insufficient controls
resulted in EPA incorrectly
reporting to Congress that it
had met the National Priorities
List (NPL) remedial action
starts requirement of the
Superfund Amendments and
Reauthorization Act of 1986
(SARA).

Background

SARA required EPA to start not
less than 175 initial, substantial,
and continuous physical on-site
remedial actions at NPL
hazardous waste sites within 36
months of its October 17, 1986,
enactment.  Sites are ranked
according to their hazard to the
environment and public health.
In an October 17,1989. report
to Congress entitled
"Commencement of Post-SARA
Remedial Actons," EPA stated
that it had started 178 remedial
actions at NPL sites during the
period October 17, 1986,
through October 16,1989.
SARA's  legislative history clearly
reflects Congress' intent that
remedial action starts be
substantial and continuous, not
isolated or preliminary, and that
the most hazardous NPL sites
be addressed first.

We Found That

Many of the 178 remedial
actions reported to Congress did
not represent the start of initial,
substantial, and continuous
physical on-site cleanup actions
at the most contaminated NPL
sites.  From our sample of 42
lemedial actions included in the
report to Congress, 28 actions
did not meet the criteria
established by SARA and its
legislative history.
  Site activities were incorrectly
claimed as remedial action starts
due to (1) insufficient EPA
Headquarters control of the
reporting process and the
quality, integrity, and reliability of
remedial action data received,
(2) inadequate Headquarters'
planning, review and  evaluation
of remedial acton starts reported
by regions, (3) conflicting criteria
between SARA and EPA for
identifying and defining remedial
action starts, and   (4) failure of
Headquarters and regional
management to property
communicate SARA
requirements to remedial project
managers.
  Also, EPA did not ensure that
post-SARA remedial actions
addressed the most hazardous
sites on the NPL. During  the
post-SARA reporting  period,
EPA had not established a
system for planning and tracking
remedial actions in relation to
sites' NPL ranking. Only 78, or
44 percent, of the 178 reported
post-SARA remedial action
starts were listed in the upper
40th percentile of the pre-SARA
NPL.
  EPA's process for controlling
and reporting SARA
accomplishments was not
effective.  Records and site files
for the post-SARA remedial
actions contained little or no
documentation of the decision
process for including  remedial
starts in the report to Congress.

We Recommended That

The Assistant Administrator for
Solid Waste  and Emergency
Response:

• Reevaluate the 178 remedial
action starts  reported to
Congress and revise the report
to more accurately reflect the
Agency's actual post-SARA
accomplishments.

• Revise and clarify Agency
guidance for defining and
identifying remedial action starts.

• Establish a formal remedial
action planning and reporting
system to ensure that future
post-SARA remedial action
reports are accurate, reliable,
and reflect Agency
accomplishments.
• Require complete
documentation of the decision
process to identify Agency
accomplishments for external
reports and establish proper
controls and retention
requirements for Hie supporting
documentation.

What Action Was Taken

The audit report (1100155) was
issued to the Assistant
Administrator for Solid' Waste
and Emergency Response on
March 30, 1991.  A response to
the final audit report is due by
June 28, 1991, In responding to
the drafl report, (fte Assistant
Administrator strongly disagreed
with our findings and
recommendations,  He statsd
that their report was based on
information available at the time
of the report on project status
and that the 178 remedial action
starts was consistent with the
congressbnally mandated
definition and their overall
strategy and guidance.
Increased Monitoring
And Enforcement
Needed To
Prevent Superfund
Cleanup Delays In
Regions 1 And 5

Problem

Regions 1 and 5
unnecessarily delayed
Superfund cleanups by not
timely reviewing required
documents submitted by
potentially responsible patties
(PRP), not assessing
stipulated penalties, and not
enforcing voluntary
agreements with PRPs.  Also,
Region  1 was not properly
monitoring  contractors'
performance.

Background

EPA may negotiate an
agreement with PRPs if it
believes they are willing and
financially capable of cleaning up
a site. Under the agreement.
EPA oversees the PRPs'
activities. PRPs are required to
submit to EPA certain products,
such as  project site plans,
quality assurance plans, and test
results before actual cleanup of
the site can  bean
We Found That

Problems existed with monitoring
and enforcement of PRPs'
activities in Regions 1 and 5 that
significantfy delayed both the
start and completion of
hazardous waste site cleanups.
For example:

• After settlements had been
reached with PRPs, Regions !
and 5 did not timely review and
approve project site plans and
other documents. The Regions
lacked definitive time frame
guidelines  and  a tracking system
to monitor  their review and
approval of PRPs* submissions.

• Regions 1 and 5 were not
assessing  stipulated penalties for
noncompliance with settlement
milestone dates, limiting their
actons to verbal negotiations 01
warning letters, and only seeking
penalties in extreme cases.

• Region 1 was not adequately
monitoring Technical
Enforcement Support (TES)
contractors hired to oversee
PRP cleanups  by conducting
and documenting field and
contractor  office reviews and
quality assurance audits.

We Recommended That

The Regional Administrator,
Region 1:

• Develop guidance, with time
frames, for reviewing and
approving  PRPs' submissions
and ensuring their compliance
with submission schedules;

• Aggressively put sue penalties
when PRPs are in
noncompliance with settlement
requirements: and

• Establish procedures to ensur
that TES contractors' performar
receive periodic field oversight
reviews, quality assurance audi<
and office  reviews.

-------
The Regional Administrator,
Region 5:

• Instruct project managers to
timely review responsible party
submissions;

• Develop guidance on granting
extensions to due dates
established in enforcement
agreements; and

• Use dispute resolution and
penalties when responsible
parties do not comply with the
enforcement agreements.

What Action Was Taken

Audit reports (1100133 and
1100149) were issued to the
Regional Administrators, Region
1 and Region 5, on February 28,
1991, and March 29, 1991,
respectively. Responses are
due by May 29,  1991, and June
27, 1991, respectively.  In
responding to the draft reports,
the Regions described actions
being taken to address our
recommendations.
 Special And
 Early Warning
 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 reviews 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.
Single Audit Process
Needs Major
Improvements

Problem

EPA did not ensure timely
completion and receipt of
single audit reports as
required by OMB Circular A-
128, nor did it ensure that
prescribed corrective actions
were taken.

We Found That

The Grants Administration
Division (GAD) and the regional
grants administration staff are
responsible for identifying and
contacting grant recipients
required to have an audit and,
when EPA is the designated
cognizant agency, ensuring that
audits are performed and reports
are received in a timely manner.
However, unless Divisional
Inspector General staff pointed
out that audits had not been
received, the regions frequently
took no action to contact
nonreporting grant recipients.
The regbns also did not
consider imposing sanctions on
the nonreporting recipients.
  GAD is responsible for
reporting annually to the
Director, Office of Management
and Budget (OMB), each State
and local government or Indian
tribe which failed to comply with
OMB Circular A-128.  In fiscal
1990, GAD relied almost
exclusively on data provided by
the OIG for this report. Despite
OiG staff assistance, GAD did
not ensure that it was submitting
correct information to OMB
regarding nonreporting entities.
GAD took no action to secure
missing single audit reports  nor
did it report the nonreceipt of
most of these reports to OMB.
  The Agency has not ensured
that corrective actions have
been taken for single audit
monetary and nonmonetary
findings.  Regions were not
consistently tracking arid
monitoring single audit corrective
actions in the Agency's
Management Audit Tracking
System and Headquarters'
oversight of the system did not
detect or correct these
inconsistencies.
We Recommended That

The Director, Grants
Administration Division:

• Ensure that regional grants
administration staff identify,
contact and receive proper anc
timely audits from those
recipients over which  EPA has
been assigned cognizance;

• Ensure that Headquarters anc
regional staff have access to
and gather all essential data to
make a comprehensive annual
report to the Director,  OMB.

The Director, Resource
Management Division:

• Ensure that ongoing correctivf
actions reported in the regional
Federal Managers' Financial
Integrity Act assurance letters
are tracked and monitored in thf
Agency's internal control
corrective action tracking
system.

• Monitor and evaluate regional
tracking of nonmonetary findings
to promote consistency in
accordance with national
guidance.

What Action Was Taken

In his March 15, 1991, response
to the draft report, the Assistant
Administrator for Administration
and Resources Management
agreed with all our
recommendations and stated
that some corrective actions had
been taken or were underway.
The final report (1400013) was
issued on March 28, 1991.  A
response is due by June  27,
1991.

-------
Electrical Code
Violations Question
Safety At The
Environmental
Research Center
Problem

While violations of the
National Electrical Code found
at EPA's Environmental
Research Center  (ERC),
Research Triangle Park, North
Carolina, had been corrected,
most of the electrical systems
still had not been inspected
by local authorities, leaving
the facility's safety in
question.

We Found That

Electrical contractors complained
of EPA mismanagement and
unsafe conditions at ERC
stemming from work performed
without county permits under
two contracts for (1) renovating
the existing emergency power-
off system and installing
uninterruptabte power systems in
EPA's National Computer Center
and (2) providing additional
chiller and generator capacity for
animal facilities at ERC.
Electrical work at ERC
historically had not always been
conducted in accordance with
the local permitting and
inspection  requirements.
   EPA disputed the contractors'
cost claims after inspecting the
chiller project, resulting in the
subcontractor obtaining a permit
and having its work inspected by
the county. The county
inspection  noted 27 electrical
code violations.  The questioned
electrical work at the ERC had
been redone in accordance with
the Code, correcting all
deficiencies reported by the
county inspector. In addition,
some of the work done by
another subcontractor on the
same project was redone and
subsequently inspected by the
county.
  However, EPA estimated that
between 80 and 85 percent of
the electrical systems at ERC
(including parts of the National
Computer Center) had not been
inspected by county inspectors.
Based on the violations found by
the earlier inspection, similar
problems could exist in
uninspected areas that raise
doubt about the integrity of the
facilities and its equipment.

We Recommended That

The Assistant Administrator for
Administration and Resources
Management identify and correct
any problems in ERC's electrical
system.

What Action Was Taken

The special review report
(1400001) was issued to the
Assistant Administrator for
Administration and Resources
Management on November 26,
1990. In his  February 27,  1991,
response, the Assistant
Administrator advised us that
EPA had hired an electrical
engineer to conduct a
systematic review of ERC's
entire electrical system.
EPA Not Obtaining
Certifications That
Funds Were  Not
Improperly Used For
Lobbying

Problem

EPA did not require all
recipients of Federal grants,
loans, and contracts to certify
that the proceeds would not
be used for lobbying to
influence executive and
legislative decisions in
connection with their award.
As a result, EPA had no
assurance that  some
recipients were not using
federal funds for lobbying.

Background

In 1989, Congress passed the
Department of Interior and
Related Agencies Appropriations
Act (Public Law 101-121)
prohibiting the use of Federal
funds to pay for lobbying in
connection with the awarding of
grants, cooperative agreements,
contracts, loans, loan grantee
commitments, and loan
insurance commitments. Each
recipient of an EPA grant,
cooperative agreement or
contract exceeding $100,000
and bans exceeding $150,000
awarded on or after December
23,1989, must certify to EPA
that the Federal funds were not
used for lobbying.

We Found That

EPA did not obtain the required
certification from 58 of 203 (29
percent) of the awards sampled.
Our sample included EPA
Headquarters, Region 1, Region
3, and the EPA field offices in
Research Triangle Park (RTP)
and Cincinnati which awarded a
total of 305 grants, cooperative
agreements, contracts and loans
between December 23, 1989
and June 30,1990, requiring
certifications under the Act.
  The Agency did not obtain
certifications primarily because it
was processing many of the
applicable grants, contracts, and
bans when the requirement
became effective.  To prevent
recurrence, the Agency revised
its grant and loan application
packages to advise future
applicants for Federal
assistance.

We Recommended That

The Assistant Administrator for
Administration and Resources
Management ensure that
missing certifications are
obtained for all grants,
cooperative agreements,  loans
and contracts awarded by the
Agency after December 23,
1989.

What Action Was Taken

The Special Review Report
(1400004) was issued to  the
Assistant Administrator for
Administration and Resources
Management on January 14,
1991. A response due by April
15, 1991, had not been received
as of April 25.  In responding to
the draft report, the Assistant
Administrator agreed with the
audit recommendations and
stated that EPA was contacting
recepients to obtain missing
certifications.
 22

-------
Construction  Grant
Earl-v Warning
System
•dent'',
Legality And
Environmental Benefit
Of $8-1  Million S3rant
Amendment
Questioned!
Hegio-'i S's 4*;,= nulli •
amendment award hi
                                 :-'-o*iutk-r< Cannot A$je-'>c ;
                                 (MWPC'-.i rn.iv nave «/;ob,i-,
                                 er.t<;ri,.nfr)fliUaS statutes
                                 unmeet :-S-stH!),  !-1tre£.>«<'
                                 FPA'4 '.:-*«Cs thi;
                                 •iniiy -?  ,o.-;i fi.*- the
                                 •.>.;•.,; I'M .i ne? aLparen
* Violated gran! regulations by
al'owmg ^edera' funding for J'~!
percent of costs instead of the
reouir&d 5^ percent and
prcvding for ;n9lig;bte fesf-,/,
  '- irtf-er, the amen irntr.nf n;-
".j appaifi-.t enviroTTsental
Denem a-'i-:. it redu^Hl ttit1
     (^s financial .-c-mrPrti' <-;i
     !'''C,i'93S'nCj fri? **rri!V'S
                                •'.','-,5'.- Water 1*.,' =1!
                                                                                    ' vv. *
                                                                                    f\3
                                                                 g-'H'H ' ,'):<, •- ,-i io>i a ^?-v^:.Q;
EPA Improperly
Awarded $5.5 Million
Grant

Problem

Region  9 improperly awarded
a $5.5 million grant to the
Gualaia Community Services
District  (District), California, to
construct a wastewater
treatment facility,

We Found  That

Region 9 prematurely awarded ;
S5.5 million  grant to the District
on June 30, 198U  to meet the
California State Water
Resources Control Board's
.;SWRCB) deadline for funding
construction grants before EPA
ortased  out the program.
  At the time o! the award,
Hegion & and SWRCB knew the
site identified m the grant was
neither the best nor most cost
riffoctive and that the facility
would not be built there.  One
•/ear after 'She award, the  grantee
and Region 9 chose a different
site and  drfferent treatment and
disposal methods.  However, the
j.'anf was not amended when
flie treatment she was changed.
 5ver 20 months had elapsed
nines the grant award without
airstruction having been
siirted,  % o! January 1991.
-"'atunattXJ project costs had
.:>,'.,aiatec! Jo $8.7 million,
• o idmg the following
 ••-...w>.'SM'v $i,25 million:

•• fylOC 'J(Xi  of collection system
cGsro vv^icj; can be avoided if an
-tiffcTiai'- ?',stPrr' were adopted;

•" SJ'x..,X>.' o! -j soosai system
 , .:.s «/nioh. can be avoided if
--,c cic-w^ were modified; and

  '*"00 . '.X-  o1' protect costs
.,• h-,;|-. s'-j..:i:i oe txDrne by tne
.-lA-ner £.' -? golf .xDorsrt to lye
'Mj'e-j  >/  tfeatw effluent
                                                                 We
                                                                                                                    That
                                                                                                  Mv; -lecjic".j! AdnitiiStrator,
                                                                                                  Region 9, not allow construction
                                                                                                  »i start untji the Region (1)
                                                                                                  iletermines whetner the grantee
                                                                                                  should be nro\/id€Ki deviations
                                                                                                  "•orr FPA r-rigulations  thai

-------
require final plans, specifications,
and a project schedule be
completed and approved before
grant award; (2) assures grant
requirements have been met,
including amending the grant to
identify the chosen treatment
site and methods; and (3)
assesses all potential cost
savings.

What Action Was Taken

The special review report
(1400018) was issued on March
28, 1991.  A response to the
report is due by June 3, 1991.
Philadelphia Claims $6
Million of Ineligible
Costs

Problem

The City of Philadelphia,
Pennsylvania, claimed $5.2
million of costs previously
recovered from customers
and an additional $784,000
which should  be reimbursed
by the U.S. Navy.

Background

Region 3 awarded 35 grants,
totaling $618 million, to the City
of Philadelphia for constructing
wastewater facilities at the
Southwest, Southeast and
Northeast treatment plants.  The
Southeast plant receives
wastewater from the
Philadelphia Naval Shipyard, a
U.S. Navy facility. Sludge from
the  Southeast plant is
transported to the Southwest
plant for disposal.  EPA
guidance requires that a U.S.
Government facility pay a share
of project costs if its volume of
wastewater exceeds a threshold.

We Found That

The City claimed  reimbursement
of $5.2 million included in its
1986 through 1989 indirect costs
even though it  had previously
recovered those costs as direct
costs from its customers through
water and sewer  rates.  Also,
the  City had not recovered
$784,000 of Southwest
Treatment Plant project costs
from the U.S. Navy for treatment
of wastewater from the shipyard.
The City failed to recognize the
shipyard's wastewater volume
exceeded the cost sharing
threshold.

We Recommended That

The Regional Administrator,
Region 3, take prompt action to
preclude overpayment of eligible
costs.

What Action Was Taken

fleports (1400010 and 1400016)
were issued to the Regional
Administrator, Region 3,  on
March 8 and March 28,  1991,
respectively. Responses are
due by May 1, 1991, and May
15, 1991, respectively.

-------
   Section  2—Audit  Resolution
'j'i't::t. e\c\ ;-
:,-,;. UUi: (U-'Sfnres Sifji .ihCdnt
I I /Clt'l'i,^ 'i'RMMiOd ,f uf'-VCuS
.vT'.cinnua1 reports whir.r.
r"-«a n unresolved  Also, this
st-i-tior1 includes 
-------
Audit Foiiowup

The Inspector Genera! 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
semiannualty, in a separate
report to Congress, the
corrective actions taken in
response to the IG's audits.  The
Office of Inspector Genera!
reviews the Agency's followup
actions on selected audits.
Below are summaries of two cf
these reviews.

Improvements Still
Needed In The Great
Lakes National
Program Office

A September 1989 audit report
showed that the Great Lakes
National  Program Office
(GLNPO) needed to improve its
grant management procedures
and internal control mechanisms.
GLNPO has overall responsibility
to dean up and prevent further
pollution  of the Great Lakes.  To
accomplish its mandate, GLNPO
(1) funds grants to study Great
Lakes pollution problems and (2)
coordinates EPA, other Federal,
State and local government
agencies" Great Lakes research
and dean up efforts.
 Our followup report (1400015)
issued to the Regional
Administrator, Region 5, found
that GLNPO and Regbn 5 had
initiated actions to address most
of the findings and
         Six
reeommendaoons in our '!98=
report.  For example, GLKPO
and Region 5 deveic;>Ki a
Memorandum ot Understate:'-,
on grant monitoring
responsibilrtie.s as fecomi-ieii,!^d
in our prior rrfocrt, GLNPO a'so
created sevefai new forms to
strengthen controls over
proposa! processing until the
grants procedures manual is
revised. However, GLNPO and
Region 5 had not comolefed the
corrective acton necessary ko
address sever a! of oui 1989
recommendations  As a result
GLNPO still did not rave
adequate controls ovo^ the
review of proposed grants and
monitoring  of current grants.
 in some cases, the Correct)*;--
Acrtion Tracking System (CATS)
and Management Audit Tracking
System (MATS) showed the
GLNPO and Region 5
completed  a specific corrective
action when, in our opin'on, the
corrective action taken did not
fully address the findings of cu"
1989 report. As a result, CATS
and MATS gave EPA regional
and Headquarters management
the impression that GLNPO  and
Region 5 had completed route
corrective actions than found r-y
our followup 'eview. Since
issuance of our followup .-epo-,
GLNPO and Region 5 have
taken positive steps to aatiresr
all prior unresolved issues anc
the new issue  on tracking
corrective ac*iO'-,s,

A lighthouse- on on.' of the
Great Lakes,  the world's
largest body of fresh water
(photo courtesy Michigan
Travel Commission*
                                 ,
Despite Substantial
Progress In The Office
Of Enforcement's
Criminal Investigation
''rogs'am, improvements
  re Still  Needed

Oi • 8>-'ptembe.' >SW>8 au.rnt
ra^'ort incv»','ti 'rj' iPi/r
prior (jcommeridtitions regarding
oompl ance wrh investigative
standards.
  Although NEK., "eompnasu'pd
to its - peoiai aqents the  need to
noUid'3 specific irfoimaticn n
c&se  ipening repor»s, some
case opening rsv-cr'-;; still were
eiirer not prapai'jc1  or were not
prepared timev  In addition, OE.
had not yet irrpemented an
indent indent and formal
quality assurance program  We
recon mendecl shaf OE (1) stress
to NEC and trie Office 01
Criminal Investigations that
special agent; Vneiy prepare
and sjbmrt csse opening: reports
and ('.'i) establish a plan with
specitic milestone jates lo
develop ana ria3 a prograni
for porradic mdiiaoisment
itviO'..':; of ares.a oftioes.
  if. ri ;spcnd'.rig to our draft
repor, Ob aa-.oecrtk:
Status  Of
Management
Decisions On 1G
Audit Reports
Thi? section presents statistca!
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  tne costs
under required statistical tables
of sections 5(a)(8) and (9) erf 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 timo
ot the audrt unsupported by
adequate documentation or
records. Since auditees
frequently provide additional
documentation to support the
ailowability of such costs
subsequent to the audit, we
expect that a high proportion of
unsupporteo costs will not be
sustained.
  EPA OIG controlled audrs
resolved aunng this  period
resufted in $30.9 million being
sustained out of $39.4 million
considered ineligible in reports
under OIG control.   This results
in an 78 petcen! sustained rate;.
-------
Table I
Inspector General Issued Reports With Questioned Costs
                                                                  Dollar Value* (thounnds)
                                                                 Questioned* Unsupported
                                                          Number      Cost*       Costs
 A.  For which no management decision has been made by the      125   $224,273      $ 84,383
 commencement of the reporting period
 8.  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
 (u) Dollar value of costs not disallowed
 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         52    114,755        38,847
 six months of issuance
 Semiannual Period Ending 3/31 91
 'Questioned costs include the unsupported costs.
"On 9 audits management did not sustain any of the $1,733,010 questioned costs. Forty-six audits included are
also included in C(ii) because they were only partially sustained. Only the costs questioned that were not in
C(i) sustained are included in this category.
107
232
88
79
55"
144
92,486
316,759
111,839
61,521
50,318
204,919
54,470
138,853
46,419
5,351
41,068
92,434
 Table II
 Inspector General Issued Reports With
 Recommendations That Funds Be Put To Better Use
                                                                      Dollar Value
                                                           Number   (in thousand*)
 A  For which no management decision has been made by the        68        $164,206
 commencement of the reporting period
 B.  Which were Issued during the reporting period                   22          40,019
 Subtotals (A + B)                                                90         204,225
 C  For which a management decision was made during the          66         147,694
 reporting period
 (i)   Dollar value of recommendations that were agreed               25*          63,482
 to by management
 - based on proposed management action                         n/a             n/a
 • based on proposed legislative action                             n/a             n/a
 (u) Dollar value of costs not disallowed                             16*           7,144
 (iii) Dollar value of non-a'vards or unsuccessful bidders               32          77,069**
 D.  For which no management decision has been made by           24          56,531
 the end of the reporting period
 Reports for which no management decision was made               8          17,744
 within six  months of issuance
 Semiannual period ending 3/31/91
    "Seven of the audits were the same audits in Herns 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.
-------
Resolution of Significant Audits
Report Number/
Report Date
Grantee/
Contractor
Report Issuance
FS Questioned/
Recommended
Efficiency
Report Resolution
    Federal Share
 to be Recovered/
        Sustained
        Efficiency
                                                          Resolution of Significant Audits-
D3AMLO-03-02J5
Q1CO?34
REPORT DATE
4/26'90

DSAMLO 03-0278
01C0329
REPORT DATE
5/24/90
                  AUPURN  NY
                 NASSAU CO  NY
UNISYS CORPORATION
VA
Report Number/
Report Dete
Grantee/
Contractor
Report Issuance
FS Questioned/
Recommended
Efficiency
Report Resolution
    Federal Share
 to be Recovered/
        Sustained
        Efficiency
                                                           D8AMLO 06-0212
                                                           0100360
                                                           REPORT DATE
                                                           6/26/90

                                                           L2CWN9-OI) 0031
                                                           0300043
                                                           REPORT DATE
                                                           4/12/90

                                                           L2CWN9 Oii 0160
                                                           0300017
                                                           REPORT DAJE
                                                           12/26/89
                                                                                                                iNEL       $  0
                                                                                                                UNSP         0
                                                                                                                UNUR         0
                                                                                                                ROOM  1 254 955
                                                                                            INEI
                                                                                            UNSP
                                                                                            UNUR
                                                                                            SUST

                                                                                            INEL
                                                                                            UNSP
                                                                                            UNUR
                                                                                            SUS~

                                                                                            INEL
                                                                                            UNSP
                                                                                            UNUR
                                                                                            SUST

                                                                                            INEL
                                                                                            UNSP
                                                                                            UNUR
                                                                                            SUST
                                                                                                                                              5!  0
                                                                                                                INEL    954,454
                                                                                                                UNSP 23,410399
                                                                                                                UNUR    63 360
                                                                                                                RCOM        0
                                                                                                                          954,454

                                                                                                                           63,36C
P2CWF 03-0049
0100231
REPORT DATE
3/29/90
DELAWARE SOl ID
WASTE AUIH  DE
                 HAMPTON RDS
                 SANITATION  VA
                                                                                                                INEI
                                                                                                                UNSP
                                                                                                                UNUR
                                                                                                                SUST
                                                                                                        5,018
                                                                                                           0
                                                                                                      779,692
                                                                                                           0
                 CHAHlfcS CO
                 COMMISSIONERS  MD
                                                                                     !NF;lGIBL[  :OC-[
                                                                                      LINSUPPOPiEU COST
                                                                                    -  UNNECESSARY/UNfirASONA^'J, COST
                                                                                    --  RECOMMtNDFD EFHCENCilS
                                                                                      RECOMMENDED EFF!C![NCi!S SjSTA^J
-------
               in     C:
    IRISM
Ti
-------
Description Of
Selected
Prosecytive
Actions
Below is a brief description of
some of the prosecutive actions
which occurred during the
reporting period.  Some of tiiese
actions resulted from
investigations imtiate-d before
October 7,  1990,
Superfund Contract
Laboratory Program
investigate*

Trie Ofticf ct 'fKe&tigaiors h >•.•
a major invesSgative initiate
underway witivn f•,<"•• Superfund
program. ^rooted a' ;raud IP. the
Contract Laboratory '""ograrn
(CLP).  Laboratory  analyse.;
under the CL.P arc-  the smp'MCt!
bcisis for fie '->ntre  Supehurd
program. Based >;>n Besting tor
the presence of h;:jarc!ous
cremicais by these ic.boratorn'!-
the Superfunc program decide,'
which cleanups to initiate and
how to carry them out
Fraudulent analyses aiulc r«i.!t
in a danger re trie pu )'ic Ke?rh
and safety as we-i as the
unnecessary ''/oend;ti;.» ;,;
cleanup funds, h dc'j'tir.r
frauduient ar>aly>A ooukl hinder
trie Departme.it of jioi'O!v.
eftorts to collect the cost of
cleanups frorr tj-ifs 'e'.ponsib'e
pe;rties.
 The followiny f've  actons
resulted from che con Tact lab
investigations

Missouri  Lab Charged
with False Test Data

Metatrace, inc., Earth City.
Missouri, and two of i:s former
officers, Dr. Carol Byiiigton,
Executive Vice Presiceit and
Kenneth Baughman, Vice
President, have pled guilty to
submitting false statements to
EPA under the CLP.  It &
alleged that the pestick't
analysis for  certain EPA
samples were not performed 11
compliance with the piotocol
required undo  the EF;A c«ntra'. t
Specifically, laDoratory oersoiirv;!
alleged!/ manipulated rosi:< .'Jieck standaicls:
so that the1,, si .c-wed t^at a
group of er;v'i'r,r pienM oa.nipie
results were  ':ii!y .compliant VMlh
protocol criteria wnon ^ ?act.
they we: a r-o>
Tenting  Eq
AS'egedly Not
Calibrated
rnanagei of the Gas
Ch'-orn itovj; apn,?/ "i';.<
Spoi-b K )metor [> 1; C • f * S;
latK'jrat>>' ai E4L Corporation
(nov.  kiov> S3 r -'i -\.Norc4ii),
RichtTrtind. Oalitjr^ia, was
indscf&c1 •:>>< */1cift.J- 2£,  1991.
Siring, '.rpi.:*! .". . jiwjad to haje
dirwic i 8rnpi,:.y>-.f.s a* EAL u.
poifof!-", GC'MS •)•'? lySfis of
sampk-s wt-'ici.i ;i,v Suniog a.'iJ
cahb-ai ng no C'.,?'. •;
equurr o.^; is r.. :j. i'-:d b> it>e
rAL a ntr<-'Ct A r '  . . i-"1 ^ .
Sr.'.r.c),;'-:..''-- T  ' - ;: : k: ha^o
d!s • Jnec'e'l G '..'''  '.; r.f-eratu s
to :'-v>^>l '.\~i-k'    : p .:. >j;; ;iy
gei)C'!r=, ea r^r.i- ^ . •••:;:, M- tht
data if w, .w  :-"•; •-;•- part o1
ttie oo<'u"f>.rr.--r.i:r "  :•' - -0 .' OG

Calif ornja Lab
Backdated  Analyses

in s''C!: i.; : Taue •: ^V'^ing fraud
aric ac-..;.e vi'ithn EIPAs Cont'aa
Latx/ra'.ory Program •jix former
er!,ph,'"Hjs of tiie Mnvironmerital
Chorni'-tr/ Labor '-it- ji) of tiie
Sa »-r,u • AppliCiC, jni;
Inifirnational Corpcranon (SA:Ci,
L- j )llr.. Cnliforma  Vve piea
guilty tt  charges o1' miking fals«
st tieTif'nts to EPA, aiding and
uw&ni . tna mak: sg of false
,.'.-;; env-.nts to EPA. and aidir.g
'):•:' absjtting the corvers.-'i.'t c'
•fi yorpTient rno'Viy ijAit"
GCI L'-ac.ed with EP/> -o p-^lor'T
u- si"  »•. or. samp es MKOT frcm
£ .:j:i it; iid tovc s,a', i"c  srtf,s in
o :>i t.  (1  dftt>-rinf the
were assessed for lateness  In
addition the contreict required
that sample analysis equipment
be timed and calibrated every
twelve hours to insure accuracy.
"•"he pint investigation by the
EPA OIG and the FBI
uncovered that backdating of
sample test result; occurred in
order to avoid the penalty. Also,
the manipulation  of the sample
analysis equipment test data
was performed to fraudulently
reflect the accuracy of analysis
equipment.

Duo Allegedly
Provided Dirty Test
Containers

Anita C. Rudd, Marvin W. Rudd,
and I-CHEM Research, Inc. of
Hayward, California, were
indicted November 30, 1990, by
a Federal grand  jury on charges
of conspiring to make false
claims to EPA,  Marvin Rudd is
also charged with one count of
using false documents.
  From June 1985: until
December 1987, I-CHEM was
EPA's sole supplier for
contaminant-free sample
containers used  to collect site
samples for analysis and
evaluation by the Contract
Laboratory  Program.  The
indictment charges that I-CHEM
and the Rudds conspired to
make false claims to EPA for
providing contaminant-free
sample containers under
contract. It is alleged that I-
CHEM shipped sample
containers to authorized EPA
requesters without actually
performing the required quality
control testing  on the containers,
notwithstanding certifications; by
I-CHEM to that effect.
                                                                  a;"v. LF ", i '-"A  " vJ,r-::d t,at
                                                                  vciatie ."''d-ii'ii'-1 -/"j.'iSfrs ho
                                                                        ,tKJ *':th'i.  ;• .:>a\ :,,  in
                                                                  v»',u;kl i o' d" ; if. :•  -vnniticj;
-------
Connecticut Company
Backdated Results,
Used Unapproved Lab

A Connecticut company, VWC
hr , pied guilty in December
 > -*90 to two charges of making
Ljise statements to EPA and
,v=,s fined $500,000,  EPA's
.o >t? ad with YWC require
i,1 imp to anaiyze water samples
/.-.thin seven days of receipt and
v:;;i sao'-ptes vfvrthin 1 0 days.
Y.vC'i.  t'oik Laboratories
, }iv's:on facility in Monroe,
•" -.v-.ecticut, was an  approved
GI. p site. YWC was charged
ft in. backdating over 60
      es and using a then-
        ved laboratory at
        y.  New .Jersey, to do
Other Cases

Aiaskan Charged in
Samoan Forgery Case

Wcnaln Campteii of Palmer,
Alaska, has been indicted  n
F«oerai court for making a
fraudulent demand for payment.
C.rnpbeil was the project
sijuervisor for the Paia Lapcxjn
VWstewater Pioje-.Tt in Amt-noan
Samoa  He worked for S&S
Contractors <",f Hawaii, the
primary oontractor on this CpA-
fi">clef< r^oiect  After the deatf-
of tiio Amer-ra" Samoa
.^•vef.^ients p'&ect officer ,
-'" d'npheSi allegedly created
acoepto'xs documents, b^a'ing
tc.i gad Signatures of the
         r?rojar4 officer,
         that unfinished
                      h
      siinpierrv1 anc tested
      :n fact sne jij.selinp -.v
      "* wEth so*! r"9*ompietw.
 --.  i **-:, in -V-^'ifsna: $'' " ^ 8^4
'I  .'"U'lM-i !f 'i •'". SDitT^f? flP $^.8
          etfv;  i-;ecai:sb S&S
 KI-: cw:Ja/e<"; Dfn'isrupio/, fPA
vw-r- !o. »<: tc boar ttv-. =i atto-ney
q,:. --i — " •* ' ''V- - ar Si'^oa
Fraud Charged in
Texas Telemarketing
Scheme

In March, 18 individuals
associated with NAC Marketing
were indicted in Dallas on a total
of 55 counts of mail fraud.  To
improve their sales prospects,
NAC falsely claimed that ft:-
Paragon water filtration unit.
designed for home use, was
EPA "approved."  NAC sold the
unit, which has an actual value
of approximately $30, over ihe
phone for $429.00. In  f"ost
instances, customer requests for
refunds were denied by NAC.
  As part of their sales  efforts
NAC also falsely claimed that
EPA had sponsored a  bill in the
U.S House of Representatives
which wouki require ail homes to
be equipped with a watei
filtration system by June 1990
  These indictments resulted
from a joint investigation by the
EPA DIG and the U.S  Postal
Service.

North Carolina  Sewage
Plant Operator
Allegedly Tampered
with Lab Results

in January, Jarnes Timberiake of
Louisburg, North Carolina, was
indicted on 38 counts of
submitting false; statements
under the Ciean Water Act, and
sever counts of mail fraud.
Prior to April 1990, »vhen he
went out of business,
^iir.beriake served as the
operator and/or arranged for
laboratory testing of wastewater
effluent for over 30 NoMts
Casolina treatment tacihfiej.
operating undei National
Pollutant Discharge Elimination
System 'NPDES) permits
Results of the lab tests were
submitted through  his clients to
Die North Carolina Division of
Environmental Management.
which administers  NPDES
permits for I: PA in the State. It
is alleged that much of the  data
supplied by "Hmberiake was
fab< seated or altered from original
lab test results.   Many of his
clients were public facilities and
O!
-------
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.
EPA Environmental
Engineer Perjures Self
in Court

An EPA environmental engineer
has pled guilty to one count of
perjury. White appearing in
Federal Court as an expert
witness for EPA in May 1990,
the employee testified that she
had received a Ph.D. in Civil
Engineering from a state
university when, in fact, she had
not

Former  Employee
Convicted of Forgery

A former EPA employee was
convicted of forgery in a county
circuit court in October 1990,
after an EPA OIG investigation
revealed that she had altered
the amount of an EPA paycheck
to increase its value from
$274.93 to $874.93. The altered
check was recovered by EPA.
Upon conviction, the employee
was sentenced to serve two
years probation and to make
restitution to EPA for a $250.00
outstanding advance obtained
when the individual reported
non-receipt of another paycheck
in January  1990. The employee
was terminated in June 1990 for
excessive absences while in a
probationary status.

Travel Voucher Fraud
Uncovered

An employee at EPA
Headquarters and his supervisor
requested that the OIG
investigate  a clerical employee
for adding false trips to several
vouchers of the complainant.
After the OIG interviewed the
clerk, she resigned.  OIG
investigators found that the
underlying vouchers of the
complainant were totally false,
and that the supervisor had
given the complainant a private
letter of warning which did not
require repayment of the false
claim. As a result of the OIG
investigation, the supervisor was
issued a formal letter of
reprimand. The complainant,
who left the Agency, was
required to repay the proceeds
of his false vouchers.
Civil And
Administrative
Actions To
Recover  EPA
Funds
Investigations and audits
conducted by the 'Office of
Inspector General provide the
basis for civil and administrative
actions to recover funds
fraudulently obtained from EPA.
Through the Inspector General
Division of the Office of General
Counsel, the OIG uses a variety
of tools to obtain restitution.
These include cooperative
efforts with the Department of
Justice in filing civil suits under
the False Claims Act, the
Program Fraud Civil Remedies
Act, and other authorities;
working with grantees using their
own civil litigation authorities;
invoking the restitution provisions
of the Victim and Witness
Protection Act during criminal
sentencing; using the Agency's
authority to administratively
offset future payments and to
collect debts; and negotiating
voluntary settlements providing
for restitution in the context of
suspension and debarment
actions. Civil and administrative
actions to recover funds usually
extend  over severai semiannual
reporting periods.

Settlement Reached
with Laboratory
Corporation

On December 5, 1990, YWC
Inc., of  Monroe, Connecticut,
entered into a global settlement
with EPA to resolve issues
raised by OIG's investigation into
fraud involving Contract
Laboratory Program work at two
of its laboratories (see story on
page 31.)  In addition to
pleading guilty to backdating
samples, and paying a $500,000
fine, YWC also entered into a
civil and administrative
settlement. Undei the civil
settlement, YWC agreed to pay
EPA $150,000 in damages for
the defective samples.  In the
administrative settlement, YWC
agreed that the two laboratories
involved in the fraud, located in
Monroe, Connecticut, and
Whippany, New Jersey, would
not take on further Government-
financed work. YWC's
laboratories were sold on
December 7,1990. The
purchaser has implemented a
compliance program designed to
assure that the abuses of the
past do not recur.

Electrical Contractor
Pays $2.9 Million for
Rigging  Bids

In March 1991, Fischbach &
Moore, an electrical contractor,
paid the United States $2.9
million to settle two civil cases
involving bid rigging on EPA-
funded wastewater treatment
projects. Of the total, $2.24
million was attributed to
Fischbach's role in rigging the
bid for expanding the Moccasin
Bend plant in Chattanooga,
Tennessee, and $600,000 was
attributed to the company's rote
in rigging the bid on the
Snapfinger Creek plant in
DeKalb County, Georgia.  Both
the Moccasin Bend suit and the
Snapfinger suit were brought in
the wake of criminal antitrust
convictions several years ago.
  The bid rigging conspiracies of
the electrical subcontractors
raised the cost of the Moccas;in
Bend plant by $778,000 and
raised the cost of the Snapfinger
plant by more than $1  million,
The United States has already
recovered $440,000 from other
defendants in the Snapfinger
litigation and $246,325 from
other defendants in the
Moccasin Bend litigation.
-------
•»!*>'.• S O'
                       il' "K
"x.-'Ttomy arse 'fP^i:>s-r:',,t >s section includes
information reouired  by
statute, recommended by
Senate report, or deemed
appropriate by tne inspector
General.
                                               A?M.
                                      / Avf o/ iS7n. j^
                                      ti, directs S^e O#;c<  .;
                                      r General to rei'/e-vc
                               existing and proposed  0,"'.\i  -'^s
jj!i.-,'X5sor; 3rjf!it!/,-na!  tx.lton line"
wrf-i 'he "Jollar '.'a'u*1 of
recompile! dat»oi;s aduaily
implementitd during the period
adds furthei oo? .fusion tc the IG
repo^ng ni\ auniis issued during
the period  Second, we did not
agree that the Inspector General
anc management tracking
systems should be combined
into a single system. Third, we
did not agree wrth a
recommendation  that a
consolidated IG and Agency
report would be helpful. At
present, the IGs and the
agencies concurrently report to
Congress only  She rtems for
which they are  responsible in the
areas of audit resolution and
implementation. Although the
tracking systems  are linked, the
differences in these separate
reports preclude a simple
consolidation and the elimination
of either report  since both the
IGs and management officials
would still have to report on
those items thai could not be
consolidated. Foudh. we did not
agree with the recommendation
to eniaige the scope of the IG
and Management reports to
reflect "non-cost"
recommendations in additional
tables for data on revenue
enhancements  or non-dollar
recommendations. Fifth, we did
not agree that IGs should report
on individual audit
recommendations. There is no
evidence that tracking individual
recommendations rather than
entire audit reports would result
in increased attention  to audit
resolution.
                                  :M  ; •"-. i'* s'jtt.. ,-*!,;;- 1 1 .-a,-/
                                  '.v:: Ctf- oiJpou.' :>! *•*-, CFC Act
                                  .. J .5*? ••(;-. aiiy ; • ;):o,,e ">: aiH""-?!
                                                                                                               ot at.'.ri:rrt> u-
                                                                                                           fta1 to ensure that the CFC
                                                                                                     wi!! be awe to cany out his or
                                                                                                     he' dudes.
                                                                                                       We supporter: the guidance
                                                                                                     recxjmmendatkin that (at a
                                                                                                     minimum) the CFC should have
                                                                                                     authority, for both the Agency
                                                                                                     and rts component parts, to:

                                                                                                     — Establish effective financial
                                                                                                     management policies and
                                                                                                     internal controls;

                                                                                                     — Ensure  adequate systems to
                                                                                                     produce useful; reliable and
                                                                                                     timely financial and related
                                                                                                     programmatic information;

                                                                                                     — Develop useful financial
                                                                                                     analysis and performance
                                                                                                     reports;

                                                                                                     — Integrate budget execution
                                                                                                     and accounting functions;

                                                                                                     — Ensure  high quality in
                                                                                                     financial management personnel

                                                                                                     OMB plans to complete its
                                                                                                     approval process of the
                                                                                                     organizational plans by May 1 ,
                                                                                                     1991.
-------
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 further 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 sfafufes relating to the
submission of offers;

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

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

  A contractor may also be
debarred for violating the terms
of a government contract or
subcontract, such as willful
failure to perform in accordance
with the terms of one or more
contracts, or a history of failure
to perform, or of unsatisfactory
performance on one or more
contracts.  A contractor may
also be debarred for any other
cause of so serious or
compelling a nature that it
affects the present responsibility
of the contractor.  Thus, a
contractor need not have
committed fraud or be convicted
of an offense to warrant being
debarred.  Determents 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 tor 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 deoarhng
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;


             October 1,1990 to
                March 31,1991

Cases on hand at beginning
of period                  235

Cases Ojpened during period  86
Subtotal                   321

Cases completed:

• Suspensions               25

• Debarnents               43

* Settlements                22
Subtotal S&D action           90

Closed after investigation      50
Total cas.es closesd

Active cases as of
March 31, 1991

• Under OIG investigation

• Under prograrr jeview

• Under OGC review

« Proposed for debarment
Total active cases
'40
181
     The following are several
     examples of suspension and
     debarment actions

     Asbestos Removal Related
     Cases

     EPA's concerted efforts are
     continuing to eliminate unethical
     asoestos removal contractors
     from doing business with the
     Government. These unlawful
     activities could adversely affect
     the? public's health.  Since poorly
     performed asbestos abatement
     projects put  at risk the health
     and welfare  of the public, EPA
     has continued to focus on
     eliminating unethical asbestos
     contractors from doing business
     with the GovernmefV.

     EPA debarred Saivator Russo
     and his affiliate New York
     company, &, Russo Equipment
     Company, inc., for 15 months,
     based upon his conviction in
     U.S. District  Court of willfully and
     knowingly bribing an EPA
     asbestos inspector.
      Mitchell Kurzban, president ot
      Kurzban, Benjamin and Son.
      Inc., also known as Kurzco
 15   Construction Company (KBS),
      Brooklyn. New York, was
119   convicted in March 1989, on iwo
      counts of bribing an EPA
 ', 2   asbestos inspector.  Kurzban
      was placed or probation and
 35   fined $200,000, EFA
      immediately suspended the
      respondents  in October 1990
      EPA entered into a compliance
      agreement with KBS and
      Kurzban, who agreed to be
      debarred through  "ebruary
      1992, and comply with all terms
      of the agreement.

      John Vittiglio and Bernaru Tu iy
      were convicted on one count of
      giving an iliegai bribe to an E^A
      asbestos inspector.  Tully was
      default debarred for Ihree years.
      His former employer, John
      Grace. & Company, entered  into
      a compliance agreement with
      EPA. Vittiglio was debarred
      through January 1, 1992

      invirex Demolition, Inc ,  New
      York (IDI, New York); Edward
      Brown; Lanza L Schwali; Invrex
      Demolition  Inc., Texas (!DI.
-------
Texas); I.D. Equipment Co.,
!)'t (iDE); and Envsrex
-  ' -/(ronmental Co>-a (EEC} were
suspended in May 1990, aftet
Srown's and Schwa'ii's
convictions on one count of
o-'ibing an EPA asa?Mdied between the EPA ar.j
Uk:- respondents  ID!, N Y.
B-own;  Schwall; IDE, and EFv- ,
A;\> agreed to be debarred
tt rough September i, 1992.
t ;:"A withdrew its suspense* -
a-'d proposed debarnent
a^asnst  ID!,  Texas in excha? • •-
*',•> concessicn.s to trie
Other FPA Case
 •erome &ro«vn, preside- 1, of '.  l\
Brck Corp. (USBC), Brooklyn
x. v , and an officer of Atlantic;
..t-'nolitior., Inc. (ADI! was
 . viViCted ot bribing an asbe::i  ;;.
ipsr^ctor  Ail 'espondents w-'i*
>,.spi-,oded by EPA, and USfC
A as debar i ed for 3 years.
,.,,!<:,me Brown and AD! signt-d
;.<.; uptonce agteement with i- >•"' '
ar-u agrewd to be debarred i. -t-l
           30, 1991. ft.i'n nl:
     3ig<*!' tirio "  'j 'r-'.'-vS
     dctii.g TIC., we1-;
     dnden  Fh-'A inspec.'cr
C herp-te irtvironrnentai
J'.i.'rvi.j&v. iiv,, a ""exas firm, was
'he c^>A cjrie'gor .:>'
                                    'r RcS; i'.)ne oun'r^ctor for
                                    >.ine ? '.hc'^ec .'•"T 'tit-
                                    -ri,-,Dor.s!b!!i1\ o? if-rf fto'sraju of
                                    .'((••xi"- siif- IP Laxii'gtOd.
                                                   ci ;»i .u'Sy t989.
                                    r-;..: ;  i-'\ -iuspendeo mo
                                      ••-•;,>if.v T April 'iiQOi
OIG
Management
initiatives
                                    : nis section identifies iwo new
                                    isfbatives by the Office of
                                    inspector General to promote
                                    "lanagemen* and financial
                                    improvements arid integrity m
                                    ~. PA s operations

                                    OsCi improves Contract Audit
                                    Program

                                    -, iij-.ja< 1'j&0 Sic U S
                                    ;: MMro'imt nia! P.oiecC  ••.
                                    •\jer;cv' pnx^ssed 8.CMJ
                                    vift;act actions cbiiga^rio riors
                                    " an $*i t'lliioo  EPA re'i!«s C'i i
                                    if"-* wc>rk Deing pcirforrii«: ui.i'yi
                                    i GOC1 contracts to assi:-' in
                                    Dairying out its mission,  Muvi ot
                                    rfie»t' contractors perfo'-'r hg'iiy
                                    •-•» ':rr iicai work in such irea.-. j-~
                                    -is-jarcri and Oet/dopr.o,it,
                                    1 ,v wdout: waste i'j  /f.'   '
                                    •,ia' 'cjafcis seftns.
                                     T'Cieiy financia1 audi;" o*
                                    xo-icts is a pro'olenn -tnjK.iini,
                                     • jnerous Peder.-.i  age-'' "?«*-."•;
                                    •••sT'^jaliy most o' l:f •••.
                                     s«r' j3r:t a^cit.; wt'io (j< "!oi'i )-'ii
                                       '••-; Detense Contra  -. PI-I';;
                                     ,i  !•{,%• {i.K,AA;  With -ie
                                    •<.,- ;' r-uii growth cit 'Ji
                                                                          o, .ere? di-ci noi tiftet- -'Ha: 3-vl
                                                                          .MA • a.'iiSity -c «iia .  ;
    piiaii-5e ays Hen '•(-,'•' .in
     v-  If; j>3 oeCcl'li'd '•)!
                                                                           V; i"r!iri*rit and (;:,(•" .-,d;.
                                                                            i v.jtr-rien) D'V!i.k.-n  -^CK'C i
                                                                                                              V; -<-x! ')'> BIS "I. INK i-  \» ".
                                                                                                            v  c.inci!>. tf •; CiG 'las =dur, :^.fii
                                                                                                            >'  l:,o!!f rilO|6<,1 tO tiXpCinO  I1':
                                                                                                            "' 'iici-'C audit proLjran' '•&'•', t, .:•
                                                                                                            ".'."-.«' a-iU (.»ntre..^ •""••• •~\w-,:>ic>i
                                                                                                            •n'oih, df«>untants (ir--- , . V^CI.K^
                                                                                                            •x  ,'• : i'.f'ti 't'E, ro!a'J'3!'j:,i.ii-'  A-I"
                                                                                                            v'  ."•>•   'iiiv.jtly fr-e ;> .1 ilj.-it'c
                                                                                                            •- • ^ii.-f.tirf; ihe ai,'i1«i vv nKiOf ;  -t
                                                                                                            i--, ;-r?  nt tlie AenrA/'s ! i-qrib! ' I-
-------
contractors in 4 of 6 OIG field
divisional offices and had begun
coordinating with DCM for EPA
to assume audit responsibility for
7 of EPA's largest contractors.
Work in the remaining divisional
offices will soon be completed.
 Also, efforts continue to
strengthen the OIG's capability
to manage and oversee audit
and investigative efforts related
to EPA contractors. Initially the
Office of Audit added former
DCAA and experienced OIG
auditors to its management staff
to oversee the planning and
implementation of expanded
contract audit activities.  These
individuals are overseeing the
development of  audit guides and
training to upgrade the capability
of OIG and IPA  audit staff to
perform the contract audits.
Additionally, the OIG has
assigned responsibility for
overseeing and  coordinating
audits and investigations of each
of ttie Agency's  top 25
contractors to a single OIG field
division  to ensure coordination of
all OIG efforts with respect to a
contractor.
 We will also expand our efforts
to coordinate financial audits of
contract costs with internal
audits of EPA's  procurement,
contract administration, and
management Such audits help
to ensure that contracts are tet
competitively and that contract
provisions were included to
adequately protect the public
interest Similarly, audits of
Agency  contract management
and administration help ensure
that contracts are being used
properly to perform needed
tasks within the  scope of the
contract and applicable Federal
requirements. Since recent OIG
audits have continued to show
major problems in these areas,
expanded efforts are essential.
By linking these efforts with
financial audits, the OIG can
better demonstrate the effect of
Agency  weaknesses and make
recommendations to help EPA
ensure that contracts and
contract resources are used in
an efficient effective, and
economical manner.
OIG Works With
Agency To Implement
Chief Financial Officer
Legislation

The Chief Financial Officers
(CFO) Act was recently enacted
to bring about much needed
improvements in Federal
financial management  The OIG
has always placed a high priority
on working with EPA to improve
financial management  During
fiscal 1991, financial
management was selected as
an area where comprehensive
audit work would be performed.
The CFO Act provides  another
mechanism the OIG and EPA
will use to promote
improvements in financial
systems and internal controls in
order to deter fraud, waste and
abuse, and to develop  useful
financial information for
evaluating programs and making
management decisions.
  The Act places increased
responsibilities  on the OIG and
Agency financial managers for
improving the Agency's financial
management systems and
internal controls. Specifically.
the OIG is responsible  for
performing annual audits of
Agency trust funds, revolving
funds and commercial activities.
To deal with  the new
requirements for the OIG to
perform audits of the Agency's
financial statements, as well as
to assist the  Agency in
implementing the Act, the OIG's
Office of Audit moved quickly to
establish an  OIG Task  Force.
  The Task Force is working
closely with Agency officials in
setting up an effective CFO
organization  with the prerequisite
authority and responsibilities
necessary to improve financial
management.  To date, the Task
Force has actively worked with
the Agency and the Office of
Management and Budget (OMB)
in developing the reorganization
proposal required by the Act
The proposal included  a
description of the functions,
powers and duties of the CFO.
The proposal has resulted in the
need for changes in a  number of
Agency-wide delegations in
order to provide the CFO with
the additional authorities and
responsibilities required by the
Act  The Task Force also
worked with the Agency's
Financial Management Division
in identifying the trust funds,
revolving funds and commercial
activities subject to audit.
 The Agency has requested a
waiver from preparing fiscal
1991 statements. If OMB grants
the waiver, the first year that the
Agency would produce audited
financial statements would be
fiscal 1992.  In the interim, the
Office of Audit will be performing
an auditability study to assist the
Agency in improving its systems
and processes for developing
financial statements.  Other
projects the Task Force will be
working on with  the Agency
include development of: (1) cost
accounting information to
support program managers,
OMB, Congress and others; (2)
meaningful performance
indicators that can be used to
measure the cost and
effectiveness of  programs; and
(3) qualifications and
performance standards, as well
as training requirements, for
senior financial management
personnel.
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 white most EPA
employees, grantees, and
contractors are conscientious
about the economy, efficiency,
and effectiveness of their work,
they have littte 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 team  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 strictiy  arm's-
tength 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 is 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

wlicnael Fitzsimmons, Office of
investigations, represented  EPA
at the Curriculum Review
Conference held in March at the
Federal Law Enforcement
Training Center (FLETC),
Giynco, Georgia. The
Conference examined all
aspects and recommended
improvements to the basic
course offered  at FLETC for
investigators assigned to offices
of inspectors general.
  John Walsh, Office of Audit,
discussed OiG policy for auditing
the Clean Water Act's State
Revolving Fund (SRF) at the
New England Intergovernmentai
Audit Forum in January  1991.
Mr. Walsh addressed the unique
nature of the SRF, the OIG's
audit history, the relationship of
the Single Audit Act and the
SRP audit requirement, as weil
as current issues involving  SRF
audits.
  David Tanner, Office of Audit,
gave a presentation in January
1991 on "How to Survive an
CHG Audit" at the annual
Superfund Contract Operations
and Review Staff Forum,
attended by Agency regional
and Headquarters staff involved
with Superfund's contracting
program.

Semiannual Report

Over 1,600 copies of each
semiannual report to Congress
aie  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,
EPA libraries, and selected
environmental groups,

IG Highlights for Fiscal 1990

A digest version of our two
semiannual reports to Congress
for Fiscal 1990 was produced
and distributed to all EPA
employees  in February.  IG
Highlights provides information
about statutory duties,
authorities, and independent
status of the Office of Inspector
Generai  :t presents a summary
of signifcan? activities of the
Office of inspf-rf-i:  C-eneral,
including problems, deficiencies,
recommendations, and
prosecutive and administrative
actions reported to EPA
management and Congress,  IG
Highlights includes an
organizational chart of the OIG
along with telephone numbers of
the Divisional Inspectors Genera!
and the OIG Hotline.
Personnel
Security Program
The personnel security program
is one of the Agency's first-line
defenses against fraud.  The
program uses background
investigations and National
Agency Checks and Inquiries to
review the integrity of EPA
employees and contractors.
 During this semiannual
reporting period, the Personnel
Security Staff reviewed 350
investigations.  The following
administrative actions were
taken, based on the conditions
identified during these reviews

* 1 employee was referred for
administrative action based on a
history  of arrests for substance
abuse.   This person resigned
while our referral was pending.

» 1 employee received a tetter of
caution for failure to list prior
drug usage on the Questionnaire
tor Sensitive Position.

• 1 contractor employee was
terminated for falsifying the
SF-86.  The contractor
employee  did not list a previous
termination.

• 1 employee received a written
reprimand for falsifying the
SF-171  by not listing a
conviction for credit card fraud

• 1 employee was terminated for
falsrfying the SF-171 by not
listing a conviction for
fraudulently changing
prescriptions.

« 2 employees received 14-day
suspensions for falsrfying the
SF~171s that they used to gain
employment with EPA,  One did
not list  a felony conviction, and
the other failed to identify
terminations by previous
employers.

 We continue  working closely
with Agency program officials on
the implementation of the OPM
regulations regarding position
sensitivity  designations and
security clearance grants.
 We are also entering
information into an operational
computer system which provides
management reports on the
status of ongoing investigations.
The system also provides
reports on those investigations
for which data has not been
entered into the system within a
certain time period.
-------
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 to improve
management in the  Federal
Government. The PCiE
coordinates interagency activities
involving common issues, and
develops approaches and
techniques to strengtnen the
effectiveness of the entire
inspector General community.
The PCIE is headed by the
Deputy Director, Office of
Management and Budget, and
.ndudes the statutory inspectors
General and other key Federal
officials.

Internal Operations Committee

During this reporting period,
John C. Martin, Inspector
General, EPA, was chairman of
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 was 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 )G
community.

Internal Operations Committee
Activities

The Internal Operations
Committee was responsible for
special assignments involving
medical and fitness standards
for investigators and OIG
technical services contracting.
 A working group, with 23
agencies participating, was
established to develop common
medical and fitness standards
for OIG investigators.  The
working group has circulated a
draft for comment by all PCIE
members. Issues examined are
grandfathering, 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 Committee also oompiettsd
work on a project to determine
PDIE members' intersst in and
the feasibility of establishing a
PCIE-wide contract for expert
technical services  L nder this
approach PCIE members would
draw from the contract as
needed to meet certain tecnn oal
service requirements < e.,
engineering services.  After
surveying the PCIE membersiip,
we held discussions with the
General Services Administration
and a private engineering
counsel.  The Comm ttee was
not convinced of the 'easibility of
such a broad based, PCIE-wide
contract.
  PCIE members had some
general interest; however, many
noted they already had access
to expert technical services, in-
house or otherwise. While a
PCiE-wide contract would cut
dcwn on the amount of time
required by individual PCIE
members to competitively
procure these services, rt would
stiii take an estimated 90 days  to
obtain the service(s) under sucn
a rontract. It would  also take a
considerable amount of GSA
and OIG staff time to set up and
manage the contract.

Technology Committee

During this reporting period,
Inspector General Martin was a
m€;mber of the PCIE Technology
Committee, which addresses
technological issues as they
relate to Federal ageraes and
the Inspector General
community. Automated Data
Processing (ADP) auditors from
the EPA OIG are participating IP
a followup review of
recommendations fron the first
two phases of the PCIE
Computer Systems Inlegi'ty
Project complete*1 in 1988. This
project identified significant
Government-wide problems with
operating system and security
system software controls at
major data centers, as well as
mapr deficiencies n standards,
documentation, and operations
affecting computer systems
integrity in Federal agencies
 Staff members frorn EPA, OiO
also made presentations at and
participated in the information
Systems and Investigations
Roundtabte.  The Rourtdtable
meets periodically so that
agencies may share ideas and
experiences relatng to a variety
of information technology issjes,
including computer security, O'G
management intoi mation
systems,  and ADP technics'
support to OIG re-aerial o'ficws.
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
EFJA programs and to advise the
Administrator on policies to
improve the efficiency and
effectiveness of EPA programs
and activities.  The Committee is
composed ct senior EPA
.Tocjram and regional officials
and i'-. chaired by the inspector
                                Poster Campaign

                                As stated in our previous
                                semiannual report, CIMI
                                developed a pamphlet entitled
                                "Ethics in a Nutshell" to briefly
                                explain trie conflict-of-interest
                                statutes and EPA ethical
                                standards. The pamphlet's
                                question- and-answer formal
                                anticipates some of the more
                                common concerns facing
                                Federal employees.  To promote
                                employee interest in reading this
                                pamphlet CIMI developed the
                                fifth poster in a series designed
                                to raise employee awareness of
                                ethics.  Each poster poses a
                                question which requires
                                employees to refer to the
                                pamphlet to obtain the answers.
                                TO increase the effectiveness of
                                the poster campaign, only
                                practical questions relevant to
                                current issues were used. The
                                poster? are on display at
                                Headquarters  and all regional
                                offices-
-------
Hotline Activities
 i he QlG Hotline Center opened
?1 now cases and completed
and closed 20 cases during the
, eoorfing period  Of the cases
closed, 6 resulted in
            !. prosecutove, or
             corrective action,
«;tiiie  14 did no? require action.
Jjscs that did not have
':TMT,e-diate valid*,' due to
•^sufficient information may be
jsec :o identify trends or
p.ittf si r i*t  of information provided to
the OiG Hotline Center:

« A complainant alleged that an
EPA project manager accepted
gifts in return for influencing
contract awards.  A review of
the complaint disclosed that the
osoject manager had a dose
personal relationship with a
contractor's family and that the
employee should have recused
himself from managing and
swa'uating the contractor. The
pioiect manager's failure to take
this step created a reasonable
Appearance of giving preferential
treatment. As a result of this
complaint, the employee has
•,
-------
   Appendix  1—Audit  Reports  Issued
    THE INSPECTOR GENERAL ACT REQUIRES A LISTING, SUBDIVIDED ACCORDING TO SUBJECT MATTER, OF EACH AUDIT REPORT ISSUED I
    THE OFFICE DURING THE REPORTING PERIOD AND FOR EACH AUDIT REPORT, WHERE APPLICABLE, THE DOLLAR VALUE OF QUEST IONE
    COSTS AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE
 Audit Control
 Number
                       Auditee
Final Report
Issued
E1SFFO-11-0018-1100026  SUPERFUND REPORT TO CONGRESS
                      FISCAL  1989
                                                     10/18/90
Assistant Administrator for Administration and Resources Management

E1FMGO-13-0033-1400013  SINGLE AUDIT ACTIVITIES           3/25/91
E1AMFO-11-0029-1100153  MANAGING  IMPLEMENTATION OF THE     3/29/91
                      NEW ACCOUNTING SYSTEM
E1XMGO-03-0317-1400004  NEW RESTRICTIONS ON LOBBYING      1/14/91
E6AMGO-11-0033-1400001  REVIEW OF ELECTRICAL CONTRACTS     11/26/90
                      AT RESEARCH TRIANGLE PARK

Assistant Administrator for Enforcement and Compliance  Monitoring

E1GMG1-05-6005-1400012  NEIC FOLLOWUP                    3/11/91

Assistant Administrator for Pesticides and Toxic Substances

                                                      3/29/91

                                                      3/26/91

Assistant Administrator for Solid Wastes
E1EPBO-01-0023-1100154  EPA PRIORITY REVIEWS OF HARMFUL
                      CHEMICAL SUBSTANCES
E1EPEO-06-0157-1100148  PESTICIDE CONSOLIDATED AUDIT
E1SGCO-04-0407-1100155  MANDATE  FOR POST-SARA REMEDIAL
                      ACTION STARTS

Office of the Comptroller

E1LMG1-11-0014-1400003  EPA 1990 FMFIA ACTIVITY

Office of Information and Resource Management

E1NMBO-15-0021-1100152  IBM 3090 OPERATIONS AT NCC
E1NMBO-15-0027-1100151  AUDIT OF RACF SECURITY SYSTEM
                                                      3/30/91
                                                     12/21/90
                                                      3/29/91
                                                      3/29/91
Procurements Management Division

E1BMF1-11-0016-1100158  ADVISORY  AND ASSISTANCE SERVICES   3/29/91

Region 1
E1SJDO-01-0145-1100133  SUPERFUND POST SETTLEMENT
                      ACTIVITIES - REGION 1
E1LMG1-01-0100-1400017  CONTROL OF CASH ADVANCES
                                                      2/27/91

                                                      3/28/91
E6FFG1-01-0082-1400014  SUPERFUND EMPLOYEE  HEALTH PROGRAM  3/26/91

Region 5

E1SJDO-05-0195-1100149  SUPERFUND POST SETTLEMENT         3/29/91
                      ACTIVITIES - REGION 5
E1XMG1-05-6006-1400015  GREAT  LAKES GRANTS  PROGRAM        3/29/91
                      FOLLOWUP - REGION 5
           Questioned Costs
	Recommend
Ineligible   Unsupported    Unnecessary/      Effioienci
                                                                      Costs
                                                                                    Costs
                        Unreasonable   (Funds Be F
                               Costs   To Better U'.
1.  INTERNAL & MANAGEMENT AUDITS (Listed by Action Official)

Administrator
-------
Audit Control
Number
                       Auditee
Final Report
Issued
Region 9

E1SFGO-09-0117-1400005  ARIZONA COOPERATIVE AGREEMENTS -   1/31/91
                        FOLLOWUP
E1SG*8-09-0143-1300054  MANAGEMENT OF LOUISIANA/PACIFIC    3/29/91
                        SITE - REGION 9
Ineligible
   Costs
                                                                                    Questioned Costs
Unsupported
       Costs
Unnecessary/
Unreasonable
       Costs
Recommended
   Efficiencies
 (Funds Be Put
To Better Use)
              TOTAL INTERNAL & MANAGEMENT AUDITS
                                                          20
2. CONSTRUCTION GRANT AUDITS
P2CU*7-01-0011-1100077
P2CW*8-01-0159-1100078
P2CW*8-01-0045-1100099
S2CW*8-01-0036-1100027
S2CULO-01-0107-1100056
S2CW*8-01 -0402- 1100057
S2CWL9-01-0175-1100107
TOTAL OF
E2AWPO-02-0284- 1400000
P2CWL9-C2-0246- 1100136
TOTAL OF
E2CU*7-03-0297-1200001
E2CW*7-03-0346- 1200007
E2AWT1-03-0126-1400010
E2AWT1-03-0156-1400016
P2CWL9-03-0308- 1100045
P2CW*8-03-0082- 1100058
P2CWL9-03-0120-1100100
P2CW*8-03-0302- 1100101
P2CW*8-03-0022-1100141
P2CW*8-03-0152-1100147
P2CWL9-03-0017-1100157
?2CW*8-03-0132-1200004
P2CW*8-03-0186- 1200009
TOTAL OF
E2CWMO-04-0208- 1200000
E2CWMO-04-0201-1200002
E2CWM1-04-0054-1200003
E2CWM1 -04-0053-1200005
E2CWM1-04-0091-1200006
E2CWM1 -04-0121 - 1200008
E2CWM9-04-0046-1200010
E2CUM1-04-0041-1200011
E2CUM1-04-0095-1200012
E2CUMO-04-0127-1200013
E2CWNO-04-0239- 1300022
E2CUN8-04-0429- 1300023
E2CUN8-04-0210- 1300029
E2BUNO-04-0210-1300032
E2CUNO-04-0176- 1300034
E2HUPO-04-0290- 1400002
M2HUL1-04-0083-1100105
M2HWL1-04-0088-1100118
P2CWNO-04-0049- 1300008
P2CWN9-04-0215-1300009
P2CUN9-04-0294-1300012
P2CWN9-04-0188- 1300027
P2CUN9- 04 - 0045 - 1 300028
S2CUN8-04-0051- 1300026
S2CWN8-04-0251-1300043
S2CWN8- 04 - 0086- 1 300044
BEDFORD
GILFORD
ESSEX
MIDDLEBOROUGH
LOWELL
PROVIDENCE
MWRA
REGION 01 = 7
EARLY WARNING - COMPOSTING
WESTCHESTER CO - PEEKSKILL,
REGION 02 = 2
COAL RIVER PSD
BERRYSBURG MUNICIPAL AUTH
PHI LA SWTP EARLY WARNING
PHILA WWTP EARLY WARNING
HAMPTON ROADS SAN I DISTRICT
CLAYSVILLE-DONEGAL JT MUNI
POSSUM VALLEY SEWER AUTH
PITTSYLVANIA CTY SEW AUTH
BALTIMORE COUNTY
YORK COUNTY OF
WSSC & FAIRFAX CITY & DC
KANAWHA FALLS PSD
PERRYVILLE COMMISSIONERS
REGION 03 = 13
ABBEVILLE
KINGSTON
KISSIMMEE
LEXINGTON-FAYETTE
GREENWOOD METRO COMM
ELIZABETHTOWN
ST ANDREWS PSD
MT. CARMEL
GROVETOWN
FT MILL
DURHAM
GRAND STRAND WSA
MYRTLE BEACH
CAVE LAND
JEFFERSON COUNTY
KY SRF AUDIT
MS DEPT. OF ENV. QUALITY
FL DEPT. OF ENV. REG.
ATLANTA
MIAMI,
ATLANTA
STURGIS,
LIVE OAK
TULLAHOMA
LEBANON
GREENEVILLE
NH
NH
VT
MA
MA
RI
MA

PR
NY

WV
PA
PA
PA
VA
PA
PA
VA
MD
VA
DC
WV
MD

SC
TN
FL
KY
SC
KY
SC
TN
GA
SC
NC
SC
SC
KY
AL
KY
MS
FL
GA
FL
GA
ICY
FL
TN
TN
TN
12/19/90
12/19/90
1/14/91
10/18/90
1V 2/90
11/ 2/90
1/22/91

10/17/90
3/ 4/91

10/22/90
1/14/91
3/ 8/91
3/28/91
10/23/90
1V 5/90
1/15/91
1/16/91
3/ 6/91
3/25/91
3/29/91
11/20/90
2/ 5/91

10/ 9/90
1V 5/90
11/19/90
11/28/90
M 9/91
2/ 4/91
3/ 6/91
3/15/91
3/20/91
3/20/91
12/13/90
12/21/90
1/24/91
2/ 7/91
2/12/91
12/13/90
1/18/91
2/ 4/91
10/17/90
10/17/90
10/24/90
1/16/91
1/29/91
V 8/91
3/13/91
3/21/91
16,118
95,771
26,721
0

53,277
904,555
1,096,442

39,010
39,010
80,282
40,942


813,134
8,120
144,505
57,161
67,906
831,776
1,064,863
35,706
84,244
3,228,63V
21,098
52,970
89,369
337,332
149,297
215,585
91,109
72,924
169,214
87,779
25,918
480,949
244,134
846,927
497,978



63,881
491,170
637,366
64,464
118,128
249,900
342,517
198,585
              TOTAL OF REGION 04 =  26
               5,548,594
                                                                                              0
                                                                                              0
                                                                                           1,427
                                                                                         97,100

                                                                                         110,241
                                                                                         534,226

                                                                                         742,994
                                                                                      3,083,611

                                                                                      3,083,611

                                                                                              0
                                                                                              0
                                                                                              0
                                                                                         20,497
                                                                                        298,814
                                                                                           1,528
                                                                                              0
                                                                                        852,527
                                                                                        525,183
                                                                                          3,285
                                                                                         39,131

                                                                                      1,740,965

                                                                                              0
                                                                                              0
                                                                                              0
                                                                                              0
                                                                                              0
                                                                                              0
                                                                                              0
                                                                                              0
                                                                                              0
                                                                                              0
                                                                                              0
                                                                                          4,932
                                                                                      2,886,523
                                                                                        333,421
                                                                                          1,297
                      0
                      0
              2,558,305
                      0
                      0
                608,164
                      0
                      0

              6,392,642
                                                       0
                                                       0
                                                  76,802
                                                       0

                                                 568,993
                                                       0

                                                 645,795
                                                      0
                                                    937
                                                      0
                                                       0
                                                      0
                                                      0
                                                      0
                                                      0
                                                   1,767

                                                   2,704

                                                      0
                                                      0
                                                      0
                                                      0
                                                      0
                                                 36,104
                                                      0
                                                      0
                                                      0
                                                      0
                                                      0
                                                      0
                                                      0
                                                      0
                                                      0
                           0
                           0
                           0
                           0
                           0
                     281,833
                           0
                           0

                     317,937
                                                                                                                        588,000
                                                                                                                      3,905,417
                                              4,493,417
                                                                                                                                41
-------
                                                                                     Questioned Costs
Audit Control Auditee
Number
E2AUT 1-05- 01 34- 1400007 S HENRY RSD EWS
P2CWN8-05-0360-1300005 EAU CLAIRE
P2CWN8-05-0140- 1300010 FT WAYNE
P2CWN8-05-0214- 1300014 MUSKEGON CO DPW
P2CUN8-05-0142-1300015 ST PAUL MWCC
P2CUN8-05-0508-1300018 GENESEE CO
P2CWN8-05-0375- 1300020 ST JOHN
P2CUN7- 05 -0200 -1300048 CHICAGO MWRDGC
P2CWN7-05-0492-1300049 CHICAGO MWRDGC
P2CUN7-05-0498- 1300050 CHICAGO MWRDGC
P2CWN6-05-0377- 1300051 CHICAGO MWRDGC
P2CWN6-05-0394- 1300057 CHICAGO MURDGC
P2CWN9-05-0066-1300058 GARY SD
TOTAL OF REGION 05 = 13
E2CWN7-06-0177-1300011 OOLOGAH,
P2CWN7-06-0178- 1300003 LAKE CHARLES
P2CWNO-06-0026- 1300004 DERIDDER
P2CWN9- 06-01 14- 1300024 BENTON
P2CWN9-06-0100- 1300035 SHREVEPORT,
P2CWN9-06-0099- 1300039 SULPHUR,
TOTAL OF REGION 06 = 6
P2CWN8-07-0030- 1300001 CHANUTE
P2CWN8-07-0161- 1300002 COFFEYVILLE
P2CWN8-07-0202- 1300025 LAKE TAPAWINGO
P2CWN9-07-0081- 1300038 METRO ST LOUIS SEWER DIST,
P2CWN8-07-0122-1300046 CHARITON
TOTAL OF REGION 07 = 5
E2CW*7-09-0192-1300053 SUN VALLEY WATER & SAN DIST
E2AWP9-09-0189-1400006 EARLY WARNING - MONTEREY
E2AWP1 -09-0059- 1400018 GUALALA COMM SER DIST. /EWR
S2CW*7-09-0072- 1300036 HEALDSBURG, CITY OF
S2CW*7-09-0089- 1300037 LAS GALLINAS VALLEY SD
S2CW*6-09-0175- 1300045 OXNARD, CITY OF
S2BWNO-09-0171- 1300055 SAN FRANCISCO, C&C WST
S2BWN9-09-0166- 1300056 SAN FRANCISCO, C&C ROCK BK.
TOTAL OF REGION 09 = 8
TOTAL CONSTRUCTION GRANT AUDITS
Final Report
Issued '
IN
WI
IN
MI
MN
MI
IN
IL
IL
IL
IL
IL
IN

OK
LA
LA
AR
LA
LA

KS
KS
MO
MO
IA

NV
CA
CA
CA
CA
CA
CA
CA

::
2/25/91
10/ 9/90
10/17/90
10/31/90
10/31/90
11/21/90
12/10/90
3/29/91
3/29/91
3/29/91
3/29/91
3/29/91
3/29/91

10/19/90
10/ 4/90
10/ 4/90
M 3/91
2/13/91
2/28/91

10/ 4/90
10/ 4/90
M 3/91
2/28/91
3/26/91

3/28/91
2/11/91
3/28/91
2/21/91
2/27/91
3/25/91
3/29/91
3/29/91

80
Ineligible
Costs

58,280
60,344
76,511
621,341
106,123
152,509
370,420
924,861
675,462
236,306
454,734
73,082
3,809,973
52,169
76,406
78,754
10,332
23,095
V.776
253,532
32,757
1,322,393
30,060
1,239,757
8,659
2,63:5,626
4,665,840


29, OB
149,163
6,485,975
1,596,249
40,029
12,966,289
29,581,105
Unsupported
Costs

87,553
116,504
1,213,469
46,463
136,888
61,589
44\014
110,146
356,998
240,323
0
51,511
2,842,458
22,587
0
0
0
4 , 624
0
27,211
0
0
0
677,531
0
677,531
0


0
0
0
0
36,583,221
36, 583, 221
52,090,633
Unnecessary/ Efficienci
Unreasonable (Funds Be P
Costs To Better U:
4,461,
0
0
0
0
0
0
0
0
9,309
17,410
0
0
26,719 4,, 461,
0
0
0
0
c
c
c
0
0
0
0
0
0
1,760,811
6,200,(
4,831,1
0
0
0
2,662,422
0
4,423,233 11, 031, (
5,416,388 19,397,;
3. OTHER GRANT AUDITS
C3HMJ1-01
G3HMKO-01
G3HMK1-01
G3HMK1-01
G3HMK1-01
G3HMK1-01
G3HMK1-01
G3HMK1-01-
G3HMK1-01-
G3HMK1-01-
G3HMK1-01
G3HMK1-01
G3HMK1-01
G3HMK1-01-
G3HMK1-01
G3HMK1-01
G3HMK1-01
G3HMK1-01
N3HMKO-01
N3HMJO-01-
N3HMKO-01-
N3HMK1-OV
N3HMKO-01-
0039-
0286-
0038-
0069-
0068-
0074-
0072-
0084-
0081-
0076-
0088-
0090-
0073-
0097-
0098-
0099-
0119-
0118-
0255-
0268-
0285-
0060-
0170-
1500134
1500000
1500078
1500203
1500262
1500274
1500275
1500279
1500280
1500281
1500296
1500297
1500299
1500427
1500428
1500429
1500495
1500496
1500079
1500080
1500199
1500202
1500263
CONNECTICUT DEPT ENV PRO    CT    11/14/90
BRIDGEWATER                 MA    10/ 2/90
WEBSTER                     MA    10/29/90
NORTHUMBERLAND              NH    12/14/90
BARNSTABLE CNTY             MA     1/ 9/91
PITTSBURGH                  NH     1/14/91
NORTH HAVEN                 CT     1/14/91
SUFFIELD                    CT     1/16/91
WALLINGFORD                 CT     1/16/91
HANOVER                     NH     1/16/91
ST. ALBANS,                 VT     1/22/91
NEWPORT                     NH     1/22/91
YARMOUTH                    MA     1/22/91
WINCHESTER                  CT     3/ 5/91
MATTABASSETT DISTRICT       CT     3/ 5/91
GUILFORD-SANGERVILLE        ME     3/ 5/91
HAZARDOUS WASTE MGMT. 7 SERVCT     3/28/91
WESTBOROUGH                 MA     3/28/91
MONTAGUE                    MA    10/29/90
VERMONT STATE OF            VT    10/29/90
WARWICK                     RI    12/13/90
WARWICK                     RI    12/14/90
NEW HAMPSHIRE, STATE OF     NH     1/ 9/91
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
-------
                                                     f ..-,8! I'cvu't      Ineligible     I    ,.,  .fi    'innecessa.>
                                                             ^                 s             .., :&
                                                         "
3;?f •''..'!,:,:'.,   Nb«  HAMf'jii'ic, biATE Of      «ii-,
J75Q  • , ,,-75,7   nua^AH                        HA
0;"''!  i."uO?7?   S'?^[CORS  KLC  P'ij'., CCHM   NH       i.'U,-u
-------
                                                                                     Questioned Costs
Audit Control
Number

G3HMK1-03-0068-1500270
G3HMK1 - 03-0057-1500343
G3HMK1 -03-0072- 1500344
G3HMK1- 03 -0075 -1500372
G3HMK1 -03-0082- 1500373
G3HMK1- 03- 0083- 1500374
G3HMK1 -03-0084- 1500375
G3HMK1-03-0080-1500398
G3HMK1 -03-0128- 1500399
G3HMK1 -03-0077- 1500421
G3HMK1 -03-0131 -1500430
G3HMK1 -03-0132- 1500431
G3HMK1 -03-0081 -1500455
G3HHK1-03-0139-1500456
G3HMK1-03-0140-1500457
G3HMK1-03-0143-1500458
G3HMK1-03-0144-1500459
G3HMK1-03-0145- 1500460
G3HMK1-03-0148-1500466
N3HMKO-03-0171 -1500083
N3HMKO-03-0180- 1500097
N3HMKO-03-0413-1500098
N3HUK1 -03-0016- 1500099
N3HMKO-03-0172-1500167
N3HMKQ-G3-OQ76-15Q0168
N3HMKO-03-0103-15Q0169
N3HMJ1 -03-0021-1500170
N3HKJO-03-Q075-1500182
N3HMK1 -03-0034-1500184
N3HHKO- 03-0344 -1500 195
N3HHJO-03-0395- 1500196
N3HKJO-03-0418-15Q0198
N3HMKO-03-0381- 1500271
N3HKHO-03-0422- 1500356
N3HMK1 -03- 0087- 1500376
N3HMK1 -03-0133- 1500432
N3HMK1-03-0157-1500497
N3HHK1-03-0158-1500498
N3HUK1-03-0159-1500499
Auditee

UYSOX TOWNSHIP MUNICIPAL
WESTMINSTER
TROY BOROUGH
WSSC
WEST CHESTER
PLUM BOROUGH MUNICIPAL
HAMPTON ROADS SANITATION
CAMBRIDGE CITY OF
OHIO COUNTY PSD
BOONSBORO
CANTOM AREA SCHOOL DISTRICT
DELAWARE RIVER BASIN COMM
YORK CITY SEWER AUTHOR
OHIO COUNTY PSD
OHIO COUNTY PSD
HANOVER BOROUGH OF
HANOVER BOROUGH
HANOVER BOROUGH
MANHEIM TOWNSHIP
DELAWARE VALLEY REGIONAL
HOWARD COUNTY
LEUISTOWN BOROUGH OF
HOWARD UNIVERSITY
DC DEPT OF PUBLIC WORKS
RAPPAHANNGCK AREA DEV 6/88
RADCO PLNG DIST 16
VA DEPT OF EMERGENCY SER


PA
MD
PA
MD
PA
PA
VA
MD
WV
MD
PA
PA
PA
WV
WV
PA
PA
PA
PA
PA
MD
PA
DC
DC
VA
VA
VA
VA DEPT OF EMERGENCY SERVICEVA
READING CITY OF
DELAWARE STATE OF 6/89
VA DEPT OF EDUCATION
VA DEPT OF CONSERVATION
HOWARD COUNTY 6/89
PHILADELPHIA CITY OF
PENNSYLVANIA STATE OF
CONSERVATION FOUNDATION INC
CHARLES COUNTY
CHARLES COUNTY
HAMPTON UNIVERSITY
PA
DE
VA
VA
MD
PA
PA
DC
MD
MD
VA
Final Report
Issued

1/10/91
2/12/91
2/12/91
2/21/91
2/21/91
2/21/91
2/21/91
2/27/91
2/27/91
3/ 4/91
3/ 5/91
3/ 5/91
3/14/91
3/14/91
3/14/91
3/14/91
3/14/91
3/14/91
3/19/91
10/30/90
IV 1/90
1V 1/90
IV V90
11/28/90
12/ 4/90
12/ 4/90
12/ 4/90
12/12/90
12/12/90
12/13/90
12/13/90
12/13/90
1/10/91
2/14/91
2/21/91
3/ 5/91
3/28/91
3/28/91
3/28/91
Ineligible Uns.jpporte 1 Unnecessary/ Efficient
Costs Costs Unreasonable (Funds Be

0
0
0
0
0
3,600
0
133,040
53,540
50
0
0
0
0
0
0
0
0
0
0
0
0
0
212
0
0
0
0
0
0
0
0
0
0
0
0
0
840,478
0

1
0
3
T
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
42,220
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Costs To Better I
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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 03 =  49

C3HMKO-04-0375-1500041  PENSACOLA                   FL
C3HMK1-04-0047-1500175  DEKALB COUNTY               GA
C3HMK1-04-0058-1500197  GREENSBORO                  NC
C3HAK1-04-0056-1500214  JEFFERSON COUNTY FISCAL COURKY
C3HWK1-04-0072-1500215  ATLANTA                     GA
C3HWK1-04-0118-1500395  TAMPA                       FL
G3HWKO-04-0343-1500001  ROANOKE RAPIDS SANITARY DIS.NC
G3HWKO-04-0348-1500002  BEAUFORT                    NC
G3HMKO-04-0342-1500003  OPELIKA                     AL
G3HWKO-04-0365-1500004  PRINCETON                   NC
G3HWKO-04-0349-1500009  JEFFERSON                   NC
G3HWKO-04-0364-1500035  PRINCETON                   NC
G3HWKO-04-0377-1500050  DALTON WATER, LIGHT & SINKINGA
G3HWK1-04-0025-1500056  GRAND STRAND WATER & SEWER  SC
G3HWKO-04-0381-1500065  ROCK HILL                   SC
G3HWK1-04-0034-1500092  CLEVELAND UTILITIES         TN
G3HWKO-04-0390-1500102  DAWSON SPRINGS WATER & SEWERKY
G3HWK1-04-0021-1500103  BEAUFORT                    NC
G3HWK1-04-0057-1500176  SPRINGFIELD                 GA
G3HWK1-04-0059-1500232  MANCHESTER                  KY
G3HWK1-04-0061-1500265  WAVELAND WASTEWATER MGMT DIVMS
G3HWK1-04-0062-1500267  BUNCOMBE COUNTY SEWERAGE DISNC
G3HWK1-04-0063-1500301  CENTRAL CITY                KY
G3HWK1-04-0078-1500307  CAVELAND SANITATION AUTHOR. KY
G3HWK1-04-0077-1500309  LAKE CITY                   FL
G3HWK1-04-0119-1500320  CENTRAL CITY WATER & SEWER  KY
G3HWK1-04-0089-1500326  DILLON                      SC
G3HWK1-04-0079-1500328  SPARTANBURG SANITARY SEWER  SC
G3HWK1-04-0082-1500329  CARROLLTON                  GA
G3HWK1-04-0102-1500362  ROCKY MOUNT                 NC
G3HWK1-04-0104-150C390  WESTERN CAROLINA RSA        SC
10/19/90
12/ 6/90
12/13/90
12/21/90
12/21/90
 2/27/91
10/ 1/90
10/ 1/90
10/ 1/90
10/ 1/90
10/ 1/90
10/16/90
10/24/90
10/25/90
10/26/90
IV V90
IV 2/90
1V 2/90
12/ 6/90
 V 3/91
 V 9/91
 V 9/91
 1/28/91
 1/29/91
 1/29/91
 21 1/91
 2/ 4/91
 21 4/91
 21 4/91
 2/19/91
 2/27/91
1,030,920

        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
   14,680
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
42,395

     0
     0
     0
     0
     0
     0
     0
     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
Audit Control
Number
G3HWK1 -04-0109- 1500391
G3HUK1 -04-01 11 -1500392
G3HWK1-04-0132-1500394
G3HWK1-04-0155-1500433
G3HUK1-04-0112-1500464
G3HWK1-04-0122-1500478
G3HWK1-04-0120-1500479
G3HWK1-04-0116-1500482
G3HWK1 -04-0185- 1500486
G3HWK1 -04-0135- 1500487
G3HWK1 -04-0136-1500488
G3HWK1 -04-0134- 1500489
G3HUK1 -04-0129- 1500490
G3HUK1-04-0137-1500491
N3HUKO-04-0331-1500032
N3HUKO - 04 - 0305 - 1 500033
N3HMKO-04-0330- 1500034
N3HMKO- 04 -0380 -1500051
N3HWKO-04-0315-1500057
N3HPJ1-04-0020-1500058
N3 HMKO - 04 - 0345 - 1 500059
N3HUKO-04-0378-1500060
N3HWKO-04-0149-1500Q61
N3HWKO-04-0329- 1500062
N3HAKO-04-0298- 1500063
N3HMJO-04-0319-1500064
N3HMJO-04-0173- 1500068
N3HWKO-04-0347- 1500069
N3HWKO-04-0316-1500070
N3HMJO-04-0388- 1500071
N3HUK1 -04-0044- 1500093
N3HUKO-04-0322- 1500094
N3HWKO-04-0450- 1500095
N3HWKO-04-0404-1500101
N3HUK1 -04-0026- 1500268
N3HWKO-04-0218- 1500287
N3HUK1 -04-0033- 1500288
N3HAK1 -04-0074-1500308
N3HWK1 -04-0086- 1500327
N3HUKO-04-0187- 1500363
N3HUKO-04-0143- 1500364
N3HUKO-04-0146- 1500389
N3HMK1 -04-0124- 1500393
N3HUK1 -04-0073- 1500463
N3HAK1 -04-0060- 1500480
N3HAK1-04-0075-1500481
TOTAL OF
C3HMKO-05-0418- 1500029
C3HMK1-05-0049- 1500147
C3HMK1-05-0170-1500348
C3HMK1 -05-0163- 1500440
G3HMKO-05-0410- 1500005
G3HMKO-05-0401-1500006
G3HMKO-05-0416-1500007
G3HMJO-05-0425- 1500008
G3HMKO- 05 -04 14 -1500011
G3HMJO-05-0426-1500012
G3HMKO-05-0450- 1500013
G3HMKO-05-0417-1500014
G3HMJO-05-0441-1500015
G3HMJO-05-0443-1500016
G3HMJO-05-0448-1500017
G3HMKO-05-0427- 1500018
G3HMJO-05-0451- 1500037
G3HM J 0 - 05 - 0444 - 1 500038
G3HMJO-05 -0453- 1500039
G3HMJO-05-0442- 1500044
G3HMJO-05-0445-1500045
G3HMJO- 05 -0433 -1500053
G3HMJO-05-0432- 1500054
G3HMK1-05-0027-1500072
Auditee
MOUNT CARMEL TN
WINNSBORO SC
GREENVILLE WATER WORKS AL
OAKLAND TN
OLD HICKORY UTILITY DIST. TN
LUVERNE AL
NEW BERN NC
KEVIL KY
OAKLAND TN
UNION SPRINGS UTILITIES BOA AL
UNION SPRINGS UTILITIES BOARAL
TALLADEGA AL
CLANTON AL
GRIFFIN GA
CHARLESTON MS
HEADLAND AL
BROWARD COUNTY FL
MISSISSIPPI STATE OF MS
PALATKA FL
GEORGIA DEPT. OF AGRICULTUREGA
SC DEPT OF HEALTH & ENVIRO. SC
RESEARCH TRIANGLE INSTITUTE NC
LANCASTER KY
BREVARD COUNTY FL
KNOX COUNTY TN
TENNESSEE STATE OF TN
FLORIDA, STATE OF FL
JACKSON MS
KNOXVILLE TN
NORTH CAROLINA STATE OF NC
AIKEN COUNTY SC
ORLANDO FL
JEFFERSON NC
MIDDLEBOROUGH KY
FT MEYERS FL
LAKE CITY FL
FAYETTEVILLE NC
CHATTANOOGA TN
BERKELEY COUNTY SC
SOUTH CAROLINA UNIVERSITY SC
SUMTER AREA TECHNICAL COLLEGSC
MEDICAL UNIVERSITY OF SC SC
MANATEE COUNTY FL
MISSISSIPPI STATE UNIVERSITYMS
FORSYTH COUNTY NC
MECKLENBURG COUNTY NC
REGION 04 = 77
SAGINAW CO FY 89 MI
LANSING FY 89 MI
KALAMAZOO FY 89 MI
DEKALB SD FY 90 IL
LA CRESCENT FY 89 MN
PARK RAPIDS FY 89 MN
WILL1AMSTON FY 89 MI
INDIANA DEM FY 89 IN
MILWAUKEE MSD FY 89 WI
S BEND FY 89 IN
JACKSON FY 89 MN
WILLIAMSTON FY 88 MI
EVERGREEN LSD FY 89 OH
LOUDON-PERRYVILLE VSD FY 89 OH
COLDWATER VSD FY 89 OH
DOWNERS GROVE SD FY 90 IL
GIRARD CITY SD FY 89 OH
8LUFFTON VSD FY 89 OH
LABRAE LSD FY 89 OH
JEFFERSON LSD FY 89 OH
BATH LSD FY 89 OH
LAKEWOOO LSD FY 89 OH
OHIO VALLEY LSD FY 89 OH
ELYRIA FY 89 OH
Final Report
Issued
2/27/91
2/27/91
2/27/91
3/ 6/91
3/15/91
3/19/91
3/18/91
3/18/91
3/22/91
3/22/91
3/22/91
3/22/91
3/22/91
3/22/91
10/16/90
10/15/90
10/12/90
10/24/90
10/25/90
10/25/90
10/25/90
10/25/90
10/25/90
10/25/90
10/25/90
10/25/90
10/26/90
10/26/90
10/26/90
10/26/90
1V 1/90
1V V90
1V 1/90
IV 2/90
V 9/91
1/16/91
1/16/91
1/29/91
2/ 4/91
2/19/91
2/19/91
2/27/91
2/27/91
3/15/91
3/19/91
3/18/91

10/15/90
11/20/90
2/13/91
3/12/91
107 2/90
10/ 2/90
107 2/90
10/ 4/90
10/12/90
10/12/90
10/12/90
10/12/90
10/12/90
10/12/90
10/12/90
10/12/90
10/18/90
10/18/90
10/18/90
10/19/90
10/19/90
10/24/90
10/24/90
10/26/90
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
0
0
0
0
2,694
0
0
0
0
0
0
0
0
0
0
0
0
0
17,374
0
0
0
0
0
0
0
0
24,240
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,790
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
-------
                                                                                       Questioned Costs
Audit Control
Number
G3HMJO-05-0431- 1500073
G3HM J 1 - 05 - 0035 - 1 500081
G3HMJ1-05-0025-1500082
G3HMJ 1-05 -0034- 1500085
G3HMJ1 -05-0038-1500086
G3HMJ1 -05-0036- 1500091
G3HMK1 -05-0042- 1500096
G3HMKO-05-0263- 1500104
G3HMJ1-05-0026-1500105
G3HHK1-05-0051-1500107
G3HMK1-05-0078-1500116
G3HMK1 -05-0048- 15001 17
G3HHK1-05-0023-1500118
G3HMK1-05-0080-1500119
G3HMK1 -05-0079- 1500120
G3HHJ1 -05-0076- 15001 23
G3HMK1 -05-0087- 1500129
G3HMJ1 -05-0088- 1500130
G3HMJ1-05-0089-1500131
G3HMK1 -05-0082- 1500132
G3HMJ1-05-0090-1500135
G3HMJ1-05-0091-1500136
G3HMJ1 -05-0092- 1500137
G3HMJ1 -05-0096- 1500138
G3HMJ1 -05-0097-1500139
G3HMKO-05-0054-1500142
G3HMK1 -05-0099- 1500149
G3HMJ1-05-0105-1500164
G3HMJ1-05-0109-1500165
G3HMK1-05-0102-1500177
G3HMJ1-05-0118-1500186
G3HM<1-05-0121-1500187
G3HMK1 -05-0081 -1500189
G3HMJ1-05-0115-1500206
G3HMJ1-05-0132-1500212
G3HMK1-05-0130-1500213
G3HMK1-05-0142-1500277
G3HMJ1-05-0139-1500278
G3HMK1 -05-0147- 1500293
G3HMK1-05-0155-1500321
G3HMJ1 -05-0153-1500322
G3HMK1 -05-0162- 1500325
G3HMK1 -05-0167- 1500349
G3HHK1 -05-0180- 1500439
G3HMJ1 -05-0193- 1500462
G3HMJ 1-05 -021 7- 1500467
G3HMJ1-05-0218-1500468
G3HMK1- 05 -0200- 1500469
G3HMJ1 -05-0198-1500470
G3HHJ1 -05-0201 -1500471
G3HMJ1-05-0208-1500472
G3HMJ1 -05-0203- 1500473
G3HMJ1-05-0204-1500474
G3HMJ1-05-0207-1500475
G3HMJ1 -05-0209- 15004 76
G3HMJ1 -05-0210- 15004 77
N3HMJ8-05-0563- 1500040
N3HMJ9-05-0501- 1500043
N3HMJO-05-0115-1500052
N3HMK1 -05-0024- 1500084
N3HMJ1-05-0045-1500121
N3HMK1 -05-0043- 1500122
N3HMK1-05-0086-1500124
N3HMK1 -05-0073- 1500143
N3HMKO-05-0419- 1500144
M3HMJ1-05-0046-1500145
N3HMJO-05-0221-1500146
N3HMJO-05-0424-1500148
M3HMKO-05-0384-1500150
M3HMJ1-05-0037-1500151
N3HMJO-05-0352-1500155
N3HMJ9-05-04 77- 1500156
M3HMJO-05-0186- 1500166
Auditee
CAMPBELL CITY SD FY 89
WASHINGTON TUP RSD FY 86/87
W WAYNE RSD FY 87
WASHINGTON TWP RSD FY 88/89
WASHINGTON FY 89
MITCHELL FY 89
LOUELL FY 89
MINNEOTA FY 89
W WAYNE RSD FY 88/89
KANKAKEE FY 88
CLARISSA FY 89
DECATUR SD FY 90
CASEVILLE FY 90
BRIGHTON FY 90
FLUSHING FY 90
JASPER FY 89
HOMEWOOD FY 90
SCOTTSBURG FY 89
LAPORTE FY 89
ELMHURST FY 90
GREENSBURG FY 89
RENSSELAER FY 89
CARBON FY 88/89
PLYMOUTH FY 89
CHESTERTON FY 89
CAIRO FY 89
ALPENA PS FY 90
ST PAUL MWCC FY 89
YOUNGSTOWN CSD FY 89
MN SRF FY 90
ANDERSON FY 89
PEKIN FY 90
CINCINNATI MSD FY 89
PAOLI FY 89
BROWNSBURG FY 89
KANKAKEE FY 90
PERHAM FY 89
INDIANA DEM FY 90
ARLINGTON FY 89
NIPC FY 91
CARMEL FY 89
CLEAR LAKE FY 89
ALLOUEZ TWP FY 90
KEWANEE FY 90
EASTERN LSD FY 89
AMO FY 88/89
COATESVILLE FY 88/89
CLEVELAND CSD FY 89
FT BRANCH FY 88/89
ALLEN CO RSD FY 88/89
ARCADIA FY 88/89
LA PAZ FY 88/89
DUPONT FY 88/89
VAN BUREN FY 88/89
DANVILLE FY 88/89
PORTER FY 88/89
WISCONSIN ST OF FY 87
SW MONTGOMERY CO FY 87
GARY FY 88
MARQUETTE CO FY 89
ST PAUL FY 89
CLEVELAND FY 89
WAYNE CO FY 89
OAKLAND CO FY 89
MICHIGAN DOA FY 87/88
BLOOMINGTON FY 89
WILLOUGHBY FY 88
VALPARAISO FY 89
INDIANAPOLIS FY 88
MUNCIE FY 89
MN STATE OF FY 89
YOUNGSTOWN FY 87
ALLEN CO FY 88
Final Report
Issued
OH
IN
IN
IN
IN
IN
MI
MN
Ml
IL
MN
IL
MI
MI
MI
IN
IL
IN
IN
IL
IN
IN
IN
IN
IN
IL
MI
MN
OH
MN
IN
IL
OH
IN
IN
IL
MN
IN
MN
IL
IN
WI
MI
IL
OH
IN
IN
OH
IN
IN
IN
IN
IN
IN
IN
IN
UI
OH
IN
MI
MN
OH
MI
MI
MI
IN
OH
IN
IN
IN
MN
OH
OH
10/26/90
10/29/90
10/29/90
10/30/90
10/30/90
1V 1/90
IV 1/90
1V 2/90
1V 2/90
1V 5/90
1V 7/90
1V 7/90
IV 7/90
1V 7/90
1V 7/90
1V 7/90
1V 8/90
IV 8/90
1V 8/90
1V 8/90
11/15/90
11/15/90
11/15/90
11/15/90
11/15/90
11/19/90
11/20/90
11/28/90
11/28/90
12/10/90
12/12/90
12/12/90
12/12/90
12/18/90
12/21/90
12/21/90
1/14/91
1/16/91
1/17/91
21 1/91
2/ 1/91
2/ 4/91
2/13/91
3/12/91
3/14/91
3/19/91
3/19/91
3/19/91
3/19/91
3/19/91
3/19/91
3/19/91
3/19/91
3/19/91
3/19/91
3/19/91
10/18/90
10/19/90
10/24/90
10/30/90
1V 7/90
1V 7/90
1V 7/90
11/19/90
11/20/90
11/20/90
11/20/90
11/20/90
11/20/90
11/20/90
11/23/90
11/23/90
11/28/90
Ineligible Unsupported Unnecessary/ Efficiencie
Costs Costs Unreasonable (Funds Be Pu
Costs To Better Usi
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
23,705
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
a
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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
-------
0 i; *** * * o fs ^
Audit Control
Number
N3Hf*U 1
N 7)HJ*J 1
'.3HM;'
*3.iMK 1
^i-iMjr
•J3HWU'
•j3HM.il
•J5r!CK •
-.'Hf'K'1
< i >- -1 ,: *

:3HMiC
.",3HWK1
33riwrl
.;3HUK'
Y5HWK1
:,3riw? :
334WK1
r.SHWKl
G3HU»"
G3HWM
-.3HWK1
G3HWK1
G3HU>";
G3HWK -.
33HUK*
G3HWK1
1,3 HHK1
G3W!
G3HWK!
G3HWK*
•J3HWK1
u3HWKl
G3HwM
L3HUK1
u34UK1
•.•3MWH.1
.:3Hwfi
H3HWL '
N3H*r. 1
'J7HMM
N~>HM.>0
'r;JW!;1
>*3 i,'!VkO
N^.IM {
•a iwk •

1SHWK1
G3HWK1
•uSHWKI
j.SHWK.1
G31WK1
G3UWK!
j3HWK1
f,3HWK1
S3HHIO
C^'WKl
>L~"J!-A:I
C3Hb< 1
1-3 H WO
'..HW» I
05-0107-1500188
-C5-0126- 1500210
-05-0125-1500211
-05-0146- 1500305
;-C5-0440 1500323
-05-0028-1500347
-J5-0149-150035G
:5 -0136- 1500424
C3 -O^A- 1510437
•u--0"7'5 If. 00441
O'A,. 01
06-0250-1500042
•06-0018 130C108
-06-003?- 150021 7
06-0041- 1SC0222
06-0040- !5002??
-06-0053 1500226
06-0036 1500??7
06-0037- ,500228
06-0038-1500230
-06-0034-1500234
-06-0035-1500235
06-0043 1500236
06-0044 '500238
-06 0046 -1 500240
06 -005C- 1500273
-06-0057-1500324
-06-0058- "500330
-06-0059-1500337
-06 -0063 -15C.J345
-06-0065-1500350
-06-0066-1500360
-06-0067-1503361
-06-0070 -1500377
'J6-007I- 15003 75
-C6- 007: -1500409
06- 0074-1 •500420
Do 00?L-1500'-25
-06-00 7?-11C')i:7
nb-002"5-'593?C7
-06-0030- '500208
-06-023C-1SO.V16
-..6 -GO'*' -i-;OJ?.59
»;A 005^- " --033^C
,o-005f. 1;CJ519
•iir- OOoi' - " 50T\ "•
-06-0052 VOC'?3
-u- 006' - '503519
-uc-006?- o003',n
-oo 02;.' ':^00:4
0,.>-'!l56-1';0n3v^
-'<. tw-y-'-v,^
^r rA '*?
07-0022- r">0020i,
07-0023-1503224
-O7- 0024 -1500225
-O7- 0027 -1500229
-07-0028-1500231
-07-0029-1500253
07-0030-1500237
-07-0031-1500244
-07 0032-1500,3.45
07-0033 1500246
-07-0036-'!500?Si.
0^-0037-150025-)
-C-'-0038-"5UJ5'n
•Ij? 003? '500554
Audit ee
YOUNGSTOWN FY 88
LANCASTER ?Y 87
LANCASTER FY 86
CHICAGO PD FY 89
INDIANA BOH FY 89
MICHIGAN CITY FY 39
CLERMONT CO FY 89
TOLEDO Fv 89
MAJOMB CO Fy 89
Nt'XICM ,'v 88/P9
R£t "ON 05 = '.C?
ARKANSAS CE?T OF »OLLUT
SHREVEPOR!
CENHAM SPFINuS
VERDf-t*
LUTHf r
TEXHOHA PUBLIC WORKS AL
VA!i ALSTYNE
VAN ALS'YNE
BAYTOWK
SAN «UGIJST;NE
SA«f AUGUSTINE
At MA
BAY1I3WN
MIMESAl WEiLS
RUS' JS
NOWATA
EL PASO PUBLIC SERVICE
BROWNWOOO
TEL; MA
MC:iPEGOR
OP • C 1 1 1
OR? C'TY
P: '- SBUftG
MOORE
BRAZOS RIVER AUTHORITY
NUfcfES OXiNTY WC.'D #4
H'.'S'IN' TOH
ARKANSAS DEP1 OF POLLbT
GAPLAN')
HOUSTON
T^ KAt- STATE Qf
DA. L/>5 COUNTY
JL CEP>OK) PARISH
Ftnai Report
issued
OH 1.:, 2/90
OH
OH
] [_
in
iu
OH
OH
MI


ION AR
LA
LA
OK
OK
i ! H , OK
TX
TX
IX
TX
Tx
AR
'X
IX
: A
OK
BOARDTX
TX
TX
TX
TX
r>
TX
OK
TX
Tx
TX
TX
ION CAR
TX
TX
TX
TX
LA
K'/ ?- 1/90
U"1 /-_"!/ 90
', .-'^/9'
?.' ~, '9'
L '"?/>'
.,3/9-
"• • i/oi
;,. / ' y s
' ,- • : , v *

i,, '••'; /90
"•/ V9L!
1 .' -' / : /90
',' .^9"
' • :' 'VI
*/ /.'-/I
•i , /?1
i, :-/9i
'/ 2/91
' ' :9'
' • ,/91
i/ ;•'?*.
1 ' ::/91
• / 4/9'
•/-I4/9I
?/ -/91
2/ 4/«i
?' ;'/91
2/1-1V91
-/K/OI
/',"'-./ 91
2; 15/9-,
fv /;.'?' 9*.
c/;;?:/^i
3/ ",'9i
?.- 4/91
3/ .,'91
V 4/0"
1//2i.7°0
12/20/90
12/2V90
•; . - 'j i
! ' JIi; ?'
S- ,Lj- L- LA '•{'.'-' 1
CA l/;:j'ON COUNTY HEALTH OIS TX r, i/9'
TL'n'»f"BGNNE PARISH CONSOLIOATLA <-'/ -,/?1
hLiEBi.O OF PCJOAQUE
H/-RVSON
IdUSfON-GALVcSTON AREA
La, : SANA SI ATE Of-
NM
AR
COUNCTX
14
N*-' r Nr-iG", MINERALS NATURAL RMH
ftf , ", .» 06 -- 42
KANTiAS f.I "Y
I POND A Li
ROCK CRFEK PUBLIC SEWER
S": . OLAF
RLNC COUNTv
MARION COUNTY
Mt'TROrOLUAN ST. I OUIS
ROCKAUAY 3EACH
LAKE. OZW
MCPHERr.ON
BRANDON
AWit&WV
i\ AVHf
JACKSON

KS
MO
DISTMO
I A
KS
Hi
SEWERMO
MO
MO
KS
MO
IA
Kip
MO
:•'/* ','91
:• / • • , v '
:/• "•>/*!
'',-' . "/> '
1 *''-!' s'

12- 1790
1 ' 2/91
' '' 2/91
1' 2/9!
1 / ?/91
* ' ti^i ',
"M 4/91
I/ 7/91
I/ 7/51
*/ 7/91
I/ 7,/'"rl
u ?/91
1 Ji/v1
2/ 5/"?1
ineligible L'.!«<
Costs
0
0
0
A
U
n
0
Q
o
Q
47,9,3
0
Q
0
0
0
0
0
0
0
n
0
0
p
0
0
n
0
0
0
0
0
3
0
0
0
0
0
0
0
0
o
0
0
0
0
0
700,070
0
0
o
0
G
700,070
0
0
0
0
0
o
0
0
0
0
0
0
0
0
""Covs






-,


r,
0

"
0
r,
Q
0
n
rj
p
(1
0
0
r;
f!
pj
0
0
0
0
])
0
0
o
0
0
0
0
0
0
n
,'
0
0
0
o
c
"
fj
0
u
0
0
f
n
0
0
0
0
0
u
:;
3
0
               Unnecessary'       Efficiencies
               .unreasonable    (Funds Be Put
                      Costa,   To Better Use!
-------
                                                                                        Questioned Costs
Audit Control
Number

G3HWK1 -07-0040- 1500335
G3HWK1 -07-0041 -1500336
G3HUK1 -07-0043- 1500342
G3HWJ1 -07-0044- 1500346
G3HWK1- 07- 0045 -1500365
G3HWK1- 07- 0046- 1500366
G3HUK1 -07-0051 -1500368
G3HWK1 -07-0052- 1500370
G3HWK1 -07-0053- 1500371
G3HWK1 -07-0054- 1500379
G3HWK1-07-0055-1500380
G3HWK1-07-0056-1500381
G3HUK1 -07-0060- 1500382
G3HUK1 -07-0057- 1500383
G3HWK1 -07-0058- 1500384
G3HWK1 -07-0061 -1500385
G3HWK1-07-0062-1500386
G3HWK1 -07-0063- 1500387
G3HWK1 -07-0059- 1500388
G3HWK1 -07-0064- 1500396
G3HWK1 -07-0065-1500397
G3HWK1-07-0066-1500402
G3HWK1 -07-0067- 1500403
G3HWK1 -07- 0068- 1 500404
G3HWK1 -07-0069- 1500405
G3HWK1 - 07-0071 - 1 500407
G3HWK1 - 07- 0073 - 1 500408
G3HUK1 -07-0074- 1500413
G3HWK1-07-0075-1500414
G3HWK1 -07-0076-1500415
G3HWK1 -07-0077-1500416
G3HWK1 -07-0079- 1500418
G3HWK1 -07-0080- 1500419
G3HWK1 -07-0082- 1500423
G3HUK1 - 07- 0083- 1 500484
G3HWK1-07-0087-1500500
G3HWK1-07-0086-1500501
G3HU<1- 07- 0088- 1500503
N3HWK1 -07-0034- 1500247
N3HMK1 -07-0035- 1500248
N3HWK1- 07- 0042- 1500338
N3HWK1 -07-0078-1500417
N3HWK1 -07-0081 -1500422
N3HMK1 -07-0084- 1500485
N3HMK1 - 07- 0085 - 1 500492
TOTAL OF
G3HHK1 -08-0018- 1500087
G3HMJ1-08-0024-1500171
G3HMJ 1-08- 0025- 15001 72
G3HMK1 -08-0026- 15001 73
G3HMK1 -08-0032- 1500220
G3HMJ1 -08-0035- 1500256
G3HMJ1- 08- 0046- 1500465
N3HMJO-08-0085- 1500024
N3HMKO-08-0045- 1500026
N3HMKO-08-0046-1500049
N3HMK1 -08-0019- 1500090
N3HMJO-08-0044- 1500133
N3HMK1-08-0015-1500140
N3HMJ1-08-0020-1500158
N3HMJO-08-0099-1500178
N3HMKO - 08-0063 - 1 50020 1
N3HMJ1 -08-0030- 1500218
N3HMK1 -08-0031 -1500219
N3HMK1 -08-0014- 1500260
N3HMK1- 08- 0027- 1500286
N3HMK1 -08-0022- 1500291
N3HMK1 -08-0036- 1500401
Auditee

SUMMER
FARMINGTON
HERCULANEUM SEWER DISTRICT
RED OAK
MONTGOMERY COUNTY
GENOA
KEARNEY
ODESSA
ODESSA
IOWA CITY
MANSFIELD
OSAGE BEACH
SENATH
MARION CO. IMPROVEMENT DIST
CHILLICOTHE
WEST UNION
MACON
ELBA
PLEASANT HOPE
PITTSBURG
VALENTINE
ORAN
PARNELL
WELLSVILLE
LEOTI
ELLINGTON
SHEFFIELD-CHAPIN CO
WELLSVILLE
SHARON SPRINGS
CRAWFORD
BEAVER CROSSING
BEAVER CROSSING
RILEY COUNTY
IRONTON
CAMDENTON
GALENA
UN10NVILLE
ASHLAND
Final Report
Issued

MO
MO
MO
IA
KS
NE
MO
MO
MO
IA
MO
MO
MO
.KS
MO
IA
MO
NE
MO
KS
NE
MO
IA
KS
KS
MO
IA
MO
KS
NE
NE
NE
KS
MO
MQ
MO
MO
MO
JOINT BOARD OF HEALTH KANSASKS
NEBRASKA UNIVERSITY OF
OTTAWA
MERAMEC REGIONAL PLANNING
INDEPENDENCE
WICHITA
EASTERN IOWA COMMUNITY COL.
REGION 07 = 59
CHEYENNE BD OF PUBLIC UTIL.
VALLEY CITY, CITY OF
VALLEY CITY, CITY OF
GILLETTE, CITY OF
STURGIS, CITY OF
HAVRE, CITY OF
RAMSEY COUNTY
ND STATE DEPT OF HLTH
RIVERTON, CITY OF
NORTHERN CHEYENNE TRIBE
GREAT FALLS, CITY OF
SCHOOL DIST. NO. 10
FARGO, CITY OF
SIOUX FALLS, CITY OF
SOUTH DAKOTA
B1SMARK, CITY OF
PEMBINA SCHOOL DIST N0.1
RAVALLI COUNTY
OGLALA SIOUX TRIBE
BOULDER, CITY OF
DENVER CITY & CO OF
HURON, CITY OF
NE
KS
MO
KS
KS
IA

WY
ND
ND
WY
SO
MT
ND
ND
WY
MT
MT
MT
ND
SO
SD
ND
ND
MT
SD
CO
CO
SD

2/ 5/91
21 5/91
2/12/91
2/12/91
2/19/91
2/20/91
2/20/91
2/20/91
2/20/91
2/22/91
2/25/91
2/25/91
2/25/91
2/25/91
2/25/91
2/26/91
2/26/91
2/26/91
2/26/91
2/27/91
2/27/91
2/27/91
2/27/91
2/27/91
2/27/91
2/28/91
3/ 1/91
3/ 1/91
3/ 1/91
3/ 1/91
3/ 4/91
3/ 4/91
3/ 4/91
3/ 4/91
3/20/91
3/28/91
3/28/91
3/28/91
M 7/91
M 7/91
2/11/91
3/ 4/91
3/ 4/91
3/21/91
3/25/91

10/31/90
12/ 5/90
12/ 5/90
12/ 5/90
12/27/90
M 7/91
3/18/91
10/15/90
10/15/90
10/23/90
10/31/90
11/13/90
11/15/90
11/26/90
12/11/90
12/13/90
12/27/90
12/27/90
1/ 7/91
1/16/91
1/17/91
2/27/91
Ineligible Unsupported Unnecessary/ Efficient
Costs Costs Unreasonable (Funds Be f

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

0
0
0
0
0
0
0
709
0
0
0
0
0
0
84,179
0
0
0
0
0
0
0

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

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Costs To Better Ui
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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 08 =  22
84,858
48
-------
                                                                        Questioned Costs
Audit Control
Number

C3HMK1-09-011M50Q452
G3HMJ1-09-0083-1500290
G3HMK1-09-0105-1500436
N3HMK1-09-0029-1500025
N3HMK1-09-0025-1500027
N3HMK1 -09-0026-1500028
N3HMK1-09-0027-1500030
N3HMK1 -09-0028- 1500031
N3HMK1 -09-0037- 1500036
N3HMKO-09-0199-1500046
N3HMK1-09-0021-1500088
N3HHK1-09-QQ45-15Q0100
N3HMKO-09-0273- 15001 14
N3HMJ1 -09-0046- 1500125
N3HMJ1-09-0047-1500127
N3HMKO-09-0093- 1500152
N3HMKO-09-0198-1500153
N3HMKO-09-0238- 1500154
N3HMK1-09-0054-1500160
N3HMK1-09-0055-1500161
N3HMK1 -09-0056- 1500162
N3HMK1 -09-0057- 1500163
N3HMJO-09-0300-1500190
N3HMK1 -09-0061 -1500191
N3HMK1 -09-0048- 1500209
N3HMK1 -09-0075- 1500221
N3HMK1 -09-0078- 1500257
N3HMK1 -09-0079- 1500258
N3HMK1- 09-0080- 1500259
N3HMJ1 -09-0036- 1500282
N3HMK1 -09-0081 -1500283
N3HMJ1 -09-0082- 1500289
N3HMK1 -09-0084- 1500310
N3HMK1 -09-0085- 1500311
N3HMJO-09-0274- 1500313
N3HMK1 -09-0086- 1500314
N3HMK1 -09-0087- 1500315
N3HMK1-09-0088-1500316
N3HMK1-09-0089-1500317
N3HMK1 -09-0100- 1500400
N3HMK1-09-0102-1500410
H3HMK1 -09-0101 -1500411
N3HMK1-09-0103-1500412
N3HMKQ- 09-0236- 1500442
N3HMKO-09-0101-1500443
N3HMK1 -09- 0107- 1500444
N3HMK1 -09-0108- 1500445
N3HMK 1-09- 0098- 1500504
N3HMK1- 09-01 13- 1500505
TOTAL OF
G3HMK1-10-0021- 1500194
G3HMK1- 10-0024- 1500292
G3HMK1- 10-0025- 1500294
G3HMK1-10-0026-1500312
N3HMJO-10-0093-1500055
N3HMK1- 10-0007- 1500089
N3HMK1-10-0010-1500126
N3HMKO-10-0088-150Q128
N3HMJ1-10-0012-1500141
N3HMKO- 10-0053- 1500157
N3HMK1-10-0015-1500159
N3HMK1-10-0018-1500174
N3HMK1-10-0019-1500192
N3HMK1 -10-0016-1500193
N3HMJO- 10-0039- 1500200
N3HMJ1-10-0023-1500284
N3HMJ1-10 0020-1500285
Auditee

HONOLULU, CITY AND COUNTY HI
ARIZONA STATE DEQ AZ
HENDERSON, CITY OF NV
VALLEJO SAN & FLOOD CTRL DI CA
EASTERN MUNICIPAL WTR. DIST.CA
ELSINORE VALLEY MUN WTR OISTCA
LSVE OAK, CITY OF CA
SAN BERNARDINO, COUNTS OF CA
FRESNO, CITY OF CA
FEDERATED STATES MICRONESIA GU
ELKO COUNTY NV
WELLS, CITY OF NV
ALAMEDA CITY OF CA
YAVAPA! AZ
ARIZONA DEPT OF HEALTH SRVS AZ
BOULDER CITY, CITY OF NV
REPUBLIC OF PALAU GU
ASOCIACION NACIONAL PRO PERSCA
FIELDBROOK COMM. SVCS, CA
ARIZONA, UNIV. OF AZ
PETALUMA, CITY OF CA
MADERA COUNTY CA
PIMA COUNTY AZ
EMERYVILLE, CITY OF CA
NEVADA STATE OF NV
LAKE OROVILLE AREA P.U.D. CA
NOVATO SANITARY DISTRICT CA
FORTUNA, CSTY OF CA
DUNSMUIR, CITY OF CA
TENNANT COMMUNITY SVCS DIST MD
OROSI PUBLIC UTIL DISTRICT CA
SOUTH LAKE TAHOE, CITY OF CA
NAPA, COUNTY OF CA
MARIPOSA, COUNTY OF CA
CALIFORNIA, STATE OF CA
NEVADA, COUNTY OF CA
CENTRAL MARIN SANITA1ION CA
MONTEREY BAY UNIFIED AIR POLCA
LAKE, COUNTY OF CA
GOLETA SANITARY DISTRICT CA
PIEDMONT, CITY OF CA
BERKELEY, CITY OF CA
SACRAMENTO, COUNTY OF CA
KAUAI . COUNTY OF hi
GUSTiNE, CITY Oc CA
FJELDBROOK COMM. SVCS. CA
SANTA CLARA VALLEY Ul R DIST CA
AVALON, CITY OF CA
PACIFICA, CI'Y OF CA
REGION 09 = 49
LANE REG. AIR POLL AUTH OR
GRESHAM, CITY OF OR
FAIRBANKS NORTH STAR BOROUG.AK
ATHENA, CITY OF OR
KING COUNTY WA
SALEM, CITY OF OR
SHOSHONE-BANNOCK TRIBES, INCID
COLVILLE CONF. TRIBES WA
ALASKA DEPT OF EDUCATION AK
LEWISTON, CITY OF ID
LANG COUNCIL OF GOVT.'S OR
IDAHO, UNIVERSITY OF ID
NATL PAC/ASIAN RES CTR AGINGUA
LANE COUNCIL OF GOVERNMENT OR
SPOKANE, CITY OF WA
SPOKANE, CITY OF WA
SEATTLE, CITY OF WA
Final Report
issued

3/13/91
1/17/91
3/ 7/91
10/15/90
10/15/90
10/15/90
10/15/90
10/15/90
1 3/ ",6/90
10/19/90
'0/31/90
IV V90
IV 6/90
IV 7/90
IV 7/90
11/20/90
11/20/90
11/20/90
11/27/90
11/27/90
11/27/90
1V27/90
12/12/90
12/12/90
12/20/90
12/27/90
V 7/91
V 7/91
I/ 7/91
1/16/91
1/16/91
1/17/91
V 29/91
V29/91
1 / 29/91
1/30/91
1/30/91
1/30/91
1/30/91
2/27/91
3,-' 1/91
3/ 1/91
3/ 1/91
3/12/91
3/12/91
3/12/91
3/12/91
3/28/91
3/28/01

12/13/90
1/17/91
V 17/91
1/29/91
10/24/90
10/31/90
IV 7/90
1V 7/90
11/15/90
1 V26/90
11/27/90
12/ 5/90
12/12/90
12/12/90
12/13/90
1/16/91
V 16/91
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
19,033
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
19,033
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
c
c
0
0
0
0
c
ij
f)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
c
0
0
c
0
0
0
0
0
Costs To Better Use)
0
0
0
0
0
0
0
0
0
("i
0
3
a
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
TL'TAl. OF REGION 10 =   17
TOTAL OTHER GRANT ,*X! !S
                                                         1,995,395
142,245
2,790
-------
                                                                                    Questioned Costs
Audit Contro!
Number
Auditee
5. SUPERFUND GRANTS
E5BICLO-Q5-0402-1100104  CINCINNATI U OF

              TOTAL OF REGION 05 =   1
                             OH
                                 Final Report
                                 Issued
                                    1/16/91
P5BGNO-06-0111-1300016  NEW MEXICO HEALTH & ENV DEPTNM    11/ 2/90
P5BFNO-06-0117-1300041  DEPT. OF HEALTH             OK     37 6/91
P5BFNO-06-0118-1300042  OEPT OF HEALTH              OK     3/ 8/91

              TOTAL OF REGION 06 =   3

P5CG*8-10-0076-1100146  WASHINGTON DEPT OF ECOLOGY  WA     3/20/91
P5CG*8-10-0084-1100156  ALASKA DEPT OF ENV CONSER   AK     3/29/91
P5CHN9-10-0155-1300047  WASHINGTON DEPT OF ECOLOGY  WA     3/26/91

              TOTAL OF REGION 10 =   3

M5E1FL1-11-0011-11000Q5  SF IAG CORPS OF ENGINEERS         10/12/90
M5BFL1-11-0013-1100054  SF -IAG NASA                      10/31/90

              TOTAL OF REGION 11 =   2

              TOTAL SUPERFUND GRANTS                  =    9

Ineligible
Costs
48,,?63
48,263
34,592
30,434
46,906
111, 932
9,155
115,499
25,718

Unsupported
Costs
0
0
115,543
0
0
115,543
212,909
319
0

Unnecessary/
Unreasonable
Costs
0
0
0
0
0
0
0
0
0

Effieienci
(Fund: Be F
To Better Ui









                                                 150,372
213,228
                                                 310,567
328,771
8. OTHER CONTRACT AUDITS
D8AMLO-01-0292-1100000
D8AMLO-01- 0273- 11 00001
D8AHLO-01 -0289- 1100022
D8AMLO-01-0288-1100023
D8BMLO-01-0249-1100024
D8AMLO-01 -0304- 1100047
D8AML1 -01 -0045- 1100048
D8AMLO-01-0303-1100049
D8AML1-01-0044-1100050
D8AML1 -01 -0050- 1100051
D8AHL1 -01 -0048- 1100052
D8AML 1-01 -0049- 11 00064
D8AML1 -01 -0046- 1100065
D8AML1 -01 -0062- 1100092
D8AML 1-01 -0063- 11 00093
D8AML 1-01 -0066- 11 00094
D8CML1-01-0065-1100095
D8CML1-01-0061-1100096
D8AML1 -01 -0064- 1100097
D8AML1-01-0085-1100098
D8CML1-01-0096-1100138
D8CML1-01-0093-1100139
D8AML1-01-0111-1100144
TOTAL OF
D8CMLO-02-0336-1100006
D8APLO-02-0340- 1100007
D8CML1 -02-0033-1 100055
TOTAL OF
D8AHL 1-03-0038- 1100031
D8BHL1-03-0041-1100032
D8DHL1 -03-0042- 1100033
D8DML1- 03- 0043- 11 00034
D8DHL 1-03-0044- 11 00035
D8DML1-03-0045-1100036
D8DML1-03-0046-1100037
D8AML 1-03-0035- 11 00038
D8AML1 -03-0036- 1100039
D8AML1 -03-0039- 1100042
D8AML 1-03- 0040- 11 00043
D8AML1 -03-0047- 1100044
D8DML1-03-0061-1100059
D8AHL1-03-0062-1100060
D8DML1-03-0063-1100061
D88ML 1-03 -0064- 1100062
D8CML1 -03-0099- 1100109
ALLIANCE TECHNOLOGIES
ABT ASSOCIATES, INC.
EASTERN RESEARCH GROUP
EASTERN RESEARCH GROUP
ALLIANCE TECHNOLOGIES
ABB ENV. SERVICES, INC.
ABB ENV. SERVICES, INC.
TRC ENV. CONSULTANTS INC)
ABB
ALLIANCE TECHNILOGIES INC
ALLIANCE TECHNOLOGIES INC
ALLIANCE TECHNOLOGIES INC.
ABB ENVIRONMENTAL SERVICES
ARTHUR D LITTLE, INC.
ARTHUR D LITTLE, INC.
CAMBRD1GE SYSTEMATIC, IMC.
ARTHUR D LITTLE, INC.
ABB ENVIRONMENTAL SERVICES
CAMBRIDGE SYSTEMATICS, INC.
INTERNATIONAL FUEL CELLS
MA
MA
MA
MA
MA
ME
ME
CT
ME
MA
MA
MA
ME
MA
MA
MA
MA
ME
MA
CT
TRC ENVIRONMENTAL CONSULTANTCT
TRC ENVIRONMENTAL CONSULTANTCT
ABB ENV. SUS INC.
REGION 01 = 23
HAZEN & SAWYER, PC
SYRACUSE RESEARCH CORP
ECOLOGY AND ENVIRONMENT
REGION 02 = 3
E.H. PECHAN & ASSOCIATES
NUS CORPORATION
WAPORA INCORPORATED
KENDRICK & COMPANY
MERCURY CONSOLIDATED
MERCURY CONSOLIDATED
MERCURY CONSOLIDATED
INTERNATIONAL SCI & TECH
PACIFIC ENVIRO SERVICE
BREGMAN & COMPANY INC
SRA TECHNOLOGIES TNC
HAMPSHIRE RESEARCH
. BOOZ ALLEN & HAMILTON INC
ETS INC
STANDARD TECHNOLOGY INC
NUS CORPORATION
ENERGY & ENVIRONMENTAL ANAL
ME

NY
NY
NY

VA
MD
VA
DC
VA
VA
VA
VA
VA
MD
VA
VA
MD
VA
MD
MD
VA
10/ 2/90
10/ 2/90
10/17/90
10/17/90
10/17/90
10/29/90
10/29/90
10/29/90
10/29/90
10/29/90
10/29/90
11/14/90
11/14/90
V 9/91
17 9/91
17 9/91
M 9/91
1/10/91
1/10/91
1/14/91
37 5/91
37 5/91
3/14/91

10/12/90
10/12/90
117 1/90

10/22/90
10/22/90
10/22/90
10/22/90
10/22/90
10/22/90
10/22/90
10/22/90
10/22/90
10/23/90
10/23/90
10/23/90
11/13/90
11/13/90
11/13/90
11/13/90
1/25/91
                                                                     *The dollar value of contract audits have not been shov.
                                                                      Public  disclosure of the dollar value of financial rec
                                                                      mendations could prematurely reveal the Governmenf's
                                                                      negotiating positions or release of this information i
                                                                      not routinely available under the Freedom of Informati
                                                                      Act.   The number of these reports and dollar value of
                                                                      the findings have been  included  in  the  aggregate  data
                                                                      displayed below.  Such  data individually excluded in
                                                                      this  Listing  will be  provided to  the  Congress under
                                                                      separate memorandum within 30 days  of the transmittat
                                                                      the semiannual  report to the agency head.   The
                                                                      transmitted data will contain appropriate cautions
                                                                      regarding disclosure.
-------

Audit Control Auditee
Number

D8CML1-03-0100-1100110 ENERGY & ENVIRONMENTAL ANAL VA
D8CML1-03-0101-1100111 NAT'L ACADEMY OF SCIENCES DC
D8BML1-03-0102-1100112 CRC SYSTEMS INC VA
D8AML1-03-0103-1100113 DYNAMAC CORPORATION MD
D8AML1-03-0104-11001U KEVRIC COMPANY MD
D8CML1-03-0105-1100115 SOBOTKA & COMPANY INC DC
D8AML1-03-0106-1100116 BOOZ ALLEN & HAMILTON PA
D8EML1-03-0107-1100117 BIONETICS CORPORATION VA
D8BML1-03-0116-1100120 NUS CORPORATION MD
D8CML1-03-0115-1100121 E.H. PECHAN & ASSOCIATES VA
D8DML1 -03-0114-1100122 PENNSYLVANIA STATE UNIVER PA
D8AML1-03-0113-1100123 ASCI CORPORATION VA
D8DML1-03-0112-1100125 MERCURY CONSOLIDATED VA
D8AML1-03-0111-1100126 NUS CORPORATION MD
D8AML 1-03- 01 17- 11 001 27 JACA CORPORATION PA
D8DML1-03-0118-1100128 ENGINEERING COMPUTER OPTECH MD
D8AML1 -03-01 19- 1100129 BREGMAN & COMPANY INC MD
D8AML1 -03-0120- 1100130 ROY F. WESTON PA
D8CML1-03-0121-1100131 NAT'L ACADEMY OF SCIENCES DC
TOTAL OF REGION 03 = 36
D8DML1-04-0029-1100010 SOUTHERN RESEARCH INSTITUTE AL
D8AML1-04-0030-1100011 RESEARCH & EVALUATION ASSOC NC
D8AML1 -04-0031 -1100015 SOUTHERN RESEARCH INST AL
D8BML1-04-0032-1100016 WILLIAMS-RUSSELL JOHNSON GA
D8AML1 -04-0036- 1100030 SOUTHERN RESEARCH INSTITUTE AL
D8CML1 -04-0076- 1100070 ENVIRONMENTAL SCIENCE £ ENG FL
D8DML 1-04-0081 -1100089 NSI TECHNOLOGY SERVICES CORPNC
D8DML1 -04-0017- 1100106 NSI TECHNOLOGY SVCS CORP RTPNC
D8AMLO-04-0402-1100134 RESEARCH TRIANGLE INSTITUTE NC
D8AML1-04-0147-1100135 RESEARCH & EVALUATION ASSOC NC
D8AML1 -04-0156- 1100140 MASON & HANGER KY
H8AML1 -04-0027- 1100008 RESEARCH TRIANGLE INSTITUTE NC
H8AML 1-04 -0028- 11 00009 RESEARCH TRIANGLE INSTITUTE NC
TOTAL OF REGION 04 = 13
D8AML1-05-0122-1100079 LIFE SYSTEMS INC OH
D8AML1 -05-0041 -1100103 FRED DEBRA CO OH
D8CMN1-05-0083-1300017 LIFE SYSTEMS INC OH
E8AXN1-05-0174-1400011 PRC EMI IL
P8CXN1 -05-0131 -1300031 OHM REM COE OH
TOTAL OF REGION 05 = 5
D8AAL1-06-0019-1100012 RADIAN CORPORATION TX
D8AML1 -06-0021 -1100013 RADIAN CORPORATION TX
D8AAL1-06-0022-1100014 RADIAN CORPORATION TX
D8CML1 -06-0026- 1100071 RADIAN CORPORATION TX
D8CML1 -06-0031 -1100088 RADIAN CORPORATION TX
D8CML 1-06- 0042- 11 00091 RADIAN CORPORATION TX
D8CAL 1-06- 0068- 11 001 32 RADIAN CORPORATION TX
TOTAL OF REGION 06 = 7
D8BGL1 -07-0018- 1100025 BLACK & VEATCH WASTE SCIENCEMO
D8CHL1 -07-0019- 1100040 DEVELOPMENT PLANNING & RESCRKS
D8DML 1-07- 0020- 11 00053 DEVELOPMENT PLANNING & RESC KS
TOTAL OF REGION 07 = 3
D8DML1 -09-0023- 1100003 TRW, INC
D8DML1 -09-0024- 1100004 AEROSPACE CORPORATION, THE CA
D8AML1 -09-0038- 1100017 ENERGY ENV. RESEARCH CORP. CA
D8AML1 -09-0039- 1100018 S-CUBED CA
D8CML1 -09-0040- 1100019 ENERGY & ENV. RESEARCH CORP CA
D8DML1 -09-0031 -1100020 ROCKWELL INTL., CORP. CA
D8BML1-09-0030-1100021 AEROSPACE CORP., THE CA
D8BML1 -09-0041 -1100028 EDAW, INC. CA
D8BML 1-09- 0042- 11 00029 EDAW, INC., CA
D8DML 1-09-0043- 11 00046 GEO/RESOURCES CONSULTANTS CA
D8CAL1 -09- 0051 -1100063 ENERGY & ENV RESEARCH CORP CA

Final Report
Issued

1/25/91
1/25/91
1/25/91
1/25/91
1/25/91
1/25/91
1/25/91
1/25/91
21 5/91
21 5/91
21 5/91
21 5/91
21 7/91
21 7/91
21 7/91
21 7/91
21 7/91
21 7/91
21 7/91

10/12/90
10/12/90
10/16/90
10/16/90
10/19/90
12/ 6/90
12/21/90
1/18/91
2/28/91
2/28/91
3/ 6/91
10/12/90
10/12/90

12/19/90
1/16/91
1V 2/90
3/ 8/91
21 1/91

10/15/90
10/16/90
10/16/90
12/11/90
12/20/90
M 2/91
2/20/91

10/17/90
10/23/90
10/30/90

10/ 5/90
10/ 5/90
10/16/90
10/16/90
10/16/90
10/16/90
10/16/90
10/18/90
10/18/90
10/25/90
11/13/90
Recommended
Ineligible Unsupported Unnecessary/ Efficiencies
Costs Costs Unreasonable (Funds Be Put
Costs To Better Use)































































-------
Audit Control
Number
D80ML1 -09-0052- 1100067
D80ML1 -09-0053- 1100068
D8CWL1 -09-0058-1 100069
D8CML 1-09- 0062- 11 00072
D8CML1 -09-0063- 1100073
D8BML1-09-0064-1100074
08CML 1 - 09-0066- 1 1 00080
D8CAL1 -09-0067- 1100081
D8CBL 1-09- 0068- 11 00082
D8CML1 -09-0069- 1 100083
D8CML 1-09- 0070- 11 00084
D8CML 1-09- 0071 -1100085
D8CML1 -09-0072- 1100086
D8AWL1 -09-0074- 1 100090
D8CPL1-09-0093-1100119
D8CML1-09-0109-1100142
08CML1 -09-01 10- 1100143
D88ML1 -09-01 12- 1100150
D8AMN1 -09-0019- 1300000
D8BMN1 -09-0033- 1300006
D8BHN1 -09-0032- 1300007
D8ABN1 -09-0060- 1300019
TOTAL OF
P8AXL1-10-0017-1100124
P8AXN1-10-0006-1300033
Auditee
TRW IMC.. ENERGY DEVEL GRP
TRW INC., SPACE & TECH GRP
JACOBS ENG. GRP., INC.,
ENERGY & ENV. RES. CORP.
ENERGY & ENV. RES. CORP.
SCIENCE APPLICATIONS INTL.
ENERGY & ENV RESEARCH CORP
ENERGY & ENV RESEARCH CORP
ENERGY & ENV RESEARCH CORP
ENERGY & ENV RESEARCH CORP
ENERGY & ENV RESEARCH CORP
ENERGY & ENV. RES. CORP.
ENERGY & ENV RES CORP
TETRA TECH, INC
SRI INTERNATIONAL
ENERGY & ENV RESEARCH CORP
IT CORP
ROCKWELL INTL CORP
SCIENCE APPLIC INTL CORP
ROCKWELL INTL., CORP.
ROCKWELL INTL. CORP.
SCIENCE APPLICATIONS INTL
REGION 09 = 33
CH2M HILL DOE PRE-AWARO
RES NAVY PREAWARD
	 i iv? win* ii ioiiui
Final Report Ineligible Unsupported Unnecessary/ Effic ienci
Issued Costs Costs Unreasonable (Funds Be P
Costs To Better Us
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA

OR
OR
11/20/90
11/20/90
11/27/90
12/12/90
12/12/90
12/13/90
12/19/90
12/19/90
12/19/90
12/19/90
12/19/90
12/19/90
12/19/90
12/27/90
21 4/91
3/13/91
3/13/91
3/28/91
10/ 2/90
10/16/90
10/16/90
12/ 7/90

2/ 6/91
2/ 7/91
              TOTAL OF REGION 10 =   2
              TOTAL OTHER CONTRACT AUDITS
                                                      =  125
                   347,867
                            581,816
195,204
10,122,54,
9. SUPERFUND CONTRACTS

D9BGL1-02-0049-1100075  ECOLOGY AND ENVIRONMENT     NY    12/17/90

              TOTAL OF REGION 02 =   1

P9CHL9-03-0070-1100102  BES ENVIRONMNTL SPECIALIST  PA     1/16/91

              TOTAL OF REGION 03 =   1

P9AHP1-04-0100-1400008  WESTINGHOUSE-HAZTECH        GA     3/ 6/91

              TOTAL OF REGION 04 =   1
P9DHL9-05-0348-1100087  MAECORP INC FY 88
P9BGLO-05-0266-1100159  WW ENG & SCI FY 89
P9CHN9-05-0178-1300013  OHM REM FY 85/86
P9EHNO-05-0079-1300021  OHM REM
P9AHN1-05-0135-1300040  OHM REM ERCS R4

              TOTAL OF REGION 05 =   5

D9BGL1-08-0001-1100002  ROGERS & ASSOC ENG CORP

              TOTAL OF REGION 08 =   1
OH
MI
OH
OH
OH
12/20/90
 3/29/91
10/26/90
12/12/90
 2/28/91
UT    10/ 2/90
P9DHL9-10-0110-1100108  RES FY86  INDIRECT COSTS     OR     1/24/91
P9AHN1-10-0009-1300030  RES PREAWARD RFP W903495C1  OR     1/29/91
P9AHN1-10-0022-1300052  RES-ERCS  REGION IV PREAWARD OR     3/27/91

              TOTAL OF REGION 10  =   3
              TOTAL SUPERFUND CONTRACTS               =    12
                          0
                    258,983
                                   0
                           1,331,775
              10,885,801
              15,333,66?
              TOTAL AUDITS =   748
                 32,493,917     54,475,240
                                           5,614,382
              45,441,75'
 HDQ 771 - - REPORTS  ISSUED BY  TYPE AUDIT AND REGION
           SEMI-ANNUAL PERIOD  ENDING  3/31/91
-------
        Appendix—2  Audits  Without
 THE  INSPECTOR  GENERAL  ACT REQUIRES A  SUMMARY OF E4CH AUD;T DEPOn   iS-SUEL  eF-"';i;.
 REPORTING PERIOD FOR WHICH NO MANAGEMENT DECiSlON HAS BEEN MADE BY fHc: T.NO Of  "HL »F-'
 'MATE AND TITLE OF EACH SUCH REPORT;, AN EXPLANATION OF THE REASONS SUCH yANAfiE>*EN r L' {'
 A STATEMENT CONCERNING THE DESIRED TIMETABLE FOR  ACHIEVING A MANAGEMENT Dt'T.-SIO'v •.
 orovides the summary, the  date and title of each such report. The Aga^cy provides the exp'anntan ""' 'he '«,>-
 not been made, and a  statement concerning the desired timetable for achieving a management daots>K  .•'< -•• .
 'G Foiiowup Status Codes of Agency's Response at 9/30/90:

 1  No Response
 2 Incomplete Response Received
 3 Proposed Response Received Awaiting Final Determination
 4. Proposed Response Received in  Review Process
 5 Final Response Received in Review Process
 6 In  Pre-ARB Referral Process
Assignment Control     Title
Number
Final Report
      Issued
Assignment Control
Number
"Rile
Final Report
      issued
ASSISTANT ADMINISTRA10H FOR AIR AND RADIATION
r'fjA.T'•"6-;bOQ'l 'IOH134     C^S  ADMIN O1  PirNA' f,t  OIH'W1.-'
'Summary, OM<^ MAS NO*  'ME' FMFNT'i Al i IHF  RFCDMV:NijATr\" 'N OiiR
•:iHbR';°oRr  AMON-, ;HI\SE NOT 'VPITWFNTED WERE RfooMMLvv.Dw; wui
 N;;'R! r'(AJ  Pf-NAi "x PCliCES AC»;f VVr'< f.'A PC'Pf  ANi' "Ar.F ; AH- o
 'MS! v AND WiJHiN Gl'.DLiNFS
  FXIIANAIION Of TIM REASONS MANAGIMFNT DECISION (IAS NOT HUN MADf
"V'GF OF AIR AND RADIATION RFSF'ONDFO TO 1H>  OiG Bv 1 "
vDE.;,"'NAE INECHMATON W'LL BE RCA'.Y  S<'RT i'
  DfSIRFDTIMf [ABU FOR ACHIEVING A MANAGE MINI INCISION •*•'•  M  I:!   .
ASSlSIANr ADMINISTRATOR FOR WA11H
MtiWF9 C6 02b! Oni~ix>OG     liStT r-)A!:r,t SYSU.M   *>:.
"Summary  CnIR REV'EW i-nDNC THA' C-A IS N0f ENS'JRIV, "MAT $;-;, RniiO
>>'WV 1C INVFSTMfNT 'N A'WiDS !S Rt Nt, SA: trii;ARrjED FR'iM Pt 'FR'ORATiON
W EN'SljH'NG THAi  Gf-:AN7!JS GL'\!RArt ::i,'Fi:::,iiNT RtVSNiJt  IHROliCH AOfOiJ
 ,S[F- i-.HAR^E SVSltW" 10 PROPER,-' JPERATS  MAIN'AIN, AND 'ifPLAOL W',\rl)
  IXPIANA1ION Of mi RtASONS MANAGtMrNT ITCkSION HAS NOT FtFFN MADT
;Hf  HNAl  DfTfRMlNAJiON (l^'rR ',\AS i;Rf^ARrD AND •? P,[ ING RFVifWED BE; '
nil' Ait T:; 1H[ 0:G  AN iNT[RNAl  ;r'iRfjAM/i 'OS GAL.^L'J l;flAV; IN 1HF ' '
:-Pr,CES3
 - D1SIRFD TIME lABtF iOH ACHIEVING A MANAGfMINF EXCISION rx»!ni;
-IFHVJ'iON iS  9/30  01
••'; ; ."i: i OWUP STAHJS AT 3, ''•;•'  ,,•"

DIRECTOR, WATtR iWISION, REGION IV
S')rWN8 04 'j24Q ^30nr)B?     I'Ni^N,'*'  "Ni                          •-
Summary. THi  nRAM:Fl" ;,LA!M! u $;=0 7'1 '• '5f ArMIN'1 'RAT'v'( i\'GI\[f RIW: ANfi
i''iN;.IRUL'T'ON C.OSTr  !HAT WERE NO1  Ei \r,W f  IN A'l"rif>\ |l/'BR90i
Nil if.llilF  COS'S Wtp! ",l AIMED i jR r'i! A,iri"'NO  -V1-,  $?ioi'"f!F
DN'-uPPORTLC COMS -A'ERF  CLAIMED
 i3CPlANATK)N Of 1KT REASONS MANAGfMfNT EUCISION t!AS NOT HI EN MAffl
AUO11 ADDRESSED '"OMPLFX INNOVAT'VE  AND At TEPNAFIVt  FUNDING i.SS'JFS  'ftHlf
RPD^IRED ADDiTIONAI  F!Mi  TO WOSf OLT Tt«r  Df'A;1 .-: vV'TH TE'F OV,  OIG AND
MANAi.FMbNT Al-it NOvV N AGREFM^J'   1 (NA' DUJ RMINA1 ,()N WA1 ;-Pi PAR; D  n
1'?9'ri!
  FJfSIRFD l!Mf TABU  EOR ACHIEVING A MANAGE MTNI EXCISION Al)~:i W'U fir
dP.'FO SHO»Tlv
:". ' lilDWM'  SFA'j,, A i'3! -11  '
                   PROCUREMENT CONTRACTS MANAGTMINT DIVISION
                   Durham Cost Advisory Branch
                   D8AMLO-03 C438 010051 :>     Cl'-MINT ;N;FRNATiONAl  VA
                   "Summary
                     EXPLANATION Of Till REASONS MANAGEMENT DECISION HAS, N01 BEEN MAEX
                   'CONTRACT HAS NOT  BF_fN AWARD1-" "J  it;  N-C^OAilONS ARF ST'li BENDING
                   -- DESIRED TIME TABI E (OR ACHIEVING A MANAGEMI NT OlCkSION Rt COI ,,T ON
                   EXPECTED BY MAY 31  199"
                   iG FOll OWUP STATIC A1  '• 31/91  i"

                   PROCUREMENF CONTRACTS MANAGE MENI DIVISION
                   Financial Analysis Section
                   P9A«N9-05-OW-03rO03o     OH MAn'R Al S (PPrGPAiE-I  OH
                   Summary WE HAVF '^COMMENDED R'-Dij: TI0^;^. OF $6/0:'')0 ;0 nPC^'t
                   F-ATES FOR [Ci'Jl^MEND pR!MAR|iv Bt^'AUS1 '•  KRRORS :N Uiiij/ATiON yElllODS
                   ADJUSTMENTS :OP r'^iy DEPRECI,AirD tC-'H-'MENl AND  iN"UPPOR!rD 'SilMAlj
                   AND ASSUMF'FIO.NS Br  FhE OON'RAdO!-
                     EXPLANATION Of THE REASONS MANAGIMTN! EXCkSION iWS NOT BUN MAIX-
                   CONTRACT HAS NOT  r'l FN AWARDED  HI  Nf  "/JiA'iQNS AP: '-.'I: :'!N.'INO
                   - DESIRED E1ME 1ABU IOH ACHIEVING A MANAGEMENT DECISION
                   IG FOLEOW1P ,-TAiUS A1  » ''i qi  ",
                   P9AHNO ^ n2-o'i f 3;in04''     OH VA'. V\ ;> !>JR i 0 PATt Si  "H          -1/7/90
                   Summary WF  nECOMMtNDED $162,'"4;i ,N r-i iCifNOifS DUE '0 PROPOSFiJ EQUIPMENT
                   RA[/S 1) EU!  pi; '",'F P W1'  ,H  A'A'-> Opiiji\AiLv
                   ?PA'>iD )NS R AN'''HFH AUDD  NUMR! «  r1'ii 'A'-S NC1 • :i D 0" '^'S A1 F) f'S S'AIU'-
                   AN" vV!'_i ;   '-"  T'   \  S " Shi> T, •  "
                     (JfSfl«E) IIMf TATSil (OH ACHIEVING A MANAGE MINI [XC&ION
                   'i, rO( OvV ,- -AT C A'  1 31/9'  '"
                   Summary WF icCOMW-NDEEi $634 HO1-, '\ 'H :,irNGi[<; r,i
                   RA;FS. n LXI/TUIN'"; ( ON:RAO; r tn 'N. , •;. VR;<: II;JNS ">N
                   ESTiMAlED '.P OFHrR THAN ACrilAl COS1 DATA
                     EXPLANATION OE  IHf RFASONS MANAGEMENT DECISION HAS NOI BUN MAIX
                   CON'RAf I -:AJ NCC RFFN AWARD'? v' "  S' CO CAT'ONS AR[ -  rl; (  PFNCiN")
                   - IX SIRED STME TABIf. K)R ACHIIVING A MANAGEMENT (XCkSION
                   iG :Ci , OW'.1' S'AU"; A  i'S'.Q'  ' .,
-------
 Assignment Control
 Number
Title
Final Report
      Issued
Assignment Control
Number
                                                 Title
Final Ftepoi
      Issue
 REGION 5 GRANTS FINANCIAL MANAGEMENT
 P2CWL9-05-0324-0100464     SUMMIT & PORTAGE GO'S  OH              8/29/90
 Summary: THE GRANTEE CLAIMED $310,720 OF INELIGIBLE ENGINEERING AND
 CONSTRUCTION  COSTS AN ADDITIONAL $6,418,581  OF UNSUPPORTED, AND $104,165
 OF UNREASONABLE ENGINEERING AND CONSTRUCTION COSTS WERE CLAIMED
 - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE-. THE
 REPORT COVERS SEVERAL ISSUES INCLUDING  COMPLEX CHANGE ORDER ISSUES
 BECAUSE OF THE VOLUMINOUS DETAILED DOCUMENTATION SUBMITTED BY THE
 GRANTEE, ADDITIONAL TIME WAS NECESSARY  TO PROVIDE A QUALITY  ANALYSIS
 = DESHED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
 RESOLUTION IS  6/15/91
 IG FOLLOWUP STATUS AT 3/31/91, [3]

 P2CWL8-05-0282-0100490     SUMMIT CO  OH                          9/24/90
 Summary. SUMMIT COUNTY, OH CLAIMED $4,737,879 OF  INELIGIBLE ENGINEERING  AND
 CONSTRUCTION  COSTS  AN ADDITION $3,290,207 OF UNSUPPORTED  ENGINEERING  AND
 CONSTRUCTION  COSTS WERE CLAIMED
 - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: THE
 REPORT COVERS SEVERAL ISSUES INCLUDING  COMPLEX CHANGE ORDER ISSUES
 BECAUSE OF THE VOLUMINOUS DETAILED DOCUMENTATION SUBMITTED BY THE
 GRANTEE, ADDITIONAL TIME WAS NECESSARY TO PROVIDE A QUALITY  ANALYSIS
 =  DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
 RESOLUTION IS  6/15/91
 IG FOLLOWUP STATUS AT 3/31/91: [1]

 P2CWN7-05-0087-0300059     CLEVELAND NEORSD OH                   6/29/90
 Summary: WE QUESTIONED INELIGIBLE  COSTS Of $443,491 OF ENGINEERING COST
 CLAIMED BECAUSE THEY WERE INCURRED AFTER THE APPROVED CONTRACT COMPLETION
 DATE OR THEY RELATED  TO  INDIRECT COSTS IN EXCESS OF ACTUAL   WE ALSO
 QUESTIONED UNSUPPORTED  $125,226
 - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:" A
 FINAL DETERMINATION LETTER WAS ISSUED ON 10/03/90 FOR THIS AUDIT  OIG
 INDICATED THAT THEY CLOSED THE AUDIT 12/19/90  EPA IS WORKING WITH THE OIG
 TO CLEAR THIS  AUDIT FROM THE OVERDUE TRACKING SYSTEM
 =  DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION:
 IG FOLLOWUP STATUS AT 3/31/91: [5]

 P2CWN8-05-0494-0300065     SHEBOYGAN  Wl                          6/14/90
 Summary: THE GRANTEE CLAIMED $69,699 FEDERAL  SHARE OF INELIGIBLE COSTS
 THESE COSTS CONSIST OF EXCESSIVE START-UP COSTS,  INELIGIBLE PAYROLL COSTS
 AND OTHER A/E  FEES CLAIMED  ALSO, THE GRANTEE CLAIMED $42,019 FEDERAL
 SHARE OF UNSUPPORTED ENGINEERING COSTS
 - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE:
 REPORT HAS  COMPLEX TECHNICAL ISSUES REGARDING EXCESSIVE START-UP COSTS
 WHICH TOOK EXTENSIVE AMOUNT OF  TIME FOR REVIEW OF DOCUMENTATION WHICH WAS
 NOT SUBMITTED UNTIL 1/16/91.
 =  DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
 RESOLUTION IS 3RD QUARTER 1991
 IG FOLLOWUP STATUS AT 3/31/91 • [3]

 P2CWN9-05-0336-0300076     WELLSVILLE  OH                          8/ 6/9C
 Summary: OVER  $1,9 MILLION QUESTIONED BECAUSE OF THE GRANTEE'S FAILURE TO
 REHABILITATE ITS SEWERS
 - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: FINAL
 DETERMINATION  CANNOT BE MADE UNTIL SEWER SYSTEM  EVALUATION SURVEY (SSES)  IS
 COMPLETE, GRANTEE HAS SIGNED CONSENT DECREE--SSES TO BE SUBMITTED ON
 7/1/92. OIG WILL NOT REINSTATE COSTS UNTIL SSES HAS BEEN SUBMITTED AND
 APPROVED.
 =  DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION:
 IG FOLLOWUP STATUS AT 3/31/91 [11

 N3HMKO-05-0143-0500671      WAYNE CO FY 88  Ml                      3/20/90
 •Summary: COUNTY MAY  HAVE EARNED AND RETAINED $12,060  IN INTEREST ON
 EXCESSIVE FEDERAL FUNDING OF $186,000.
 - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: THE
 GRANTEE HAS NOT RESPONDED TO THE AUDIT FINDINGS   THE REGION  HAS CONTACTED
 THE GRANTEE REGARDING THE REFUND DUE. PAYMENT IS  EXPECTED SHORTLY
 =  DESBED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION: EXPECTED
 RESOLUTION IS 4/30/91.
 IG FOLLOWUP STATUS AT 3/31/91 [1]
                                                    P2CWN4-05-0183-5100159     EUCLID  OH                              7'|2
                                                    Summary: WE QUESTIONED THE ENTIRE GRANT AWARD OF ALMOST $143  MILLION THI
                                                    GRANTEE FAILED TO MEET GRANT CONDITION NO. 3 AND OPERATE THE PLANT
                                                    SUFFICIENTLY TO MEET IT NPDES PERMIT
                                                     EXPLANATION Of  THE REASONS MANAGEMENT DECISION HAS NOT BEFN MADC: THE
                                                    GRANTEE IS IN LITIGATION WITH THEIR CONTRACTOR OVFR INCURRED COSTS  THE
                                                    AGENCY MUST AWAIT THE OUTCOME OF  THAT LEGAL PROCESS BEFORE  COMF1 ETiNG
                                                    THE MANAGEMENT DECISION
                                                    = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION
                                                    IG FOLLOWUP STATUS AT 3/31/91  [3]
                                                    P3DWL1-05-0360-5100559     PRC ENG CT FY 80/81  IL                  9/25
                                                    'Summary WE  RECOMMENDED OVERHEAD RATES OF  14536 PERCENT AND 131  73
                                                    PERCENT FOR FISCAu YEARS 1981  AND  1980, RESPECTIVELY
                                                    - EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE
                                                    PRELIMINARY DETERMINATION HAS BEEN ISSUED THE REGION IS AWAITING LEGAL
                                                    ADVICE FROM REGIONAL COUNSEL
                                                    = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION: TARGETED FINAL
                                                    DETERMINATION DATE IS 5/30/91
                                                    IG FOLLOWUP STATUS AT 3/31/91  [2]

                                                    P2CWN4-05-0357 6100389     DETROIT WSD  Ml                         8/2b,
                                                    Summary: THE CITY  OF DETROIT, Ml CLAIMED OVER $169,000 OF UNREASONABIE
                                                    ENGINEERING COSTS
                                                    - EXPLANATION OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADC: BASE!
                                                    ON RECENT  GUIDANCE FROM HEADQUARTERS, THE REGION IS IN THL PROCESS OF
                                                    IMPLEMENTING THIS GUIDANCE AND EXPECT TO HAVE A REVISED PROPOSED FINAL
                                                    DETERMINATION TO  OIG DURING THE 3RD QUARTER FY-91
                                                    = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION.
                                                    IG FOLLOWUP STATUS AT 3/31/91  (2)

                                                    P2GWN4-05-0264-6100390     DETROT WSD   Ml                         d/2'3/
                                                    'Summary: WE QUESTIONED INELIGIBLE FORCE ACCOUNT COSTS OF $20,872 INCURRED
                                                    PRIOR TO THE  GRANT AWARD IN ADDITION. UNSUPPORTED FORCF ACCOUNT COSTS C
                                                    $36,370 INCURRED  AFTER THE APPROVED CONSTRUCTION COMPLETION DATE WERE
                                                    QUESTIONED
                                                     EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEFN  MAM.. BASiT
                                                    ON RECENT  GUIDANCE FROM HEADQUARTERS. THE REGION  IS IN THE PROCESS  OF
                                                    IMPLEMENTING THIS GUIDANCE AND EXPECT TO HAVE A REVISED PROPOSED FINAL
                                                    DETERMINATION TO  OIG DURING THE 3RD QUARTER FY-91
                                                    = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                                    IG FOLLOWUP STATUS AT 3/31/91  [2]

                                                    P2CWN4-05-0263-6100391     DETROIT WSD  Ml                         8/25/1
                                                    Summary: THE GRANTEE CLAIMED UNREASONABLE FORCE ACCOUNI COSTS OF $236,COi
                                                    THE GRANTEE ALSO CLAIMED INELIGIBLE  COSTS OF $15,000
                                                     EXPLANATION  OF  THE REASONS MANAGEMENT DECISION HAS NOT BEEN  MADt. BASED
                                                    ON RECENT  GUIDANCE FROM HEADQUARTERS, THE  REGION  IS IN THF PROCESS  OF
                                                    IMPLEMENTING THIS GUIDANCE AND EXPECT TO HAVE A REVISED PROPOSED FINAL
                                                    DETERMINATION TO  OIG DURING THE 3RC QUAR1ER FY-91
                                                    = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION
                                                    IG FOLLOWUP STATUS AT 3/31/91  [3]

                                                    P2CWN4-05-0280-6100574     DETROIT WSD  Ml                         9/30/t
                                                    Summary: WE QUESTIONED INELIGIBLE COST OF $293,000 MOSTLY TOR CHANGE
                                                    ORDERS WE ALSO QUESTIONED UNNECESSARY COST OF $399,000  FOR FORCE
                                                    ACCOUNT AND GRANTEE  DELAYS  CHANGE ORDER COSTS OF $148,00 WERE
                                                    UNSUPPORTED
                                                    - EXPLANATION  Of THE REASONS MANAGEMENT DECISION HAS NOT BEEN  MADT: BASED
                                                    ON RECENT  GUIDANCE FROM  HEADQUARTERS, THE  REGION IS IN THE  PROCESS  OE
                                                    IMPLEMENTING THIS GUIDANCE AND EXPECT TO HAVE A REVISED PROPOSED FINAL
                                                    DETERMINATION TO  OIG DURING THE 3RD QUARTER FY-91
                                                    = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION:
                                                    IG FOLLOWUP STATUS AT 3/31/91  [2]

                                                    P2CWN4-05-0265 6100575     DETROIT WSD  Wl                         9/30'8
                                                    Summary: THE GRANTEE CLAIMED INELIGIBLE AND UNSUPPORTED CONSTRUCTION COSTS
                                                    OF $559,000 THE GRANTEE ALSO CLAIMED UNREASONABLE ENGINEERING  COSTS OF
                                                    $374,000
                                                    - EXPLANATION  OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN  MADE: BASFD
                                                    ON RECENT GUIDANCE FROM  HEADQUARTERS, THE  REGION IS IN THE PROCESS  OF
                                                    IMPLEMENTING THIS GUIDANCE AND EXPECT TO HAVE A REVISED PROPOSED FINAL
                                                    DETERMINATION TO  OIG DURING  THE 3RD QUARTER FY-91
                                                    = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION.
                                                    IG FOLLOWUP STATUS AT 3/31/91  [2]
54
-------
Assignment Control      Title
Number
Final Report
      Issued
Assignment Control
Number
Title
Final Report
      Issued
P2CWN5 05-024? 7000034        DETROIT WSD             Mi    10/6/86
•Summary WE QUESTIONED INELIGIBLE CONSTRUCTION AND LNGINEERING COSTS OF
$20,006 IN ADDITION  WE QUESTIONED UNSUPPORTED ENGINEERING COSTS OE $40,495
INCURRED AFTER THE APPROVED CONSTRUCTION COMPLETION DAI
  EXPLANATION OF THE REASONS MANAGEMENT EXCISION HAS NOT BEEN MADl
BASED ON RECENT GUIDANCE FROM HEADQUARTERS,  THE RFG'ON IS IN THE F'ROOE SS
OF IMPLEMENTING THIS GUIDANCE AND EXPECT ^0 HAVE A R!VISED PROPOSED UNA1
DETERMINATION TO DIG DURING THE 3RD QUARTER FY-91
  Dt SIRED TIME TABLE FOfl ACHIEVING A MANAGEMENT DfCISION
•'i FOLLCWUP STATUS  AT 3/31/91  |2]

-'2CWN5 05-0246 /'JOOC44     DETROIT WSD  Ml                        10/ 7/86
Summary: THE GRANTEE CLAIMED UNREASONABLE  FORCE ACCOUNT COSTS OF $336,000
  EXPt ANATON Of THE REASONS MANAGEMENT DFCISION HAS NOT BEEN MAD!. BAS! D
ON RECENT GUIDANCE  FROM  HEADQUARTERS, THE REGION IS IN THE PROCESS OF
MPLEWTNTING THIS GU'DANCE AND EXPECT IQ HAVE A REVISED  PROPOSED f'NAJ
DETERMINATION TO OIG DURING THE 3RD QUARTER FY-91
- DESIRED TIME TABU FOR ACHIEVING A MANAG1MENT DECISION
iG KM iOWL)P STATUS  AT 3/31/91  |2]

~2r,WN:,'05-0275 /G00045     DEiROIT WSD  Ml                        10,' /'SG
Summary. WE QUESTIONED $80,000 OF INELIGIBLE ENGINE F RING AND CONSTRUCTION
COSTS  ENGINEERING COSTS OF $11/000 INUJHRED AFTER THE  APPROVED
CONSTRUCTION COMPLETION  DATE WERE  NOT SUPPORTED
  EXPLANATION OF THF REASONS MANAGEMENT DECISION HAS NO! BEEN MADf  bAS; U
ON Pi SENT GUIDANCE  FROM  HEADQUARTERS THE REGION 'G IN Hit PROCESS OF
IMPLEMENTING THIS GUIDANCE AND EXPECT TO HAVE A REV'S! D  PROPOSED EINAI
DETERMINATION TO GIG DURING THE 3RD QUARTER FV t)1
- OFSIREO TIME TABU TOR ACHIEVING A MANAGE MINT DtGISION
IG fOLlOWUP STATUS  AT 3/31/91  121

'•'CWN5 05 0247 /000049     DETROIT WSD  Ml                        10; 8/'3G
Suwnary WE QUESTIONED UNREASONABLE TECHNiCAl SERVICES  AND  CONSTRUCHON
COSTS OF $559,000
  LXPIANATION OF THE REASONS MANAGIMLNT OtClSION HAS NOI BEEN MADE.
bASEO ON RECENT GUIDANCE FROM HEADQUARIERS, THE REGION IS IN THf PROOFS^
Oc IMPLEMENTING THiS GUIDANCE AND EXPECI 10 HAVE A REvlSID PROPOSED i !NA:
DETERMINATION TO OIG DJRiNG THF 3RD QUAR^R FV-91
  OfSIHEH TIME TABIF f()R ACHIEVING A MANAGFMINT DfCISION
'3 cOLiOWUP STATUS  AT 3'?V91  •?}

P2CWN5-05 0276 70000oO     DETROIT WSD  Ml                        10/8/86
Summary WE QUESTIONED $59,000 OF INELIGIBLE ENGINEERING COSTS ENGINEERING
COS IS OF $433600 INCURRED AFTER THE APPROVED CONSTRUCTION COMPLE'ION
DATE WERE NOT SUPPORTED
  EXPtJWAnON Of  M REASONS MANAGEMENT DECISION HAS NOI BEEN MADf liASFO
ON RECENT GUIDANCE  FROM  EiEADQUARTEPS, THE REGION IS IN THE PROCESS OE
IMPLEMENTING TIES GU'DANCE AND EXPECT T0 HAVE A Ri VISED  PROPOSED EiNAI
DETERMINATION TO C"G ;.H;RiNG THE 3RD QUARTER Ev 91
=  DESIRED I IMF TABLE I OR ACHIEVING A MANAGIMfNT EXCISION:
iG TOLLOWUP STATUS  AT 3-'3!/91  [?}

':2'3AI? 05 U136-7',>/}980     SAuGi i   "..                               ,v'.va/
Summary SAUGET IL WAS AWARDED FEDERAL  FUNDS 'N EXCESS OE $/ MILLION  'OR
INELIGIBLE AND UNNECESSARY PRO.IIC!  COSTS
  FXPIANATION OF TLK REASONS MANAGEMENT DECkSION HAS NOT BEEN MAI*  THE
AUCiT REPORT HAS COMPLEX ISSUES WI'H TOTAI QUESTIONED AND UNSUPPORTED
COSTS OF $15,323 316  THE REGION IS  SEEKING GUIDANCE FROM REGIONAL CQt'NSE:
AND AAFER DIVISION   A  DEVIATION Ri QUEST IS PENDING IN EPA HEAOQUARTI RC
=  IXSIRED TIME TABU FOR ACHIEVING A MANAGEMfNI DTCISION
:G fOILOW'.P STATUS  A1 1'ji'9i  {/>,

P2GWN6 05-0132-8000464     DETROIT W3D  Ml                         1/20/88
Summary DETROIT OLAIMtD INELIGIBLE COSTS OE  ALMOST $26 MILLION RESULTING
FROM ITS f All LIRE TO  HONOR A CONTRACT  WE ALSO QUESTIONED UNSUPPORTED
COSTS OE ALMOST $2 1 MILLION
  EXPLANATTON OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE THE
REGION  IS IN THE  PROCESS OF  IMPLEMENTING  GUIDANCE RECEIVED RECENTLY FROM
HEADQUARTERS AND EXPECT  TO HAVE A REVISED  PROPOSED FINAL DETERMINATION TO
OIG  DUPING THE 3RD QUARTER  OF FY 91
= LXSIRID TIME TABLE FOR ACHIEVING A MANAGEMINI DiCISION
'G rni'OW'l" STATUS  AT 3'31/91  '?]
                   P2CWN7-05 0237-8100724    DETROIT WSD  Ml                         8/29/88
                   Summary DETROIT, Ml CLAIMED OVER $2/4,000 OF  INELIGIBLE CONSTRUCTION COSTS
                   WE ALSO QUESTIONED UNSUPPORTED ENGINEERING AND FORCE ACCOUNT COSTS OF
                   $662,000
                     EXPLANATION OF THE REASONS MANAGEMFNT DECISION HAS NOT BEEN MADE: BASED
                   ON RECENT GUIDANCE FROM HEADQUARTERS, THE REGION IS IN THE PROCESS OF
                   IMPLEMENTING THIS GUIDANCE AND EXPECT TO HAVE A REVISED FINAL DETERMINATION
                   TO OIG DURING THE 3RD QUARTER FY 91
                   -  DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION:
                   IG  FOLLOWUP STATUS AT 3/31/91  |2]

                   P2GWN5-05 0169-8100774    DETROIT WSD  Ml                         9/1/88
                   Summary WE QUESTIONED INELIGIBLE CONSTRUCTION AND ENGINEERING COSTS OF
                   $96,520 ENGINEERING COSTS OF $992,430  INCURRED AFTER THE  APPROVED
                   CONSTRUCTION COMPLETION DATE WERE NOT SUPPORTED
                     EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE. BASED
                   ON RECENT GUIDANCE FROM HEADQUARTERS, THE REGION IS IN THE PROCESS OF
                   IMPLEMENTING THIS GUIDANCE AND EXPECT TO HAVE A REVISED PROPOSED FINAL
                   DETERMINATION TO OIG DURING THE SECOND QUARTER FY-91
                   ---  DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION
                   IG  FOLLOWUP STATUS AT 3/31/91  [2|

                   P2CWP6 05-0111-9400026    PON1IAC  Ml                            3/31/89
                   Summary THE GRANTEE CLAIMED INELIGIBLE CONSTRUCTION AND ENGINEERING COSTS
                   OF $12852? AN ADDITIONAL $134,735 OE UNSUPPORTED ENGINEERING COSTS WERE
                   QUESTIONED
                     EXPLANATTON OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE' THE
                   AUDIT WAS  IN UTIGATION UNTIL RECENT!Y  A REVISED FINAL DETERMINATION LETTER
                   WAS  ISSUED ON 3/29/91
                   -  DESIHfO TIME TABLE TOR ACHIEVING A MANAGEMENT DECISION  AUDIT SHOULD BE
                   CtOSED SHORTLY
                   IG  FOLLOWUP STATUS AT  3'31/91  (3)

                   REGIONAL ADMINISIRATOR. REGION 3
                   P2CW8 03 01/8-0100536     GREENBRIER CO PSD fr2 WV                9/28/90
                   Summary REGIONAI  ADMINISTRATOR,  REGION 3 RECOMMENDED COST  RECOVERY
                   INCLUDES INELIGIBLE  ($1,1/6,607) ADMIN AND  LEGAL EXPENSE,  AE BASIC, OTHER Ah
                   AND PROJECT INSPECTION FEES AND CONSTRUCTION AND FQUPMENT COSTS,
                   UNSUPPORTED ($216,599) ADMINISTRATIVE EXPENSE & CONSTRUCTION COSTS,
                   UNREASONABLE ($216,599) AE BASIC FEES
                    EXPLANATION Of THE RFASONS MANAGEMENT DECISION HAS NOT BEEN MADE: DUE TO
                   THE DIFFICULT ISSUES INVOIVED AND THE LENGTH OE TIME NEEDED BY THE  PROGRAM
                   OFFICIALS TO RESPOND TO THE AUDIT FINDINGS THE TIME REQUIRED TO COMPLETE THE
                   PiSOLUTION WAS LONGER THAN NORMALLY NECESSARY
                   -= DESIRED TTMf  TABLE FOR ACHIEVING A MANAGEMENT DECISION: RESOLUTION
                   EXPECTED BY MAY 31, 1991
                   IG  FOLLOWUP STATUS AT 3/31/91  [4]

                   REGIONAL ADMINISTRATOR, REGION 4
                   E2CWN7-04-0302-0300C54     SYEACAUGA UTILITIES BD AT               5/10/90
                   Summary: THF GRANTEE TERMINATED THE ORIGINAL CONTRACTOR FOR CONVENIENCE
                   AND D€  NOT  HOLD THE CONTRACTOR AND/OR  THE BONDING COMPANY FOR CHANGED
                   SITE CONDITIONS AND INCREASED COSTS OF  $1  6 MILLION
                    EXPLANATION OF THE REASONS MANAGEMENT DECISION  REGION AND DIVISIONAL OIG
                   CANNOT REACEi AGREEMENT ON A MANAGEMENT DECISION  OIG MAY REFER AUDIT TO
                   ERA'S ALJDIT  RESOLUTION BOARD (ARB)
                   - DESIRED TIME TABIE FOR ACHIEVING A MANAGEMENT DECISION
                   IG  TJLLOWUP STATUS AT 3/31/91  (21

                   REGIONAL ADMINISTRATOR. REGION 5
                   E2AWTO-05-0223-0400020     SELIERSBURG EWS  IN                    6/14/90
                   Summary REGION  5 AWARDED A $5 5 MILLION STEP  2+3  GRANT TO SELLERSBURG, IN
                   FOR A PROJECT WHICH DID NOT MEET THE ELIGIBILITY REQUIREMENTS FOR A STEP  2+3
                   GRANT
                    EXPLANATION Of THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE: REGION
                   AND DIVISIONAL OIG CANNOT REACH AGREEMENT ON A MANAGEMENT DECISION  THE
                   RESOLUTION  MAY  BE  ELEVATED TO EPA'S AUDIT  RESOLUTION BOARD (ARB)
                   = DESIRED TIME TABIE FOR ACHIEVING A MANAGEMENT DECISION
                   IG FOLLOWUP STATUS AT 3/31/91  fl)
-------
Assignment Control
Number
Title
                               Final Report
                                     Issued
Assignment Control
Number
1 Hie
                               Final Repo
                                      liSSUC
E2AWTO 05 0224 0400045     W  'ERRE H'.OIE FV.'S  .N.
Summary: RLGION 5 AWARDED A 3TP ?<- > GRAN! Of $,•> > •':;  !- r   : 'A' -.' '
HAUTE. IN FOR A PROJECT WHIU' DID NOT MIL!  ;ht Fi 1P,I>. !  v' -ilOJ'f-iMiN '
STEP 2+3 GRANT
  EXPLANATION OF [HE REASONS MANAGEMENT DECISION HAS  NO! 8LI N MAi>
AND DIVISIONAL DIG CANNOT REACH AGREEMENT ON  A  MANAGE Ml Ni OF "INGN
RESOLUTION MAY BE ELEVATED TO EDA'S AUDiT -'LiOlUllON BOARD |A«>','.
= DESIRED flMF  TAB1F FOR ACHIIVING A MANAGEMENT D6CISION
'G FOLLOWUF S'A1!> A! 3'3 -91  [1]

REGIONAL APMTN'CTRA' ™, R>. iiCN 1
P2CW8-0"1 004? 0100533     ALLFNSIOWN  N"
Summary CLAIM! D UNAElOWAEiLt COSTS OE $21952o ($6f O'-v iM  G<3E! AN
$159,500 UNSUPPORTED! FOR THE CONSTRUCTION OF A SWAGE  THEAlvtENi >-
  LXPLANAT10N Of THt REASONS MANAGEMENT DIVISION HAS  NOT Bf EN MADi
T ,'19/90, THE REGION SUBMITTED IIS FINAL DEIF RMINATION LEfitR TQ THt  : ,
Old ASKED FOR ADUIHONAL INFORMATION WHICH WAS  SUBSFGUiN1^ "R^VO-
AND MANAGEMENT ARE NOW 'N AGREEMENT AND  AUDIT WIU B: UO,,EF, SHOP"
= DESIRED T1ML TABU fOH ACHIEVING A MANAGtMfNT DfCISION  AUD'T W.' ;  -,
CLOSED SHCRT^
IG FOLIOWUP :;iAT, ? AT T":  ?   <;>j

REGIONAL ADMINlSFRAlOfi, HIGION ?
P?CW8-02 U0,?8 irCC'129     NYC  SPRING CnKtK  NY
Summary THE GRANTEE CLAWD TOTAL UNALLGWAtji ?  rn-M-   ,.  «,".!',',' ;  > '
PF$;G\i AND CONSTRUCTION OF A -iMl-NTlON P.A;-iN
  FXPIANAFION OF THE REASONS MANAGI MtNT DECISION HAS  NOT BtfN MALM
NEW VORK S!ATL  DFP1  OF ENViRONMi N'Ai  CONSEPv'A'iON iS  ;'i  iJiLGATM
Ai'lMflRi'Y R;SPONC^LE  l-CR THi AUDIT '-,  RECC^dCN  A  F SA   " '  OV'.A'
LETTER WAS 'SSL'ED 2/22 9'   '.' : C^G A»t" " 'P AUUil ON''   'Mi O'-.V,',' ; ^  /
WAS SLBSf OUENTI V PrtOVjif,
- DCvSlRFD TIME TABIF FOfi AC'J HIVING A MANAU'MlNf Dl GISlON  • »     -
RFSOLLjTiON IS 3PD QLIAr-^R lyn'
ic ! 'LLOwijF STATUS AT 'i ::i  :'   2:

P2CW7 C2-C220 01031,'Jt)     vVESTCHESTLR GO  N"'
Summary; I HI  jFiANTil C..AiM[D fOTAt LiNAvlOWi'Lt  v.O^t  o-  $'. V; ' ' ' >
UPGRADE A WASTEWATER  FRFATWENT P1ANT
- IFXPIAMAIION OF IHt REASONS MANAGLMFMT DiClSION HAS  NOi BUN MAM
AUC:T  RESOLUTiOlM PREPARFD ijY NEW VORK StAi'  ijFPT ;,» :_\V1; . '\Vt N Al
GCNSERVATION IS BHNG HELD 'PEND.NC A 'JECIJON f>J In'"  ViAV>, \
NCN-COMP'hANCF WITH InE 'JbER CHAF^oE  R'Q'li^EVF-N'G C'F  !,-:   , • A\ »V''',:
'I'F CASE ;o -3HNC' FitVlE.v'tj iN FrJA '1(3  tA\' "FO T-F "j .  ;  , \   '-A',.,"''. ,
DECLSiON
- DfSIFCD TIMF  TABLE K» ACIIILVlNi:; A MANAGIMf Ni IJtCISKW
1C 'OIL'WJ^ C; ':  ' •'   \'<  ~.
Lt'">L;H ON 3/28/01  lnlS INECPMAFION WAS PR'ii/.E'FP  C ,HF   .1
= L> SIRED 1IMF lARLt FOR ACHIEVING A MANAGi MEMS CHCKION   •  f  '.:
RESOLUI'ON IS 3RD QUARTER ''t!01
;G F3l!OVK'P C'ATIK AT 5/j1,T   ^

P?CiV"fi  02 019' C'.w'V     NIAGARA ! -V S  *u
Summary THE GFIANTtE CiAiMF ) ;:::•''!  -JNAl ' Jv/A^ t  "'\-,i      j  -'  ','  -  •
STUDY Oh EXCtoS'iVf. DHY  WEAT1'FR '"'.OvVS IN  !r':  AAolLv\,''' <  TH'A'ViN   -
CONVEYANCi .V-oTEV >  ''!-(ifr   INF  iG!RI_-  (,0?"S"'ALi  $;"•:.   ' •'<-,
UNS'JPPOHIED COSTS FQTALU) $34,818
  FXPLANATiON CM iHF REASONS MANAGFMINI  ftCISION llA,S NOi BliN MAi>
NFW /DflK !TArF Pi0!  OF t \'v!rfONVEM Al  rONSiRVAi.ON  -•'.  ' ')  "> 'A.1.   r
LETTER ON 3/U/91  TH6 INFORVAFION WAS PRC'ViDf'J !u 'K  0")
  DFSIHn) I1MF TABIE TOO ACHIFViNC A MANAGI Mf.Nf DLCISION  I. < " ' :
F-FSOtL'FlON IS 3RD GijAF^EH 1^1
vj -Oi _OV»IP SrAU" AT '-1/31, '>1  !"•
                                                     "our (nary.
                                                       IXI'LANAFION (If lill RIASONS MANAGi MFNF DfCISION HAS NOT BUN MADE  HE
                                                     '•f'-fj YORK  SlAU DF1'  i>  FNV:'i'->jf/i fA!  CONSERVATION [S  'UF DETEGAT-'D
                                                     A.JTi ORI!V  RELPOW, r FOP OF  H  v-uJ.ON ">' CONSTRUCTION GRANT AUDiiS
                                                     NYSI'EC CEUCE HAMDLING AUDIT 'if S''E jTlCN^ HAS RECENTLY UNDERGONE A MAJOF
                                                     REORGANIZATION A"H SOMF AT.!^;'.N! Dt L «Y  fXPECTED
                                                     - DfSIRED  TIME iABtl (OR ACIIIfVINC. AMANAGFMfNT DECISION- R! SOlbTiCN IS 3R
                                                     .J.'/V-TER 193'
                                                     Summary: CiTY ''  .OFTlANO  NY OIAMED UNALLOWABLE COSTS OF  $941,594
                                                     COMPRISED OF iNhldlBLF CCS.', 01  1356,803 AND UNSUPPOR 1D COSTS OF
                                                     $.34791  HEV 'OS'S REL All T.'; HE CONSTRUCTION OF !NTf POEPTORS, EXPANSi
                                                     AND UPGRADING OF A f-PIM.»RY rt-"-r  I .ANT
                                                       fXPLANAIiON t> TW REASONS MANAGI Ml Nf MCISION HAS NOf BFEN MADI  THE
                                                     N'.W YCFV STAT- LEP"  OF  I SVRCNMFNTAL  CONSERVATION 13 THE DELEGATED
                                                     frr- npiTY REST AvBi F f  R Ti"_ •:;;.'": UT'ON Oi  CONSTRUCTION GRANT AUDITS
                                                     MYS." EC 0FriCE  'A'.DLING A1; ill R ':'~ LJTIQNS HA.. REDEN'IY UNDERGONE A MA, OR
                                                     •OT-JAN/ATiCA  vV.TH BuM,' A'iiNij;'.N' T)ElAf
                                                     - IX:>IRED HMI IA8IF FOR ACHIEVWC A MANAGIMFNT DfCISION EXPECTED
                                                     KS  UTICN  IS '''if. OUAfrFR 1'!"
                                                     "   %L' A"'^ -,1f: !- AT T31  ':'   '

                                                     ".CVi'o f'2-'V'  ' :   !'!•'      '31,', i'A1 T!M(;.-i;  Nv '/  3/90
                                                     "Suminary
                                                       IXIMANAIION (>t 'HI RIASONR MANAGIMENI DfCISION HAS NOT BFIN MADf  THE
                                                     SEW 'OPK S'A   '.:-.( !  '.'•  . r/,13  r >:     ,„_  .-,. ^IONU  CONSTRUCTION GRANT AUDIFS  1

                                                     'E>; JAV.'A" ON  "-•  <  ,,M! A' '-N.V.N; :IE; AY
                                                              IIM! fAWS FOR  ACtliiVSNC A MANAtiMlNT DiXlSION- FXPiCTE'i
                                                     liumi'iary,  -  v'i >/,   0- S^^'N  -, ,\r H NY Ci AIMED TJTAL UNAi EOWABlE COSTS
                                                      .  $, ",,.V."  0 V-Mii D Of NfL.'.i1,,  t COS FS OF $-484,565 AN3 UNSUPPORTED CO1
                                                      1  i '"fi'  A-  : .iV"1 .,-:">'  •     i'^M«UCTION 0,  INIERCtPFING SE WERS !'UM
                                                     ,  A, ;N,,, A'JT  ' Ti:, r' f  »\,\s I /, :•  'P IREAiWINT PL AN"
                                                      TXi ACTION  CM  H! HI ASC*IK MAMWMINT DfCkSION HAS NOI BUN MADf- HE
                                                      •A  '••'« ,c  A   •  .•"  ",  tf.v -"f v  MAI. oo'NSiFIXATION >s  >'f DELEGATI-,.
                                                     .v !ii '-<]!' Rrr i  ••,')"'',  if,'  '••!    -',i  o\ rc ;"iNSTuuc''CN GRAN: AI;,~ ;s   T
                                                     ';•'-.:• .  "•"'.-  •."  ' ""  -;.'        , TI N,-. i,". M;(..NI;'I i NIX-GONF.  A MAJOR
                                                     i ! "r>, jANIZAT Op, ,\ ,i -.;;Mt \   N • K1 UtLA\
                                                       ijf.:iR[n TIMI  IM;:- ;nn A-;HI|V,N(, A MANAGIMLNT IMCKION  ix^YCTin
                                                     !-i)nvr,i*y
                                                       |X|".ANAflON i < Hit ;«ASOHS MAKAUMINI  DfCkSION HAS NOf BEEN MADf  THE
                                                     '.r-\   3HK  S"AT   .,.'  -v  i*,V')  '/v-NiAL  CONSERVATION ISSUED A FINAL DE ('S 0"»
                                                      >  '• i  "'.  3/1'   •    '  '- '\i'r-l,i.' i 1\ WAi pRi'VPFL  TO TFiF  OG
                                                       Df.riRlD  1IMI  IAl,lt t OR ACHII V!W. A MANAGi MI NT DFCISION  EXIfCi'D
                                                       tXP!AWiK)N Of iHi WAvSON-S MANAGi MINI  DFCISK)N HAS NOI FiFIN MAIX "  HE
                                                     \,D'i Rr- .R: :s. .•!• . MJVIP ^,- ,'-MS OF j'JLSiiOMEO COSTS  AS WEII AS
                                                      ir\.r '_,.'•%'  ' ",". OH \'AN-V',J,'FN: AMD IN E-'NAL CONTRO!  DEMCIENCIEC  TUAr
                                                     •it. ;;-. T'J ;•• AM-E-V'"   " J,i 'I".AI  R^sos'iiiCN is CMRI'INTEY CiRCiJ'AUNG FOR

                                                       IXSIRI n TIMI  . Wll i i OH ACHIl VING A MANAGI Ml N! Hi CISION: i XPECTEi
-------
Assignment Con
Number
                                                                  issued
Assignment Control     Title
Number
Finai
      Issued
                                                                                                                            •,.   ,',  -   ." i  '-'   •

                                                                                  AH"  i. •  -f.."     N-'i..  V-:-   .   '.-     $  "'<•;•

                                                                                             Or Ml  RiASORS MANAGfMIN!  IHONON HAS «*'.;  SI! IS MAN
                                                                                     *«D 'IMI  iAIM-   OH ACtWVING A MANAJVMIN! Ota"
 i' Ji N/V. -(.*)!«? '':' !-!  i  '"!( -
                                           ' '„ * M •,' •  **;;  it! M H ^ *
          KM!  !/«>'. "i/!
                                  -. a.'W. y Ml N "
              y   in i-i V-M, -ilHAi.! Mi ••  'X IV*, • ,AS NO' •'»('
                                                                                                                           aSK_if, "A- NIJ! !'HN
                                                                               '.ui'ir'Kiii    ',       J '  •   • i! .'.        '-   \ '   '-   .  .  '  •  •   •" A '".


                                                                                 iXIMAN/V.'irfi  X  •  ii  i-i vkltv. MViAu Mi«; in i.frk* HA.1, f*'!l iJ! I N MAiJt
  •' XI'(ANA I ION (X  I' ii IV AK1MS, ,VlWt) j Mi (i  '
                                                                                  H;-.!!!':,  iW,  'V< •  i >'• AtMII'viW  ' WAMu'W Ni:  )!(,:, KIN '
                                                                                   rj '-AjJK-W  „   ht  't-ASCTC MA.V.JT M' -i'  l<':iSK*, '1A' N(i' BUN MAIN
  i ", 'i Af-A.lON :)f  it -i! A^'H'. Nfc.'iA. x M!N' '' !,t-'K  .>',  •*    .1 -
                                                                                 •Xl'i «iN,\!KW (If Hft  i^lASOMf" MANAfjIMIV  [XCISWN HAS Nil' "i (S MAi)t
                                                                                 N > • /i.,  •   -:  • '.,  V*K i M »j '--v   ,    !•',,,'.,  ,v.   ,,   , ,-•
  Di  flfD  -,u
                                   MANAGI knl N!
-------
 Assignment Control      Title
 Number
Final Report
      Issued
Assignment Control
Number
Title
Final Report
      Issued
 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
 GIG HAS TRANSMITTED THIS AUDIT  TO THE AUDIT RESOLUTION BOARD (ARB) FOR
 RESOLUTION  IN ADDITION, THE REGION IS CONTINUING TO WORK WITH THE  DIVISIONAL
 GIG TO RESOLVE THE ISSUES IN THE AUDIT
 = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION:
 IG FOLLOWUP STATUS AT  3/31/91  [5)

 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"
 - EXF1ANAT10N OF THE REASONS MANAGEMENT DECISION HAS NOT BFFN MADE
 RESOLUTION OF THIS AUDIT IS BEING HELD IN ABEYANCE PENDING ISSUANCE OF AN
 ADDITIONAL AUDIT OF THE MONTEREY REGIONAL POLLUTION  CONTROL AGENCY
 = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION:
 IG FOLLOWUP STATUS AT  3/31/91  [5]

 REGIONAL ADMINISTRATOR, REGION 6
 E2CWN8-06-0037-0300055     BARTLESVILLE OK                        t/1 1/90
 Summary: AUDIT OF CONSTRUCTION GRANTS C-400690-01,02,03,12,13 & 14
 QUESTIONED COSTS OF $10,974,785 (FEDERAL SHARE  $8,189,026) THE GRANTEE
 FAILED TO UPDATE FACILITY PLANS AND  COST EFFECTIVE ANALYSIS EVEN THOUGH
 DESIGN INCREASED CONSTRUCTION COSTS FROM $31 M TO $9 8 M
 - EXPLANATION OF TOE REASONS MANAGEMENT DECISION HAS NOT BFFN MADE. A
 REQUEST FOR DEVIATION FOR CITY OF BARTLESVILLE ON PROJECT PERFORMANCE WAS
 SUBMITTED TO EPA HQ A TOTAL  OF $101,320 WAS QUESTIONED.  EPAS SHARE IS
 $75,990.  ESTIMATED COMPLETION OF DEVIATION REQUEST IN EPA HEADQUARTERS IS
 5/91
 = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMFNT DECISION.
 IG FOLLOWUP STATUS AT  3/31/91  [3]

 REGIONAL ADMINISTRATOR, REGION 8
 E2CW7-08-0036-0100418     THREE LAKES WATER & SANIT   CO           7/31/90
 Summary: THREE LAKES WATER AND SANITATION DISTRICT, GRAND LAKE CO DID NOT
 PROCURE CONSTRUCTION)l SERVICES FOR THE BUILDING OF THEIR NEW $14 MILLION
 WASTEWATER TREATMENT WORKS  BASED ON THE LOW COMPETITIVE BID IN ADDITION,
 THE CLAIMS FILED WITH EPA COULD NOT BE SUPPORTED
 - EXPLANATION OF THE REASONS  MANAGFMENT DECISION HAS NOT BEEN MADE: THE
 REGIONAL OFFICE PREPARED A MANAGEMENT DECISION LETTER ON  10/24/90 ~ AT THAT
 TIME, A DEVIATION  REQUESTWAS PREPARED FOR REVIEW IN  EPA HQ RESOLUTION  IS
 PENDING THE FINAL DECISION ON THE DEVIATION REQUEST
 = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION
 IG FOLLOWUP STATUS AT  3/31/91 |1)

 P5BHN9-08-0092-0300096     SO  ADAMS  COUNTY WSD  CO               9/27/90
 Summary: SOUTH ADAMS COUNTY  WATER & SANITATION DISTRICT (SACWSD) DID NOT
 PROVIDE CONTRACTS FOR IT'S WATER TREATMENT FACILITY IN A MANNER THAT
 ASSURES A REASONABLE  PRICE OR THAT THE BEST OFFERORS ARE AWARDED
 CONTRACTS  SACWSD ALSO APPROVED UNNECESSARY CHANGE ORDERS
 - EXPLANATION OF THE REASONS  MANAGEMENT DECISION HAS NOT BEEN MADE: THE
 REGIONAL OFFICE PREPARED A MANAGEMENT DECISION LETTER ON 12/20/90 ~ AM HAT
 TIME, A DEVIATION REQUEST WAS  PREPARED  FOR  REVIEW IN EPA HQ  RESOLUTION IS
 PENDING THE FINAL DECISION ON THE DEVIATION REQUEST
 = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION.
 IG FOLLOWUP STATUS AT 3/31/91   [1]
                   REGIONAL ADMINISTRATOR. REGION 10
                   P5CHN9-10-0151-C300095     OREGON DEQ  OR
                   'Summary:
                    EXPLANATION OF THE REASONS MANAGFMENT DECISION HAS NOT BFFN MADE  THE
                   PROJECT OFFICER SENT A RESPONSE TO THE DIG  ON 2/14/91 DIG ASKED FOR
                   ADDITIONAL INFORMATION ON 3/18/91  PROGRAM OFFICE  IS PREPARING THE FiNAL
                   DETERMINATION LETTFR
                    DESIRED TIME TABLE FOR ACHIEVING A MANAGEMFNT DECISION AUDIT SHOULD BE
                   CLOSED SHORTLY
                   IG FOLLOWUP STATUS AT 3/31/91  [I]

                   E2AWPO-10-0017-0400012     ELBE WATER DIST EARLY  WARN  WA          3/30/1
                   Summary: THE ELBE WATER & SEWER DISTRICT PROPOSED  TO CONSTRUCT A $2 2
                   MILLION MODIFICATION OR REPLACEMENT  TO SERVE  39 HOUSES (ABOUT $60,000 PER
                   HOUSE)  HOWEVER, THE PROJECT WAS NEITHER COST  EFFECTIVE  NOR DID IT QUALIFY
                   AS A MODIFICATION OR REPLACEMENT PROJECT
                    EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE. A
                   TECHNICAL REVIEW TO DETERMINE IF THE  ISSUES RAISED IN THE AUDIT WERE CA'JSEO
                   BY A FAILURE IN DESIGN IS STILL IN PROCESS  HEAVY WORKLOAD IN  THE PROGRAM
                   Of FICE HAS DELAYED THE COMPLETION OF THE REVIEW
                   = DESIRED TIME TABLE FOR ACHIEVING A MANAGEMENT DECISION
                   IG FOLLOWUP STATUS AT 3/31/91  PI

                   E3BG'6-10-0066-8109761     MOSLS LAKE IRR & REHAB DIST  WA         8/31/f
                   Summary: INTERIM AUDI* OF DEMONSTRATION GRANT TO RESTORE MOSES LAKE  AND TC
                   CONTROL NON-POINT POLLUTION SOURCES FOUND TOTAL  COSTS  QUESTIONED OF
                   $2,439,103 (FS $1,205,039)   GRANTEE  USED  STANDARD METHODOLOGY INSTEAD OF
                   DEVELOPING NEW INNOVATIVE TECHNIQUES
                    EXPLANATION OF THE REASONS MANAGEMENT DECISION HAS NOT BEEN MADE. EPA S
                   AUDIT RESOLUTION BOARD (ARB) IS REVIEWING  THIS AUDIT  CURRENTLY, THE OFFICE 0
                   THE GENERAL COUNSEL IS ESTABLISHING A LEGAL TEST TO ADDRESS  THE ISSUE UNDER
                   REVIEW
                   = DESIRED TIME TABLE FOR ACHIEVING A MANAGFMENT DECISION:
                   IG FOLLOWUP STATUS Al 3/31/91   [C]

                       TOTAL AUDITS ISSUED BEFORE REPORTING PERIOD FOR WHICH NO MANAGEMENT
                               DECISION WAS MADE DURING THE REPORTING PFRIOD     67
                   " Agency procedures do not require the 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 providec a summary o!  the audit

                   " Although the Agency s response indicates that a management decision had been made on
                   this audit,  the  DIG audit tracking system indicates  that the response had either  not bean
                   received or reviewed tc determine acceptance in accordance with the Agency's followjp
                   system guidance  On the 'irst of each mor.th we  furnish the Agency's followup coordinator
                   with the status of each open audit to oe resolved, a copy of all the accepted management
                   decisions and  resulting audit closeouts and  the  related dollars sustained  The Agency had
                   not  prevously brougT to our attention  that  an alleged management decision had been made
                   on this audit
58
-------
Mailing Addresses and Telephone Numbers  •  QIC 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 30X9
Audit: (404)347-3623 FTS 257-3623
investigations: (404)347-3623
FTS 257-3623

Boston
Office of Inspector General
JFK Federal Building DIG 521
Boston, MA 02203
Audit: (617) 535-3160 FTS 835-3160
!nvestigations:(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, KS 66101
Audit: (913) 551-7824 FTS 276-7824
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

Sacramento
Office of Inspector General
801 I Street Room 466
Sacramento, CA 95814
Audit (916) 551-1076 FTS 460-1076

San Francisco
Office of Inspector General
75 Hawthorne St (I-4)
19th Floor
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
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
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IT. H.
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               Report
               Fraud
               Waste or
               Abuse
               to the
               Inspector
               General
               HOTLINE
    Information is Confidential
    Caller Can Be Anonymous
    800-424-4000 or 202-382-4977
vvEPA
  U.S. Environmental Protection Agency
  Office of the Inspector General
  401 M Street S.W.
  Washington D.C. 20460
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